G.R. No. L-45330 - Canete vs. Court of Appeals

The Supreme Court's review of decisions from the Court of Appeals is limited to questions of law.
The Court does not re-evaluate factual findings unless they are unsupported by the record or constitute a serious abuse of discretion.
The findings of the Court of Appeals in this case were based on substantial evidence, warranting no disturbance by the Supreme Court.

The case involves the ownership and control of properties belonging to a religious congregation amidst a schism.
Citing the precedent set in Watson v. Jones, the Supreme Court ruled that the control of properties in a religious congregation during a schism is determined by the numerical majority of the members.
Members who separate themselves from the congregation cannot claim rights to the properties based solely on their previous membership.

The Cofradia de Nuestra Seora de Belen was founded in the early 1900s by Inocenta de Veyra as a voluntary religious group.
Inocenta donated significant religious images to the Cofradia in 1919 and 1930, which were to be cared for by the group.
The governance of the Cofradia has historically relied on customs and traditions, with no formal by-laws established.

A division arose within the Cofradia due to a conflict involving the parish priest, leading to two factions: one loyal to the ex-parish priest and the other to the newly appointed priest.
Respondents, claiming to be members of the Cofradia, initiated legal action for the recovery of personal properties, including religious images and funds.
Petitioners contended that the images were ecclesiastical properties and that the respondents lacked legal standing to sue as members of an unregistered organization.

The trial court ruled in favor of the respondents, declaring them the true owners of the disputed properties and ordering the petitioners to pay damages and attorney's fees.
The court allowed immediate execution of the judgment despite objections from the petitioners, leading to an appeal to the Court of Appeals.

Petitioners raised multiple errors regarding the legal personality of the Cofradia, the jurisdiction of the civil courts over ecclesiastical matters, and the validity of the trial court's decisions.
They argued that the trial court exceeded its jurisdiction by addressing issues related to the suspension of Fr. Manuel Gomez and the rightful parish priest.
The petitioners also contested the trial court's rejection of their counterbond and the award of damages to the respondents.

The Court of Appeals upheld the trial court's findings, stating that the plaintiffs were co-owners of the images and that the images were not church properties.
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