G.R. No. 141324 - Spouses Junson vs. Spouses Martinez

Special Services Corporation (petitioner) obtained a judgment on October 10, 1972, in a replevin with sum of money case against Alejandro Estudillo for approximately P94,727.52.
A writ of execution was issued but remained unsatisfied, leading to an alias writ executed on December 15, 1972, whereby a notice of levy was annotated on Transfer Certificate of Title (TCT) No. 51837.
The title covered two parcels of land in Sampaloc, Manila, registered in the names of several individuals including Alejandro Estudillo, his wife, and other co-registered Chapter members.

On June 27, 1973, Alejandro Estudillo filed a Motion to Dissolve and/or Cancel the Notice of Levy claiming that he and the other registered owners held the interests merely in trust for Centro La Paz (a chapter of Union Espiritista Cristiana de Filipinas, Inc.).
The alleged trust was supported by earlier "Acknowledgments" executed on October 20, 1961, and October 2, 1971, and by letters to the City Assessor dated February 15, 1963, November 29, 1963, and August 8, 1966.
Centro La Paz solidified its claim by submitting a third party claim on July 21, 1973, asserting exclusive ownership of the contested properties.

On July 23, 1973, Centro La Paz instituted Civil Case No. 91412 for Damages and Preliminary Injunction against both petitioner Special Services Corporation and the Sheriff of Manila.
In their pleadings, Centro La Paz reiterated that the registered owners were acting as trustees holding the property in trust for the organization.

In response to the suit, petitioner contended that the Torrens Title was conclusive, arguing that the absence of annotations of the Acknowledgments on TCT No. 51837 could not affect title.
On August 27, 1973, the lower court issued a writ of preliminary injunction enjoining the intended public auction sale of Estudillo’s interest, conditioned on Centro La Paz posting a bond of P30,000.00.
Later on August 30, 1974, the trial court rendered a judgment permanently enjoining petitioner from proceeding with the public auction sale, dismissing petitioner’s counterclaim for lack of merit.
The court’s findings emphasized that a preponderance of evidence established that the registered owners held the property as trustees for Centro La Paz, drawing on documentary evidence including deeds, acknowledgments, petitions for tax exemption, and correspondences with the City Assessor.

Dissatisfied with the trial court’s ruling, petitioner appealed to the Court of Appeals.
The appellate court affirmed the trial court’s decision, thereby upholding the permanent injunction and concluding that the property in dispute was held in trust for Centro La Paz.
Petitioner then elevated the issue through a Petition for Review on Certiorari questioning specific issues related to the juridical personality of Centro La Paz and the validity of its ownership claim based on the executed documents.

Centro La Paz asserted that, as a chapter of the Union Espiritista Cristiana de Filipinas, Inc. (a duly registered semi-religious and charitable organization), it possessed a distinct juridical personality and the right to sue and be sued.
Evidence presented included a Deed of Donation dated March 13, 1957, several Acknowledgments, deeds of sale, and petitions related to tax exemptions—all aimed at establishing that the registered owners were acting as trustees.
Petitioner argued that the registered title, in principle, was conclusive and thus the absence of annotated trust documents on TCT No. 51837 should not prejudice its claim.

Whether Centro La Paz, being only a chapter of the Union Espiritista Cristiana de Filipinas, Inc., possesses an independent juridical personality under Philippine law.

The issue centers on the capacity of a chapter to sue and be sued independently and whether it can truly represent the interests of the mother organization.

Whether the alleged executed documents, evidencing a trust relationship and conferred ownership, validly transfer and confirm ownership of Transfer Certificate of Title No. 51837 in favor of Centro La Paz.

This involves assessing the evidentiary value of the Acknowledgments, deeds, petitions for revocation of tax assessments, and other supporting documents to support the claim of trust ownership over the property.