G.R. No. 208284 - Iglesia De Jesucristo Jerusalem Nueva of Manila, Philippines, Inc. vs. Dela Cruz

The petitioner is the Iglesia de Jesucristo Jerusalem Nueva of Manila, Philippines, Inc., represented by its president, Francisco Galvez.
The respondent, Loida Dela Cruz, also represents and asserts authority on behalf of a similarly named religious group, using the designation Church of Jesus Christ, "New Jerusalem," and involving all persons claiming rights under her.
The dispute centers on a parcel of land covered by Original Certificate of Title (OCT) No. 35266 and corresponding Tax Declarations (TD) purportedly owned by the petitioner, with allegations surrounding the rightful owner and proper representation.

On March 26, 2007, petitioner filed a Complaint for unlawful detainer with damages before the Metropolitan Trial Court of Malabon City.
Allegations include:

The petitioner’s claim of being a religious corporation with a long history dating back to 1940, founded by Rosendo Gatchalian, with Galvez identified as a relative of the founder.
Ownership of a subject lot measuring 204 square meters and 71 square meters as evidenced by OCT No. 35266 and its corresponding TD.
Historical fact that a chapel built on the subject lot was used exclusively by members until after the founder’s death; subsequently, after disorganization of the membership, any visitor was allowed to use the chapel.
The claim that, in 1998, without the consent or knowledge of the entire membership, Dela Cruz organized and created the organization known as Church of Jesus Christ, "New Jerusalem," effectively claiming authority over the subject lot.
A demand on February 12, 2007, was issued that the respondents vacate and surrender possession, which was refused by Dela Cruz.

The petitioner’s position is reinforced by documentary evidence such as a Secretary’s Certificate, various OCT and TD copies, SEC Certificate of Incorporation, and related court orders and proceedings.

Dela Cruz alleges she is an officer of the Obispo Representante at Pastor General ng Iglesia ni Jesu Cristo "Bagong Jerusalem" Inc., asserting her authority is evidenced by a board resolution and a Secretary’s Certificate.
Her answer denies specific allegations by the petitioner regarding her office address, the property’s registration, and the authenticity of the petitioner’s title and evidentiary documents.
She contends that the records (including OCTs and TDs) already bear the name of “New Jerusalem, New Church of Jesus Christ” or similar variations, and that petitioner’s reconstituted title was obtained under irregular pretenses after the alleged loss or misrepresentation of the original title.
Dela Cruz further asserts that any ejectment case filed by her was aimed at clarifying her authority and that petitioner’s subsequent actions were merely retaliatory and without merit.

The Metropolitan Trial Court (MeTC) dismissed petitioner’s Complaint for lack of evidence, emphasizing that petitioner failed to prove a better right of possession.
The Regional Trial Court (RTC) affirmed the MeTC’s decision, clarifying that the subject property was registered in the name of “The Iglesia De Jesucristo Jerusalem Nueva of Manila, Philippines, Inc.” and that the only issue was who was authorized to represent the registered owner.
The Court of Appeals (CA) denied petitioner’s Petition for Review and reaffirmed the lower courts’ findings, highlighting the credibility and consistency of Dela Cruz's evidence regarding her authority.

The petitioner contends that his evidence is clear and convincing, alleging that respondents failed to present sufficient evidence on their claim that the petitioner’s organization and Dela Cruz’s organization are the same.
He argues that a Torrens Certificate of Title cannot be subjected to collateral attack.
He disputes the CA’s finding that Galvez voluntarily vacated the subject lot, maintaining that he still enjoys possession therein.

Whether the Court of Appeals seriously erred in dismissing the appeal despite petitioner’s contention that:

There was clear and convincing evidence showing his right to the disputed property; and
The respondent failed to present evidence to prove that the petitioner’s and respondent’s religious corporations are one and the same entity.

Whether the CA erred in dismissing the appeal on the ground that a validly issued Torrens Certificate of Title should not be subjected to collateral attack.

Whether the CA erred in its conclusion that petitioner’s representative, Galvez, voluntarily vacated the subject lot, particularly in light of the ejectment case filed by the respondents.