Case Digest (G.R. No. 7999)
Facts:
Roman Catholic Bishop of Nueva Segovia v. Government of the Philippine Islands et al., G.R. No. 7999, December 19, 1913, the Supreme Court En Banc, Moreland, J., writing for the Court.
The petitioner, the Roman Catholic Bishop of Nueva Segovia, sought registration of title to fifty-one parcels of land located in various municipalities of Ilocos Norte before the Court of Land Registration. The Government of the Philippine Islands and several private respondents (collectively, the appellees) opposed registration in respect of certain parcels; the Court of Land Registration denied registration as to those contested parcels, and the petitioner appealed to the Supreme Court.
Neither side produced paper titles; both the petitioner and the respondents relied on possession and oral testimony to establish their rights. The petitioner introduced a certificate executed by the Archbishop, registered in the registry of property, asserting that the Church owned large portions of the lands. The lower court treated this certificate as insufficient to establish a legal title against persons then in possession and resolved factual disputes in favor of the respondents on a parcel-by-parcel basis; the petitioner excepted to those findings and also objected to the form of the decrees that the court entered in the parcels it did award to the petitioner.
On appeal, the Supreme Court reviewed the evidence and plans for each contested parcel. The Court accepted the trial court's credibility findings and concluded that those findings were not against the fair preponderance of the evidence. A separate issue concerned the form of the registration decrees: the Court of Land Registration had decreed registration in the name of the Bishop "in trust for the use, purpose, behoof, and sole benefit of the Roman Catholic Apostolic Church in these Islands" pursuant to its reading of section 157 of the Corporation Law (Act No. 1459); the petitioner contested that wording as improper and sought registration simply in the name of the Bishop....(Subscriber-Only)
Issues:
- Did the Court of Land Registration err in denying registration of title to the contested parcels where the parties relied on possession and oral testimony rather than paper title?
- Does a certificate executed by the Archbishop and registered in the registry of property constitute a title equivalent to a Spanish-law title such as a composicion con el estado or an informacion posesoria, effective against persons in possession at the time of its registration?
- Was the Court of Land Registration's decree registering title "in trust for the use, purpose, behoof, and sole benefit of the Roman Catholic Apostolic Church in these Islands" a proper form of registration, or sh...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)