In a dispute over property rights, the Supreme Court affirmed the Court of Appeals’ decision favoring Loida Dela Cruz, representing the Church of Jesus Christ, “New Jerusalem.” The Court found that Dela Cruz’s representation of the religious organization with the name “Bagong Jerusalem” was valid and that the disputed property rightfully belonged to them, despite claims by Iglesia De Jesucristo Jerusalem Nueva of Manila, Philippines, Inc. This decision underscores the importance of establishing clear authorization and consistent evidence in property disputes involving religious organizations, impacting how such entities can assert their rights over claimed properties.

Whose Land Is It? Unraveling a Church Property Dispute in Malabon

The case of Iglesia de Jesucristo Jerusalem Nueva of Manila, Philippines, Inc. v. Loida Dela Cruz centered on a heated dispute over a parcel of land in Malabon City. The Iglesia de Jesucristo Jerusalem Nueva of Manila, Philippines, Inc., represented by its president Francisco Galvez, filed a complaint for unlawful detainer against Loida Dela Cruz, who used the name Church of Jesus Christ, “New Jerusalem.” Petitioner claimed ownership of the land based on Original Certificate of Title (OCT) No. 35266, asserting that Dela Cruz’s occupation was merely tolerated. Dela Cruz countered that she represented the true owner, Obispo Representante at Pastor General ng Iglesia ni Jesu Kristo “Bagong Jerusalem” Inc., arguing that Galvez had irregularly acquired his title.

At the heart of the legal battle was the question of which party had the rightful authority to represent the true owner of the disputed property. The Metropolitan Trial Court (MeTC) initially dismissed the petitioner’s complaint, a decision upheld by both the Regional Trial Court (RTC) and the Court of Appeals (CA). These courts found that Dela Cruz had presented more convincing evidence of her authority to represent the actual owner, leading to the dismissal of Iglesia de Jesucristo’s claim. The Supreme Court was then tasked with determining whether the CA erred in affirming the lower courts’ decisions, particularly concerning the evidence presented by both parties and the application of property law principles.

The Supreme Court approached the case by first establishing the essential elements of an unlawful detainer action. The Court reiterated the provisions of Section 1, Rule 70 of the 1997 Rules of Civil Procedure. This rule dictates that a complaint for unlawful detainer must demonstrate that the initial possession was lawful, that the possession became unlawful after notice of termination, that the defendant remained in possession, and that the complaint was filed within one year from the last demand to vacate.

SECTION 1. Who may institute proceedings, and when. — Subject to the provisions of the next succeeding section, a person deprived of the possession of any land or building by force, intimidation, threat, strategy, or stealth, or a lessor, vendor, vendee, or other person against whom the possession of any land or building is unlawfully withheld after the expiration or termination of the right to hold possession, by virtue of any contract, express or implied, or the legal representatives or assigns of any such lessor, vendor, vendee, or other person, may, at any time within one (1) year after such unlawful deprivation or withholding of possession, bring an action in the proper Municipal Trial Court against the person or persons unlawfully withholding or depriving of possession, or any person or persons claiming under them, for the restitution of such possession, together with damages and costs.

Building on this legal framework, the Court examined whether the petitioner had sufficiently proven that the respondents’ possession was initially based on tolerance. This is a critical element in unlawful detainer cases, as it establishes the legal basis for the plaintiff’s claim that the defendant’s continued possession is unlawful. The Court emphasized that the burden of proof lies with the plaintiff to demonstrate that the defendant’s entry and subsequent possession were indeed permitted by tolerance.

A pivotal aspect of the Supreme Court’s analysis was the determination of which party had the authority to represent the registered owner of the disputed property. Both parties presented conflicting claims and evidence, leading the lower courts to examine the credibility and consistency of their submissions. The RTC, as quoted by the CA, noted significant inconsistencies in the petitioner’s claims. The court highlighted the discrepancy between the petitioner’s claim that the religious organization was established in 1940 and the fact that it was only registered in 1999. This discrepancy cast doubt on the petitioner’s credibility and weakened its claim to rightful representation.

There is no question that the subject [lot] is registered in the name of ‘Iglesia cle Jesucristo, Jerusalem Nueva of Manila, Philippines’, ([‘]Nueva do Manila’ for brevity) in 1940, [Galvez] argued that he is the president of ‘Nueva de Manila’ hence, authorized to represent the same; likewise, [Dela Cruz] as an officer of Church of Jesus Christ, ‘New Jerusalem’ (‘New Jerusalem’ for brevity) claims the same representation as ‘Nueva de Manila’ and ‘New Jerusalem’ are one and the same entity.

In contrast, Dela Cruz presented evidence that she was the authorized representative of Obispo Representante at Pastor General ng Iglesia ni Jesu Kristo “Bagong Jerusalem” Inc. This organization, which also bore the translated names “New Jerusalem” and “Jerusalem Nueva”, was registered in 1955, predating the petitioner’s registration. The RTC and CA found Dela Cruz’s evidence to be more consistent and credible, further supporting their decision in her favor.

Furthermore, the Supreme Court took note of Dela Cruz’s argument that Galvez had obtained a new title to the property based on a false claim that the original had been destroyed by a flood. Dela Cruz asserted that the original title was still in the possession of Obispo Representante at Pastor General ng Iglesia ni Jesu Kristo “Bagong Jerusalem” Inc., suggesting that the issuance of the reconstituted title was irregular and improper. This claim added weight to Dela Cruz’s challenge to the validity of the petitioner’s title.

The Court also addressed the issue of ownership, recognizing that while the primary issue in an ejectment case is possession de facto, ownership may be considered to determine which party has a better right to possess the property. The Court reiterated that an ejectment case is not necessarily decided in favor of the party presenting proof of ownership. The key is to establish the jurisdictional facts required for the particular type of ejectment case filed.

An additional layer of complexity arose from the petitioner’s failure to substantiate its claim that it merely tolerated the respondents’ possession of the disputed property. The Court emphasized that the acts of tolerance must be proven, and the petitioner failed to adduce sufficient evidence to support this claim. This failure further undermined the petitioner’s case and contributed to the Court’s decision to deny the petition.

This legal principle underscores the importance of not only possessing a title but also demonstrating the circumstances under which another party’s possession began. Without clear evidence of tolerance, a claim for unlawful detainer becomes significantly weaker. The Court’s decision highlights the necessity for religious organizations to maintain meticulous records and documentation to support their claims of property ownership and authorized representation.

In conclusion, the Supreme Court’s decision rested on a thorough analysis of the evidence presented by both parties, the legal requirements for an unlawful detainer action, and the principles of property law. The Court found that Dela Cruz had successfully demonstrated her authority to represent the rightful owner of the disputed property, while the petitioner had failed to substantiate its claims of tolerance and rightful possession. The decision serves as a reminder of the importance of clear documentation, consistent evidence, and adherence to legal procedures in property disputes involving religious organizations.

FAQs

What was the key issue in this case?	The central issue was determining who had the rightful authority to represent the true owner of the disputed property between Iglesia de Jesucristo Jerusalem Nueva and Loida Dela Cruz, representing Church of Jesus Christ, “New Jerusalem.”
What is an action for unlawful detainer?	Unlawful detainer is a legal action to recover possession of property from someone who initially had lawful possession but whose right to possess has expired or been terminated. The plaintiff must file the complaint within one year from the last demand to vacate.
What did the lower courts decide?	The Metropolitan Trial Court (MeTC), Regional Trial Court (RTC), and Court of Appeals (CA) all ruled in favor of Loida Dela Cruz, finding that she presented more convincing evidence of her authority to represent the actual owner of the disputed property.
What was the significance of the registration dates of the religious organizations?	The RTC noted that Iglesia de Jesucristo Jerusalem Nueva was registered in 1999, whereas Obispo Representante at Pastor General ng Iglesia ni Jesu Kristo “Bagong Jerusalem” Inc. was registered earlier in 1955. This discrepancy cast doubt on the petitioner’s claim of being the original organization.
What role did the concept of “tolerance” play in the decision?	The petitioner claimed that it merely tolerated the respondents’ possession of the property, but the Court found that the petitioner failed to provide sufficient evidence to prove this tolerance. Without proof of tolerance, the claim for unlawful detainer was weakened.
What is the effect of a Torrens title in an ejectment case?	While a Torrens title generally implies a right to possession, the Court emphasized that an ejectment case is not automatically decided in favor of the titleholder. The key jurisdictional facts required for the specific type of ejectment case must be established.
How did the Court address the issue of ownership in this case?	The Court acknowledged that while the primary issue in an ejectment case is possession, ownership may be considered to determine which party has a better right to possess the property. However, the determination of ownership is provisional and only for the purpose of resolving the issue of possession.
What evidence did Loida Dela Cruz present to support her claim?	Dela Cruz presented a Secretary’s Certificate proving her authority to represent Obispo Representante at Pastor General ng Iglesia ni Jesu Kristo “Bagong Jerusalem” Inc., the organization she claimed was the true owner. She also challenged the validity of the petitioner’s reconstituted title.

This case provides a valuable lesson for religious organizations and property owners alike. It underscores the importance of maintaining clear and consistent records, properly documenting claims of ownership and authorized representation, and adhering to legal procedures in property disputes. The need to substantiate claims and the careful examination of evidence are crucial aspects of such cases.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: THE IGLESIA DE JESUCRISTO JERUSALEM NUEVA, G.R. No. 208284, April 23, 2018