47

IGLESIA FILIPINA INDEPENDIENTE vs HEIRS of

BERNARDINO TAEZAFACTS:
Iglesia Filipina Independiente (IFI) was the owner of a parcel of
land (Lot 3653)subdivided into four. From
1 !3"1 !6# $uprme %ishop &ev. 'acario a#
sold one lot to%ienvenido de u man and two lots to %ernardino
*ae a. *ae a registered the sub+ect parcels of land and transfer
certi,cates were issued in hisname. -e then occupied a portion of
the land.In anuar/ 1 0# IFI ,led for annulment of sale
annulment of the sub+ect parcels of landagainst &ev. a and
the defendant %ernardino *ae a on the ground that &ev. a was
notauthori ed to sell. *he &* rendered +udgment in favor of IFI. *he 2
reversed such decision.It ruled that IFI being a corporation
sole# validl/ transferred ownership over the land in uestion
through its $upreme %ishop# who was at the time the
administrator of all propertiesand the o4cial representative of the
church. It further held that t he authorit/ of the then$upreme
%ishop &ev. a to enter into a contract and represent the
plainti7"appellee
cannotbe ass ail ed# as there are no provisions i n its c o
nstituti on and c anons giv ing the s ai dauthorit/ to an/ other
person or entit/.
ISSUE:
89: the deed of sale with mortgage is null and void or
unenforceable;
HELD:
*he issue boils down to the uestion of whether then $upreme %i
shop &ev. a isauthori ed to enter into a contract of sale in behalf of
petitioner.<etitioner maintains that there was no consent to the
contract of sale as $upreme %ishop&ev. a had no authorit/ to
give such consent. It emphasi ed that 2rticle I= (a) of
their anons provides that >2ll real properties of the hurch
located or situated in such parish canbe disposed of onl/ with the
approval and conformit/ of the la/men?s committee# the
parishpriest# the @iocesan %ishop# with sanction of the
$upreme ouncil# and ,nall/ with theapproval of the $upreme
%ishop# as administrator of all the temporalities of the hurch.> It
isalleged that the sale was done without the re uired approval
mentioned in the anonsA *he *rial court also found that the
la/men?s committee indeed made its ob+ection to the saleBnown
to the $upreme %ishop but the latter still eCecuted the contract of
sale despite suchopposition. -e clearl/ acted be/ond his powersD
*his case clearl/ falls under the categor/ of unenforceable
contracts mentioned in 2rticle 1E03# paragraph (1) of the ivil
ode# whichprovides# thusD2rt. 1E03. *he following contracts are
unenforceable# unless the/ are rati,edD(1)*hose entered into in the
name of another person b/ one who has been given
noauthorit/ or legal representation# or who has acted be/ond his
powersA<etition ranted. IFI is the rightful owner of sub+ect lots.