IGLESIA FILIPINA INDEPENDIENTE vs HEIRS of BERNARDINO TAEZA

FACTS: 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
his name. -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 land
against &ev. a and the defendant %ernardino *aea on the ground that &ev. a was not
authori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
properties and 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
cannot be assailed# as there are no provisions in its constitution and canons giving
the said authorit/ 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 %ishop &ev. a
is authori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
can be disposed of onl/ with the approval and conformit/ of the la/men?s committee# the
parish priest# the @iocesan %ishop# with sanction of the $upreme ouncil# and ,nall/
with the approval of the $upreme %ishop# as administrator of all the temporalities of the
hurch.> It is alleged 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 sale
Bnown to the $upreme %ishop but the latter still eCecuted the contract of sale despite
such opposition. -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# which provides# thusD

2rt. 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 no
authorit/ or legal representation# or who has acted be/ond his powersA

<etition ranted. IFI is the rightful owner of sub+ect lots.