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    #112 Iglesia Filipina vs. Heirs of Taeza

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    Harry Dave Ocampo Pagaoa
    The Iglesia Filipina Independiente filed a complaint to annul a deed of sale with mortgage from 1976 regarding a parcel of land. The Supreme Bishop of the church sold the land to Bernardino Taeza through installment payments. However, the sale was invalid because it did not comply with the Canons of the church, which require approval from all church entities, including the laymen's committee. The laymen's committee opposed the sale, but the Supreme Bishop executed the contract anyway. Therefore, the contract is considered unenforceable as the Supreme Bishop acted beyond his powers in executing the sale.

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    #112 Iglesia Filipina vs. Heirs of Taeza

    Uploaded by

    Harry Dave Ocampo Pagaoa
    238 views2 pages
    The Iglesia Filipina Independiente filed a complaint to annul a deed of sale with mortgage from 1976 regarding a parcel of land. The Supreme Bishop of the church sold the land to Bernardino Taeza through installment payments. However, the sale was invalid because it did not comply with the Canons of the church, which require approval from all church entities, including the laymen's committee. The laymen's committee opposed the sale, but the Supreme Bishop executed the contract anyway. Therefore, the contract is considered unenforceable as the Supreme Bishop acted beyond his powers in executing the sale.

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    #112 Iglesia Filipina vs. Heirs of Taeza.docx

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    The Iglesia Filipina Independiente filed a complaint to annul a deed of sale with mortgage from 1976 regarding a parcel of land. The Supreme Bishop of the church sold the land to Bernardino Taeza through installment payments. However, the sale was invalid because it did not comply with the Canons of the church, which require approval from all church entities, including the laymen's committee. The laymen's committee opposed the sale, but the Supreme Bishop executed the contract anyway. Therefore, the contract is considered unenforceable as the Supreme Bishop acted beyond his powers in executing the sale.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    238 views2 pages

    #112 Iglesia Filipina vs. Heirs of Taeza

    Uploaded by

    Harry Dave Ocampo Pagaoa
    The Iglesia Filipina Independiente filed a complaint to annul a deed of sale with mortgage from 1976 regarding a parcel of land. The Supreme Bishop of the church sold the land to Bernardino Taeza through installment payments. However, the sale was invalid because it did not comply with the Canons of the church, which require approval from all church entities, including the laymen's committee. The laymen's committee opposed the sale, but the Supreme Bishop executed the contract anyway. Therefore, the contract is considered unenforceable as the Supreme Bishop acted beyond his powers in executing the sale.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 2

    Doctrine:  Unenforceable contracts are those which cannot be enforced by a proper action in

    court, unless they are ratified, because either they are entered into without or in excess of
    authority or they do not comply with the statute of frauds or both of the contracting parties do not
    possess the required legal capacity.

    IGLESIA FILIPINA INDEPENDIENTE v. HEIRS OF BERNARDINO TAEZA

    G.R. No. 179597, December 03, 2014


    THIRD DIVISION, PERALTA, J.

    FACTS:

    Iglesia Filipina Independiente was the owner of a parcel of land described as Lot 3653,
    containing an area of 31,038 square meters, 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 Lot 3653-D, with an area of
    15,000 square meters, to one Bienvenido de Guzman.

    Rev. Macario Ga, in his capacity as the Supreme Bishop of the plaintiff-appellee, to the
    defendant Bernardino Taeza, for the amount of ₱100,000.00, through installment, with mortgage
    to secure the payment of the balance. Subsequently, the defendant allegedly completed the
    payments. In 1977, a complaint for the annulment of the February 5, 1976 Deed of Sale with
    Mortgage was filed by the Parish Council of Tuguegarao, Cagayan, represented by Froilan
    Calagui and Dante Santos.

    ISSUE:

    Was the sale valid?

    HELD:

    No.

    The sale is invalid for not being in conformity with the Canons of the church.

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

    Sec. 113. Acquisition and alienation of property. – Any corporation sole may purchase and hold
    real estate and personal property for its church, charitable, benevolent or educational purposes,
    and may receive bequests or gifts for such purposes. Such corporation may mortgage or sell real
    property held by it upon obtaining an order for 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,
    regulations and discipline of the religious denomination, sect or church, religious society or order
    concerned represented by such corporation sole regulate the method of acquiring, holding,
    selling and mortgaging real estate and personal property, such rules, regulations and discipline
    shall control, and the intervention of the courts shall not be necessary.
    The Court finds it erroneous for the CA to ignore the fact that the laymen’s committee
    objected to the sale of the lot in question. The Canons require that ALL the church entities listed
    in Article IV (a) thereof should give its approval to the transaction. Thus, when the Supreme
    Bishop executed the contract of sale of petitioner’s lot despite the opposition made by the
    laymen’s committee, he acted beyond his powers.

    This case clearly falls under the category of unenforceable contracts mentioned in Article
    1403, paragraph (1) of the Civil Code, which provides, thus:

    Art. 1403. The following contracts are unenforceable, unless they are ratified:

    (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 beyond his powers;

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