Digest for Barlin v Ramirez

20. Barlin v Ramirez [GR L-2832, Nov 24, 1906]—ATV

A very old case that happened in 1906, in the pueblo of Lagonoy, province of Ambos Camarines. The Roman Catholic Church which had been razed to the ground in 1869 was reconstructed, from government funds and from “voluntary” labor of the townspeople, upon orders of the town officials, also based on general laws and guidelines of the Spanish government. Reconstruction was completed in 1873, and until 1902 a Roman Catholic priest administered this church, until it came under the care of P Vicente Ramirez. In November 1902, a successor to Ramirez was appointed but he refused to turn over the church, convent and other properties. This was the point in history when Spain ceded authority to the United States and all its property together with it. Many Filipino clergy rebelled against the Roman Catholic Church whom they said refused to recognize and grant the rights of the Filipino priests. This Filipino priests joined together and formed the United Filipino Church, who, though not recognizing the Roman Catholic Church, nonetheless continued to hold office and ceremonies in the Roman Catholic tradition, on the condition that unless the Roman Catholic Church recognized them, they will hold on to their church properties and refuse to turn them over. For reason, REV. JORGE BARLIN, in his capacity as apostolic administrator of this vacant bishopric and legal representative of the general interests of the Roman Catholic Apostolic Church in the diocese of Nueva Caceres came to file a case against P. VICENTE RAMIREZ, ex-rector of the Roman Catholic Apostolic Parochial Church of Lagonoy and the Municipality of Lagonoy. Rev Barlin held that the church and its adjuncts were a property of the Roman Catholic Church, while Padre Ramirez held that the town of Lagonoy was the owner of the property. The court held that the church was a property of the Roman Catholic Church. There was a law that states that all church buildings were made by the Spanish government and representatives in the Philippines using government and private local funds, but the Spanish government implemented this to the effect that the churches and its income were dedicated for the propagation of the faith. Hence, its properties were beyond the commerce of man. Priests held them in the concept of guardians or stewards. The truth is that, from the earliest times down to the cession of the Philippines to the United States, churches and other consecrated objects were considered outside of the commerce of man. They were not public property, nor could they be subjects of private property in the sense that any private person could the owner thereof. They constituted a kind of property distinctive characteristic of which was that it was devoted to the worship of God Furthermore, the municipality cannot show evidence of title, right of ownership or possession. On the contention that the Roman Catholic Church no longer had legal and juridical personality in the islands, since the latter half of the third century, and more particularly since the year 313, when Constantine, by the edict of Milan, inaugurated an era of protection for the church, the latter gradually entered upon the exercise of such rights as were required for the acquisition, preservation, and transmission of property the same as any other juridical entity under the laws of the Empire. (atv) (recommended reading, very interesting case ;)