*265.* _Title, Taxes, Judicial Notice._—If the title is in the bishop in fee in accordance with church law it is not “owned by any religious association” and is liable for taxes. The laws of the Catholic Church are not the subject of judicial notice, but must be alleged and proved as any other fact.(478) *266.* _Title, Diocese, Rule._—Where the title to the property of the diocese was in the bishop for the use of the church and subsequently the diocese was incorporated, the bishop was not divested of title and it was still necessary to have the property conveyed by deed.(479) In some other States, however, the contrary rule prevails.(480) *267.* _Priest, Deed, Funds._—Where it was claimed that a priest purchased lands and took the deed in his own name and paid therefor with funds belonging to the congregation, the conveyance will not be decreed by the court only upon the clearest and most satisfactory evidence.(481) *268.* _Monks, Missions, Title._—The fact that the monks or priests were at the head of the missions in California when it was acquired by the United States, does not prove that the Catholic Church had universal ownership of the property.(482) The acts of Congress giving the city of San Antonio authority to sell public lands, was intended, no doubt, to dispose of mission property, but it was held not to affect the Catholic Church, the title to which had been confirmed by another act of Congress.(483) *269.* _Texan Revolution, Land._—At the time of the Texan Revolution, a Catholic church held no real estate of perfect title, but enjoyed only the use of the land that it possessed and continued so to occupy after the admission of Texas into the Union.(484) *270.* _Priest, Agent, Deed._—The priest in charge of a congregation is the agent of the archbishop, and where the title to the real estate is conveyed by absolute deed to the bishop, the congregation, against the protest of the priest and without obtaining leave from the bishop, has no right to tear down a church for the purpose of rebuilding or repairing it.(485) And a priest in charge of mission property may maintain in his name an action to recover its possession.(486) *271.* _Devise, Uncertainty._—A devise of property “to the Roman Catholic Orphans” of a certain diocese, making the bishop of the diocese executor of the will and giving him power to sell the property and use the proceeds for the benefit of the Roman Catholic orphans, is void for uncertainty.(487) *272.* _Donor, Ambiguous Provision._—The religious convictions of the donor may be shown for the purpose of construing an ambiguous provision of a deed or will.(488)