- Petitioner
- Seventh Day Adventist Conference Church of Southern Philippines
- Respondent
- Northeastern Mindanao Mission of Seventh Day Adventist
- Citation
- G.R. No. 150416
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Corona, J.
- Decided
- July 21, 2006
Summary
This case involved a property dispute over a 1,069 sq. m. lot between two Seventh Day Adventist organizations. The spouses Cosio allegedly donated the property to SPUM-SDA Bayugan in 1959, then sold the same property to SDA-NEMM in 1980. Petitioners, claiming to be successors of the 1959 donee, challenged SDA-NEMM's ownership. The Supreme Court held that the 1959 donation was void because SPUM-SDA Bayugan, being unincorporated, lacked juridical personality to receive donations. The Court rejected petitioners' de facto corporation argument, emphasizing that corporate existence requires SEC registration and certificate of incorporation. The 1980 sale to SDA-NEMM was upheld as valid, with ownership properly transferred through constructive delivery via public instrument under Civil Code Article 1477. The decision reinforced principles of corporate juridical personality and property transfer requirements under Philippine law.