Case Digest (G.R. No. 179597)
Facts:
In Iglesia Filipina Independiente v. Heirs of Bernardino Taeza, the petitioner, Iglesia Filipina Independiente (IFI), a duly registered religious corporation under the 1987 Constitution, owned Lot 3653, a 31,038-square-meter parcel in Tuguegarao, Cagayan, covered by Original Certificate of Title No. P-8698. Subdividing Lot 3653, IFI sold Lot 3653-D to Bienvenido de Guzman between 1973 and 1974. On February 5, 1976, its then Supreme Bishop, Rev. Macario Ga, executed a Deed of Sale with Mortgage conveying Lot 3653-A and 3653-B (10,000 square meters) to Bernardino Taeza for ₱100,000 in installments, allegedly fully paid. Unknown to the laymen’s committee of the Tuguegarao parish, which formally opposed the sale by resolution, Rev. Ga never secured the required concurrence of the laymen’s committee, parish priest, Diocesan Bishop, and Supreme Council under Article IV(a) of IFI’s Canons. In 1977, the laymen’s committee unsuccessfully sought annulment of that deed before the Court ofCase Digest (G.R. No. 179597)
Facts:
- Ownership and Subdivision of the Property
- Iglesia Filipina Independiente (IFI), a corporation sole, owned Lot 3653 (31,038 sqm) in Tuguegarao, Cagayan, under OCT No. P-8698.
- The lot was subdivided into 3653-A, 3653-B, 3653-C, and 3653-D.
- Initial Sales and Transactions
- Between 1973 and 1974, IFI sold Lot 3653-D (15,000 sqm) to Bienvenido de Guzman.
- On February 5, 1976, Rev. Macario Ga, as Supreme Bishop of IFI, sold Lots 3653-A and 3653-B (10,000 sqm) to Bernardino Taeza for ₱100,000, payable in installments, secured by a mortgage; payments were allegedly completed.
- Early Challenges and Leadership Dispute
- In 1977, the Parish Council (Laymen’s Committee) filed for annulment of the 1976 Deed of Sale; the suit was dismissed for lack of personality to sue.
- After Rev. Ga’s term ended in 1981, a leadership dispute arose; Rev. Ga filed with the SEC, which in 1988 recognized Bishop Abdias dela Cruz as Supreme Bishop.
- Registration and Further Litigation
- Taeza registered the parcels, obtaining TCT Nos. T-77994 and T-77995, and occupied the land. IFI demanded vacation but to no avail.
- In January 1990, IFI under Bishop Tito Pasco filed Civil Case No. 3747 in the RTC for annulment of sale; on November 6, 2001, the RTC declared the 1976 Deed null and void, TCTs void ab initio, ordered reconveyance, and awarded damages and attorneys’ fees.
- Court of Appeals Decision and SC Review
- The CA, on June 30, 2006, reversed the RTC, holding that the Supreme Bishop validly represented IFI and that no canon provision vested authority elsewhere.
- IFI filed a Rule 45 petition in the Supreme Court, raising three issues on nullity, enforceability, and bad faith.
Issues:
- Nullity and Enforceability of the 1976 Deed
- Whether the February 5, 1976 Deed of Sale with Mortgage is null and void for lack of required corporate consent under IFI Canons.
- If not void, whether the deed is nonetheless unenforceable for the same reason.
- Buyer’s Good Faith
- Whether Bernardino Taeza purchased in bad faith, knowing of the internal opposition to the sale.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)