- Petitioner
- Iglesia Filipina Independiente
- Respondent
- Heirs of Bernardino Taeza
- Citation
- G.R. No. 179597
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Peralta, J.
- Decided
- February 3, 2014
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.
Intellegal Wiki · Key Holding
Granted the petition and reversed the CA, holding that a corporation sole's Supreme Bishop who sold church property without the approval of all the entities required by the church canons and the Corporation Code acted beyond his authority, rendering the sale unenforceable under Article 1403(1); a constructive trust arose under Article 1456 and, the suit being within the ten-year period under Article 1144, reconveyance was ordered.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.