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Iglesia Filipina Independiente v.


Categories
Heirs of Taeza
G.R. No. 179597, 3 February 2014
 Articles

FACTS:
 Case Digests

Iglesia Filipina Independiente was the owner of a parcel of land


 Chapter News
described as Lot 3653, containing an area of 31,038 square meters,

 Uncategorized situated at Ruyu (now Leonarda), Tuguegarao, Cagayan, and covered


by Original Certificate of Title No. P-8698. The said lot is subdivided
as follows: Lot Nos. 3653-A, 3653-B, 3653-C, and 3653-D. It then sold
Recent Posts Lot 3653-D, with an area of 15,000 square meters, to one Bienvenido

de Guzman.
 CMS Logging
Inc. v. Court of Rev. Macario Ga, in his capacity as the Supreme Bishop of the

Appeals plaintiff-appellee, to the defendant Bernardino Taeza, for the amount


of ₱100,000.00, through installment, with mortgage to secure the
 Lim v. Saban payment of the balance. Subsequently, the defendant allegedly

completed the payments. In 1977, a complaint for the annulment of


 Eurotech
the February 5, 1976 Deed of Sale with Mortgage was filed by the
Industrial
Parish Council of Tuguegarao, Cagayan, represented by Froilan
Technologies,
Calagui and Dante Santos.
Inc. v. Cuizon

ISSUE:
Whether then Supreme Bishop Rev. Ga is authorized to enter into a
 Manila Remnant
contract of sale in behalf of petitioner.
Co., Inc. v. Court

of Appeals
RULING:

 Bedia v. White
No. The sale is invalid for not being in conformity with the Canons of

the church.

Recent Comments
Section 113 of the Corporation Code of the Philippines provides that:

 Marjorie Sec. 113. Acquisition and alienation of property. – Any corporation


Mejorada- sole may purchase and hold real estate and personal property for its
Cuenco on 13 church, charitable, benevolent or educational purposes, and may
ZN law grad receive bequests or gifts for such purposes. Such corporation may
pass 2017 Bar mortgage or sell real property held by it upon obtaining an order for
Exam that purpose from the Court of First Instance of the province where
the property is situated; x x x Provided, That in cases where the rules,
 Prescription on
regulations and discipline of the religious denomination, sect or
IBP-ZN joins
church, religious society or order concerned represented by such
community
corporation sole regulate the method of acquiring, holding, selling
outreach in Jose
and mortgaging real estate and personal property, such rules,
Dalman
regulations and discipline shall control, and the intervention of the
courts shall not be necessary.
 Ronald on
Salient features
The Court finds it erroneous for the CA to ignore the fact that the
of the Revised
laymen’s committee objected to the sale of the lot in question. The
Guidelines for
Canons require that ALL the church entities listed in Article IV (a)
Continuous Trial
thereof should give its approval to the transaction. Thus, when the
of Criminal
Supreme Bishop executed the contract of sale of petitioner’s lot
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despite the opposition made by the laymen’s committee, he acted
beyond his powers.

This case clearly falls under the category of unenforceable contracts


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mentioned in Article 1403, paragraph (1) of the Civil Code, which

IBP- provides, thus:


ZN
joins
comm
outre Art. 1403. The following contracts are unenforceable, unless they are
in
Jose ratified:
Dalm
March 17th, 2018
(1) Those entered into in the name of another person by one who has

been given no authority or legal representation, or who has acted


Salien beyond his powers;
featu
of
the *Case Digest by Claudette Anne G. Sayson JD IV, S.Y. 2019-2020
Revis
Guide
for
Conti By jurist | February 5th, 2020 | Case Digests | Comments Off
Trial
of
Crimi
Cases
May 24th, 2017

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CMS Logging Inc. v. Lim v. Saban


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