La Filipina Evangelical Church, Inc. v. United Church of Christ in the Philippines

 

La Filipina Evangelical Church, Inc. v. United Church of Christ in the Philippines

G.R. No. 209668

March 22, 2023

 

FACTS:

                United Church filed a Complaint against Evangelical Church for recovery of possession over four contiguous parcels of land situated in Tagum City. United Church claimed that its members have been in possession of the subject properties since 1957. Its members constructed thereon a church building where they could use as a place of worship and in furtherance of related activities. United Church declared the subject properties for taxation purposes and was issued tax declarations with a total market value exceeding PHP300,000.00. Sometime in 2000, a conflict arose among the members of United Church. As the members failed to settle their differences and resolve their dispute, around 30 families formed Evangelical Church, a religious corporation duly registered with the Securities and Exchange Commission.

Sometime in August 2000, members of Evangelical Church removed the United Church signboard and replaced the same with La Filipina Evangelical Church, Inc. Since the members of United Church were outnumbered by the members of Evangelical Church, United Church was ousted of its possession of the subject properties. Members of the United Church had to temporarily hold worship services at the residence of one of its members. United Church sent a final written demand to Evangelical Church. As the demand was left unheeded, United Church filed the instant complaint before the RTC.

Evangelical Church contended that United Church was never in possession of the subject properties, and that it was Evangelical Church, albeit under the name of United Church, which declared the said lots for taxation purposes prior to its separation, cessation, and withdrawal from the mainstream of United Church. Moreover, it was their members, through their collective efforts, who caused the construction of the church building on the subject properties. Meanwhile, due to internal conflicts in United Church, several of its members withdrew their affiliation from the mainstream of United Church and formed an independent congregation in the name of Evangelical Church. In this regard, Evangelical Church insisted that its members are the very same original members of United Church

 

ISSUE:

                Whether or not the courts may resolve questions relating to possession of public lands.

 

HELD:

                No. The instant complaint filed by United Church is one for accion publiciana or recovery of possession of the subject properties. United Church never asked that it be declared the owner of the lots in question, but only prayed that it be allowed to recover possession thereof from Evangelical Church. Notably, while regular courts would have no power to conclusively resolve the issue of ownership given the supposed public character of the lands in dispute, as the same falls within the exclusive jurisdiction of the DENR, it is equally settled that this does not divest regular courts of jurisdiction over possessory actions instituted by occupants or applicants to protect their respective possessions and occupations, such as in this case. Moreover, in Gabriel, Jr. v. Crisologo, We held that: The objective of the plaintiffs in accion publiciana is to recover possession only, not ownership. When parties, however, raise the issue of ownership, the court may pass upon the issue to determine who between the parties has the right to possess the property. This adjudication, nonetheless, is not a final and binding determination of the issue of ownership; it is only for the purpose of resolving the issue of possession, where the issue of ownership is inseparably linked to the issue of possession. The adjudication of the issue of ownership, being provisional, is not a bar to an action between the same parties involving title to the property. The adjudication, in short, is not conclusive on the issue of ownership. Notwithstanding the foregoing discussions, this Court is not inclined to make a definitive ruling on the classification of the properties in question, that is, whether the same are public or alienable or disposable lands.