The Supreme Court ruled that a church has the right to eject a former pastor from church property, even if the pastor claims the church was not the actual purchaser. The Court emphasized the importance of adhering to procedural rules while ensuring substantial justice. This decision clarifies the balance between technical compliance and the merits of a case, especially concerning property disputes within religious organizations.

Whose Land Is It Anyway? A Church’s Legal Battle for Its Property

This case originated from a dispute over the possession of a church lot and building, registered under the name of Evangelical Free Church of the Philippines (respondent). Elinel Caña (petitioner), a former pastor assigned to Malabon Evangelical Free Church (MCEC), was permitted to occupy the property. However, after his license was revoked, he refused to vacate the premises, leading the church to file an ejectment suit. The initial decisions of the Municipal Trial Court (MTC) and Regional Trial Court (RTC) favored Caña, but the Court of Appeals (CA) reversed these decisions, ordering Caña to vacate the property.

At the heart of the legal battle were procedural technicalities and conflicting claims of ownership. Caña argued that the CA erred in giving due course to the church’s petition, citing non-compliance with rules regarding the certification of non-forum shopping and the submission of pertinent documents. He also claimed that MCEC, not the respondent, had actually purchased the property, and thus he had a right to remain. The church countered that it held the title to the property and that the procedural lapses were cured by subsequent compliance. Furthermore, it asserted its right to possess the property as the registered owner.

The Supreme Court addressed the procedural issues first, emphasizing that while strict compliance with procedural rules is mandatory, substantial compliance can suffice under justifiable circumstances. In this context, the Court highlighted that the subsequent submission of a Board Resolution authorizing the church’s counsel to sign the certification of non-forum shopping constituted substantial compliance. Citing National Steel Corporation v. Court of Appeals, the Court reiterated that procedural rules should serve to promote justice and not to subvert it through excessive literalness.

Circular No. 28-91 was designed to serve as an instrument to promote and facilitate the orderly administration of justice and should not be so interpreted with such absolute literalness as to subvert its own ultimate and legitimate objective or the goal of all rules of procedure — which is to achieve substantial justice as expeditiously as possible.

Regarding the claim of ownership, the Court found Caña’s evidence insufficient to overcome the church’s title to the property. While Caña presented affidavits and a resolution from MCEC asserting its ownership, the Court deemed these self-serving and unsubstantiated. The church, on the other hand, presented the Deed of Absolute Sale and the Transfer Certificate of Title, both of which unequivocally proved its ownership. The Court reaffirmed the principle that a certificate of title serves as evidence of an indefeasible and incontrovertible title to the property.

The Court also dismissed Caña’s argument that funds from MCEC’s Church Assistance Revolving Fund (CARF) loan were used to purchase the property. The Court agreed with the CA’s finding that evidence merely proved the full payment of MCEC’s CARF loan but not the usage of proceeds to purchase the subject property. The Court highlighted that such claims could not supersede the respondent’s presented documentary evidence which established the ownership.

Building on these points, the Supreme Court emphasized that the person who has a Torrens Title over a land is entitled to possession. The Court affirmed that a person whose stay is merely tolerated becomes an illegal occupant the moment they are required to leave, thereby, affirming CA’s decision. This ruling reinforced the church’s right to eject Caña from the property.

Consequently, the Supreme Court denied Caña’s petition, affirming the CA’s decision. The Court underscored that the ruling was conclusive only on the issue of possession de facto, and would not bar or prejudice a separate action involving title to the property.

FAQs

What was the key issue in this case?	The key issue was whether the Evangelical Free Church of the Philippines had the right to eject its former pastor, Elinel Caña, from a property registered under the church’s name. This involved questions of procedural compliance and property ownership.
Why did the Court of Appeals initially dismiss the church’s petition?	The CA initially dismissed the petition due to non-compliance with procedural rules, specifically the lack of proper verification and certification of non-forum shopping, and failure to attach copies of essential pleadings.
How did the church rectify the procedural lapses?	The church rectified the lapses by submitting a copy of the Board Resolution authorizing its counsel to sign the certification of non-forum shopping and providing the necessary documents.
What did Elinel Caña argue regarding the property’s ownership?	Caña argued that the Malabon Christian Evangelical Church (MCEC) had actually purchased the property and that he had a right to remain on the premises as a result.
What evidence did the church present to prove its ownership?	The church presented the Deed of Absolute Sale and the Transfer Certificate of Title, both registered under its name, as evidence of its ownership of the disputed property.
Why did the Court not accept Caña’s evidence of ownership?	The Court deemed Caña’s evidence, consisting of affidavits and a resolution from MCEC officials, as self-serving and unsubstantiated. The documents attested MCEC is the owner but were deemed as having vested interest, thus, not considered competent.
What is the significance of having a Torrens Title?	Having a Torrens Title signifies an indefeasible and incontrovertible title to the property in favor of the person whose name appears therein, entitling them to possession.
What type of possession was the central issue in this case?	The central issue was possession de facto, which refers to actual or material possession of the property, rather than ownership itself.
Was the issue of ownership resolved conclusively in this case?	No, the Supreme Court clarified that the ruling was conclusive only on the issue of possession de facto. It would not prevent a separate action regarding the title or ownership of the property.

This case reinforces the importance of adhering to property rights and the legal procedures necessary for asserting those rights. While technical compliance with procedural rules is essential, the Court’s decision highlights that substantial justice should ultimately prevail.

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: Elinel Caña v. Evangelical Free Church of the Philippines, G.R. No. 157573, February 11, 2008