G.R. No. 3490 - Roman Catholic Apostolic Church vs. Municipality of Placer

In December 1903, the Roman Catholic curate of Placer and Taganaan initiated an action in his own name before a justice of the peace in Surigao to recover possession of the church, the convent, and the cemetery.
The original proceeding was subsequently reversed in a Court of First Instance because an amendment to the complaint expanded the cause of action beyond the jurisdiction of the justice of the peace, as established in Alonso vs. Municipality of Placer.

The action in the present case was brought originally in this court under Act No. 1376.
Evidence from the prior litigation was stipulated and submitted as proof, showing that the facts of this case are analogous to other church controversies previously settled by the court.
The earlier principles set forth in Barlin vs. Ramirez support the defendant’s entitlement to judgment for possession.

The complaint not only seeks possession of the church property but also a declaration of ownership over the said property.
Although previous opinions had indirectly inferred the ownership of the property by the Roman Catholic Church, there had been no prior definitive pronouncement on the ownership issue.

The plaintiff’s argument is anchored on the authority of the recent Supreme Court of the United States decision in The Municipality of Ponce vs. The Roman Catholic Apostolic Church in Porto Rico, which is binding as precedent.
The defendant contended that the Roman Catholic Church is not a juridical person, arguing that it lacks legal incorporation and that the property was constructed using funds contributed by the municipality.
Extensive judicial discussion was made referencing:

The organic act which granted the legislative assembly authority over court jurisdiction and procedure.
Legal principles stemming from Spanish law, Roman law, and international treaties, including the treaty of Paris and concordats between Spain and the Holy See.
The longstanding recognition of the church’s legal personality from the era of Emperor Constantine to the present, as reinforced by codifications such as the Civil Code provisions in force in Cuba, Porto Rico, and the Philippines.

The court noted that public funds appropriated for the building or repair of churches, when approved by the proper authorities, constituted irrevocable gifts, thereby solidifying the church’s title to the property.
It was emphasized that the inherent legal personality of the church and its property rights are not affected by the origin of the funds, whether from the crown or municipal contributions.
The judicial notice was taken of Spanish law as applicable to insular possessions, ensuring that the church’s property rights were protected against any claim of interference or expropriation by the municipality.

Whether the amended complaint sufficiently stated a cause of action entitling the Roman Catholic Church both to possess and to receive a declaration of ownership over the church property (church, convent, and cemetery).
Whether the Roman Catholic Church qualifies as a juridical person or legal entity capable of maintaining its property rights in the courts.
Whether the payment or contribution of funds by the municipality for the construction or repair of the church affects the irrevocable donation to the church and its title therein.
Whether the legislative assembly of Porto Rico had the constitutional and legal authority to confer jurisdiction over special controversies involving ecclesiastical properties.
Whether the established legal norms, including international treaties (such as the treaty of Paris), Spanish and Roman law, and the principles enshrined in concordats, provide a definitive safeguard for the church’s property rights.