Case Digest (G.R. No. L-8451) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On October 4, 1954, Mateo L. Rodis, a Filipino citizen and resident of Davao City, executed a deed of sale of a parcel covered by Transfer Certificate of Title No. 2263 in favor of the Roman Catholic Apostolic Administrator of Davao, Inc., a Philippine-incorporated corporation sole whose actual incumbent was Msgr. Clovis Thibault, a Canadian citizen. When presented for registration to the Register of Deeds of Davao City, the deed was referred to the Land Registration Commissioner “en consulta” under Section 4 of Republic Act No. 1151 because the Register doubted whether a corporation headed by an alien could hold private land without proof that at least 60% of its capital or assets were owned by Filipino citizens. After hearing, the Commissioner, applying Sections 1 and 5 of Article XIII of the 1935 Philippine Constitution, held on September 21, 1954 that the petitioner was disqualified from acquiring the land without such proof and ordered denial of registration. A motion for r Case Digest (G.R. No. L-8451) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Sale and Registration Attempt
- On October 4, 1954, Mateo L. Rodis, a Filipino citizen, executed a deed of sale over a parcel covered by Transfer Certificate of Title No. 2263 in Davao City in favor of the Roman Catholic Apostolic Administrator of Davao, Inc., a corporation sole whose incumbent (Msgr. Clovis Thibault) was a Canadian citizen.
- The Register of Deeds of Davao, invoking a prior Carmelite Nuns precedent, required the petitioner to submit an affidavit that at least 60% of its capital, property, or assets were owned by Filipino citizens before registering the deed.
- Referral and Administrative Resolution
- Petitioner objected that its case differed from the Carmelite Nuns (it had only one incorporator and held property in trust for all local Catholics), and declined to submit the demanded affidavit in the same form.
- The Register of Deeds referred the issue to the Land Registration Commissioner en consulta under Section 4 of Republic Act No. 1151.
- After hearing, on September 21, 1954, the Commissioner ruled that under Articles XIII, Sections 1 and 5 of the 1935 Constitution the petitioner was not qualified to acquire private lands absent proof of 60% Filipino ownership or control, and ordered registration denied.
Issues:
- Constitutional Qualification
- Whether a religious corporation sole, whose sole member (the incumbent Ordinary) is an alien, qualifies to acquire and register private agricultural lands under Article XIII, Sections 1 and 5 of the 1935 Constitution.
- Effect of Nationality Requirement
- Whether the constitutional requirement that 60% of a corporation’s capital be Filipino-owned applies to a corporation sole administering church temporalities rather than owning them beneficially.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)