Case Digest (G.R. No. L-2383)
Facts:
The case centers on a petition by the City of Manila, which sought the registration of a parcel of land measuring 16,412 square meters located in the Paco district of Manila. The Roman Catholic Church opposed this application, asserting its historical claim over the land. The Church contended that it had occupied the site for its church, convent, and cemetery since around 1801 until 1899, when both structures were destroyed by the United States Army during military actions. The Church emphasized that it had consistently asserted its exclusive right to this property, even filing a declaration of possession upon the establishment of property taxes in Manila and continuing to pay taxes on it up to that time. During the lower court proceedings in the Court of Land Registration, both parties presented evidence acknowledging the land in question's historical use as the site of the church and convent until their destruction. The court also noted that this plot was previously part
Case Digest (G.R. No. L-2383)
Facts:
- Parties Involved
- The petitioner and appellant: The City of Manila.
- The respondent and appellee: The Roman Catholic Church.
- Subject Matter and Application
- An application was filed by the City of Manila for the registration of a parcel of land situated in the district of Paco within its jurisdiction.
- The boundaries of the land were described in detail in the plan and the application, covering an area of 16,412 square meters.
- Historical Background and Possession
- The Roman Catholic Church contended that the parcel in question had been the site where its church, convent, and cemetery of Paco were established.
- It was admitted by both parties that from about 1801 until 1899 the church and convent of Paco occupied the location.
- In 1899, during the war, the church and the convent were destroyed by fire, caused by the United States Army.
- Evidence of Exclusive Possession
- The Church argued that it had long exercised exclusive possession over the parcel.
- When the land tax was established in the City of Manila, the Church filed its declaration for the exclusive possession of the property.
- The Church had continuously paid the taxes imposed on the said property, further reinforcing its claim of possession.
- Additional Historical Context
- It was also admitted by both parties that the plot was only a portion of a larger area originally granted by the Spanish Government.
- This grant was made to the inhabitants of the town of Dilao or Paco.
- The grant served as compensation for land formerly occupied by them, which was expropriated due to its proximity to the city fortifications, contrary to the royal ordinances.
- The historical use of the land for the construction of the church complex played a key role in establishing the Church’s claim over it.
Issues:
- The Effect of Destruction on Possession
- Whether the destruction and subsequent disappearance of the church and convent buildings in 1899 extinguishes the real right of possession previously held by the Roman Catholic Church.
- Validity of Tax Declarations and Continuous Possession
- Whether the continuous payment of taxes by the Roman Catholic Church, along with its declaration of exclusive possession in the land tax system of Manila, is sufficient to maintain its right despite the absence of the original structures.
- Implication of Prior Grants and Historical Use
- How the historical grant by the Spanish Government to the inhabitants of Paco (including the Church’s subsequent occupation) affects the current dispute over land registration.
- Relevance of Residents’ Conduct
- Whether the appellant’s contention that the residents merely permitted or tolerated the construction of the church for contributory reasons has any bearing on the established possession rights of the Church.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)