G.R. No. L-3212 - Roman Catholic Apostolic Church vs. Municipalities of Tarlac and Victoria

The case is an original action brought under Act No. 1376, which provided for the resolution of controversies involving church property in the Philippine Islands.
The action involves the Roman Catholic Apostolic Church as plaintiff and certain municipalities and individuals (including the municipalities of Tarlac and Victoria, and Gregorio Aglipay as representative of the Independent Filipino Church) as defendants.
It is a follow-up to previous decisions on the construction of parts of Act No. 1376, as seen in The Roman Catholic Church vs. The Municipality of Badoc cases.

The open square known as the plaza of the church of Tarlac (formerly part of the pueblo of Tarlac).
In the former pueblo of La Paz (now a barrio in Tarlac):

These properties were claimed to be in the possession and under the administration of the defendants, namely Gregorio Aglipay and the municipality of Tarlac.

The grounds of the church of Victoria–bounded by streets known as procesionales and recognized as the plaza of the church.
The chapels and associated grounds located in the barrios of Calibungan, San Andres, Balbaloto, and Bantog.
These properties were in the possession and under the administration of several defendants including Gregorio Aglipay, Antonio Mariano, Canuto Aglipay, Geronimo Velasco, and the municipality of Victoria.

The Roman Catholic Church claimed ownership and possession of the aforementioned properties, emphasizing that these lands had been in its possession for more than twenty-five years until recently taken by the defendants.
The complaint further prayed that the defendants be declared to have no right or interest in the properties, that a receiver be appointed, and that a preliminary injunction be issued to stop the Independent Filipino Church from using the property during the pendency of the action.

The complaint, as amended, was duly served on all defendants except one (Antonio Mariano), and an answer was filed which ambiguously appeared to represent all defendants or only Gregorio Aglipay.
The issue of default for non-response by other defendants was raised, potentially allowing judgment by the terms of section 4 of Act No. 1376.
Evidence was taken by a commissioner after appointment, demonstrating the long possession of the property by the plaintiff church, particularly in the barrio of La Paz, where the church had been administered and physically occupied for over twenty-five years.
The defendant’s answer alleged that the property was public property of the Government of the Philippine Islands, maintained only for administrative purposes up until the cessation of Spanish sovereignty.
An interim agreement reached between the plaintiffs and the Attorney-General (on behalf of the municipalities) dismissed the claims regarding public highways and plazas, narrowing the dispute solely to the lands in the barrio of La Paz.

The answer and briefs largely relied on previous decisions where it was held that such properties were not automatically transferred to the United States government by the treaty of Paris, and that the municipalities themselves lacked ownership of church property.
The case referenced decisions in Barlin vs. Ramirez, Roman Catholic Church vs. Santos, and the City of Manila vs. The Roman Catholic Church, all of which rejected the claim of public ownership over these church properties.
The doctrine from the Bishop of Cebu vs. Mangaron was also cited, supporting the recovery of possession based on long and peaceful possession even if an action was not brought within one year of dispossession.

A motion by the defendant, Gregorio Aglipay, sought dismissal on the ground that Act No. 1376 was inconsistent with the earlier act of Congress (July 1, 1902) concerning the Philippine Islands.
The defendants also argued a violation of the equal protection clause of the law, asserting that the statute was discriminatory by not allowing municipalities to initiate actions without the Attorney-General’s consent.
The court considered analogous reasoning from United States case law, notably United States vs. The Union Pacific Railroad Company, regarding legislative provisions that may favor one party procedural rights over others.

Whether the property in the barrio of La Paz is public property belonging to the Government of the Philippine Islands or whether it is rightly and historically owned by the Roman Catholic Church.
Whether the treaty of Paris and the cessation of Spanish sovereignty affected the ownership and title to these church properties.

Whether the Roman Catholic Church, having been in continuous possession of the disputed property for more than twenty-five years, is entitled to recover possession despite the potential lapse of the one-year period typically required for such actions.
Whether the defendant’s assertion of having taken possession after 1898, without any valid title, deprives the church of its right to immediate possession.

Whether Act No. 1376, by prescribing different methods and conditions for initiating actions for the municipalities versus the Roman Catholic Church, violates the equal protection clause as protected by the act of Congress of July 1, 1902.
Whether the motion to dismiss on these constitutional grounds can be considered during the merits of the case.

Whether the failure of certain defendants to file an answer should result in their default, and if such default justifies the entry of judgment against them without further evidence for some of the claims alleged by the complaint.