G.R. No. L-13816 - Romero vs. De los Reyes, Jr.

The case involves an appeal by Severo Romero and 44 others (plaintiffs-appellants) against a decision of the Court of First Instance (CFI) of Ilocos Norte which dismissed their complaint.
The dispute centers on the control and administration of the properties of the Iglesia Filipina Independiente (IFI), a religious body founded in 1902 by the late Gregorio Aglipay.
The IFI, also known as the Aglipayan Church, developed its own doctrines, faith, rituals, and discipline, as embodied in its two authoritative books: the Oficio Divino (published in 1907) and the Doctrina y Reglas Constitucionales (promulgated in 1903).

In January 1946, the IFI split into two factions: one led by Bishop Santiago A. Fonacier and the other by Bishop Isabelo de los Reyes, Jr.
The division stemmed from a contest for the position of Obispo Maximo (Supreme Bishop), which had been held by Gregorio Aglipay until his death in 1940.
Subsequent to the split, Fonacier and de los Reyes engaged in legal and ecclesiastical battles over the legitimacy of their claims to be the true head of the IFI.

In the accounting case No. 72183 initiated on February 9, 1946 before the CFI of Manila, Fonacier alleged that in August 1947, Isabelo de los Reyes, Jr. committed abjuration or apostasy by abandoning the fundamental doctrines and practices of the IFI.
Both the Court of Appeals (in CA-G.R. No. 6371-R) and the Supreme Court (in G.R. No. L-5917, decided January 28, 1955) had dealt with the issues regarding the legitimacy of leadership and the alleged abjuration, ultimately ruling that de los Reyes was the legitimate Obispo Maximo of the IFI.
The alleged doctrinal changes were ruled by the courts as irrelevant to the division of the Church, as they occurred after internal conflicts had already materialized.

Recovery of the possession of IFI properties, which were held in trust under Commonwealth Act No. 434.
A preliminary injunction restraining defendant Isabelo de los Reyes, Jr. from using the name and properties of the IFI.

The complaint detailed that on or about August 5, 1947, de los Reyes, together with a supposedly constituted Supreme Council of Bishops and a General Assembly, adopted a “Declaration of Faith” and Articles of Religion that were radically different from the original doctrinal bases of the IFI.
The allegation was that by altering the doctrines and abandoning the original faith and practices (as set forth in the Doctrina y Reglas Constitucionales and Oficio Divino), de los Reyes forfeit his authority over and interest in the IFI.

Defendant de los Reyes opposed the issuance of the writ of preliminary injunction claiming lack of representative capacity of the plaintiffs and asserting that the matter was already settled by the previous case (G.R. No. L-5917).
A motion to declare defendant in default was filed by the plaintiffs-appellants when de los Reyes failed to timely file an answer, though he later argued that the extended period had not expired.
The trial court eventually declared de los Reyes in default and proceeded to collect evidence solely from the plaintiffs, despite his earlier participation by testifying in his own behalf during the preliminary injunction hearing.

The trial court found that the issues concerning the faithful adherence to the IFI’s original doctrines and the rightful head of the Church had already been determined in the prior accounting case (G.R. No. L-5917).
The case brought by the plaintiffs-appellants was effectively a continuation of the longstanding rivalry between the two factions within the IFI, with the underlying disputes already settled by judicial decision.
As a result, the trial court, on January 17, 1958, dismissed the complaint without pronouncing costs.

Appellants contended that the trial court improperly took judicial notice of the doctrine of res judicata even though the defense was not pleaded in a Motion to Dismiss or Answer.
They also argued that the issues relating to de los Reyes’ alleged abjuration and the subsequent departure from the IFI's fundamental doctrines were not identical to those resolved in the earlier case.
Appellants maintained that the property and name of the IFI were at stake and that the rights of the faithful members were being improperly compromised.

Whether the trial court erred in taking judicial notice of the prior judgment (res judicata doctrine) even though the defense was not expressly pleaded by the defendant in his responsive pleadings.
Whether the alleged abjuration and doctrinal changes purportedly enacted by Bishop de los Reyes, Jr. invalidated his authority to administer the IFI and its properties.
Whether the dispute over the IFI’s properties and the authority to use its name should be considered separate from internal ecclesiastical matters, and thus within the competence of the civil courts.
Whether there is an identity of subject matter and cause of action between the present case and the previous case (G.R. No. L-5917), thereby justifying the application of the doctrine of res judicata.
Whether the plaintiffs-appellants had sufficient standing as representatives of the faithful members of the IFI to seek the reliefs pleaded in their class suit.