(1) Iglesia Filipina Independiente (IFI) owned land that was subdivided and sold in parts, including to Bernardino Taeza. However, IFI claimed the Supreme Bishop who approved the sale lacked authority to do so under IFI's canons. (2) The court held that while the Supreme Bishop administered church properties, canon law required approval from other church bodies before land sales, which was not obtained. (3) Therefore, the sale contract was "unenforceable" under Civil Code provisions for contracts entered into without proper authority, and ownership of the lands remained with IFI.
(1) Iglesia Filipina Independiente (IFI) owned land that was subdivided and sold in parts, including to Bernardino Taeza. However, IFI claimed the Supreme Bishop who approved the sale lacked authority to do so under IFI's canons. (2) The court held that while the Supreme Bishop administered church properties, canon law required approval from other church bodies before land sales, which was not obtained. (3) Therefore, the sale contract was "unenforceable" under Civil Code provisions for contracts entered into without proper authority, and ownership of the lands remained with IFI.
(1) Iglesia Filipina Independiente (IFI) owned land that was subdivided and sold in parts, including to Bernardino Taeza. However, IFI claimed the Supreme Bishop who approved the sale lacked authority to do so under IFI's canons. (2) The court held that while the Supreme Bishop administered church properties, canon law required approval from other church bodies before land sales, which was not obtained. (3) Therefore, the sale contract was "unenforceable" under Civil Code provisions for contracts entered into without proper authority, and ownership of the lands remained with IFI.
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.