Iglesia Filipina Independiente v. Heirs of Bernardino Taeza

Summary

The Supreme Court ruled in favor of Iglesia Filipina Independiente in this property reconveyance case involving church land sold without proper authorization. Supreme Bishop Rev. Macario Ga sold church property to Bernardino Taeza in 1976 despite opposition from the laymen's committee, violating church canons requiring approval from all specified entities. The Court found the sale unenforceable under Civil Code Article 1403(1) as the Bishop exceeded his authority. Applying constructive trust principles under Article 1456, the Court ordered reconveyance since the action was filed within the 10-year prescriptive period. The decision emphasized that corporation sole property transactions must comply with internal governance rules, and all required approvals must be obtained for valid property disposal. This case demonstrates the interplay between corporate law, property rights, and religious institutional governance in Philippine jurisprudence.