Eladio Alonso vs. Tomas Villamor, et al.

Posted Jul 26, 1910

By Anonymous

6 min read

Case Title and Citation

Eladio Alonso, plaintiff-appellee, vs. Tomas Villamor, et al., defendants-appellants.
G.R. No. L-2352, July 26, 1910
Supreme Court - En Banc
Ponente: Justice Moreland

Facts

On December 11, 1901, members of the municipal board of Placer addressed a letter to R.P. Eladio Alonso, priest in charge of the local Roman Catholic Church, stating they had received an order from the provincial fiscal (dated the 5th instant) asserting that cemeteries, convents, and other buildings erected on town land or at town expense belong to the town, and directing that revenues and certain donated images and their alms be turned into the municipal treasury.
The municipal-board letter asked Alonso to deliver the key of the alms box for the image of St. Vicente.
On December 13, 1901, the defendants took possession of the church, its appurtenances (including the cemetery and convent), and the personal property contained therein; Padre Alonso protested and was removed from possession.
Plaintiff brought an action to recover the value of articles taken from the church and the rental value of the church and appurtenances from December 11, 1901 until April 1904.
The court below awarded the plaintiff P1,581 with interest at 6% from the date of judgment, consisting of P741 for the articles and P840 for rent; the defendants appealed.
Defendants’ primary defense: the church and its contents were erected/purchased with funds voluntarily contributed by the people of the municipality, so the municipality was the owner.
The ownership question had been litigated previously in The Roman Catholic Apostolic Church v. Municipality of Placer (September 23, 1908; 11 Phil. Rep. 315), and in Barlin v. Ramirez (7 Phil. Rep. 41), and considered with reference to a decision from Porto Rico (Municipality of Ponce v. Roman Catholic Apostolic Church in Porto Rico, 28 Sup. Ct. Rep. 737).
The court examined the record and evidence and found the property to be the property of the Roman Catholic Church at the time of defendants’ seizure.

Issues

Were the defendants entitled to take possession of the church and its appurtenances on the ground that the municipality owned them?
Was the seizure of the church property and occupation by the defendants wrongful, making them liable for the value of articles taken and rental value?
Was the action improper because it was prosecuted in the name of Padre Eladio Alonso rather than in the name of the bishop or the Roman Catholic Apostolic Church (the real party in interest)?
Was the valuation evidence of the articles taken and of the rent incompetent and therefore a ground for reversal?

Ruling

No - The court found the property belonged to the Roman Catholic Church and the defendants were not entitled to take possession on the municipality ownership theory.
Yes - The seizure and occupation were wrongful and illegal; the lower court’s award for value and rent was correct.
No - The court held the action could be amended to substitute the Roman Catholic Apostolic Church (or the bishop) as the real party in interest; reversal was not required for the misnomer.
No - Because no objection to the competency of the valuation evidence was made at trial, the objection could not be raised for the first time on appeal.

Reasoning / Ratio Decidendi

On ownership:
- The court reviewed the record and prior decisions (The Roman Catholic Apostolic Church v. Municipality of Placer, 11 Phil. Rep. 315; Barlin v. Ramirez, 7 Phil. Rep. 41; and the Porto Rico decision cited) and concluded the church, its appurtenances, and the articles were the property of the Roman Catholic Church at the time of seizure.
- Accordingly, municipal officers’ occupation and seizure were without legal right and therefore wrongful.
On valuation evidence:
- Although counsel on appeal contended that values and rent were not proved by competent evidence, the court noted no objection to the introduction of that evidence was made at trial; issues not raised before the trial court could not be considered for the first time on appeal.
On substitution of the real party in interest:
- Section 114 of the Code of Civil Procedure requires actions to be prosecuted in the name of the real party in interest; the court acknowledged Padre Alonso was not the real party but had prosecuted the action on behalf of the bishop/the Church.
- Section 110 of the Code of Civil Procedure permits amendments to add or strike out the name of any party in furtherance of justice; Section 503 provides that judgments shall not be reversed on formal or technical grounds that did not prejudice real rights.
- The plaintiff consistently asserted he acted not on his own behalf but for the Church; no one was misled and no substantial prejudice resulted from the misnomer.
- The court adopted a substance-over-form approach, finding the error purely formal and subject to correction by substituting the Roman Catholic Apostolic Church as plaintiff.
- The court cited multiple authorities approving substitution and refusal to allow procedural technicalities to defeat substantive rights.

Doctrine / Legal Principle

Property devoted to ecclesiastical use belongs to the religious corporation (Roman Catholic Apostolic Church) despite contributions by towns or individuals, when established by applicable precedents.
Courts should favor substance over form; procedural misnomers may be corrected by amendment to name the real party in interest when no prejudice results.
Under Code of Civil Procedure:
- Sec. 110 permits amendment of pleadings to add/strike/correct party names to determine the actual merits.
- Sec. 503 precludes reversal for formal or technical errors that did not prejudice substantive rights.
Evidentiary objections not raised at trial are generally waived and cannot be raised for the first time on appeal.

Disposition

The process, pleadings, proceedings, and decision are amended by substituting the Roman Catholic Apostolic Church in the place and stead of Eladio Alonso as party plaintiff; the complaint is treated as though originally filed by the Church.
The judgment of the court below is affirmed as amended.
No special finding as to costs was made.
The lower court’s award of P1,581 with interest at 6% from the date of judgment (comprised of P741 for articles and P840 for rent) was upheld.

Concurring / Dissenting Opinions

Chief Justice Arellano, Justices Torres, Johnson, and Trent concurred.
No dissenting opinion is reported.

Significance / Notes

Confirms that municipal officials cannot appropriate church property on the ground of municipal ownership when prior law and precedent recognize ecclesiastical ownership.
Reinforces judicial authority to correct misnomers and substitute the real party in interest to avoid rejecting meritorious claims on procedural technicalities.
Illustrates the principle that pleadings’ form should not defeat substantive rights when no prejudice results.
Emphasizes waiver of appellate review for evidentiary objections not raised at trial.

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