delivered the opinion of the court:
Frаnk Carson, county treasurer, applied to the county court of Winnebago county for judgment, with order of sale of a tract of land containing 11.64 acres on the west bank of Rock river, adjoining the city of Rockford on the south, delinquent for general taxes of 1921. The appellant, Peter J. Muldoon, Catholic Bishop of Rockford, filed his objection on the ground that the property was exempt, alleging that it was purchased by him for the purpose of providing a monastery for an order known in the Catholic church as the Poor Clares; that prior to April 1, 1921, the ordеr of Poor Clares occupied the premises, which were improved with two houses and out-buildings, and since said time the property has been known as the Monastery of the Corpus Christi; that the оrganization was essentially a religious one, having no other desire or function but self-denial and prayer; that the organization consisted of a mother superior and about fifteen associate sisters, having no desire other than manual labor and prayer, and that all the property had been used and devoted exclusively to the support of the monastery and the сarrying on of the religious work of the order known as the Poor Clares. Upon a hearing the objection was overruled and judgment was entered, from which this appeal was prosecutеd.
Historically the Poor Clares of the Order of St. Clare was organized in the year 1212 in Italy by St. Clara, who from religious zeal gave up wealth and worldy position and she and her followers accеpted vows of obedience, chastity, poverty and seclusion from the public. The order was instituted in the United States in 1875, and the branch of the order to which the Rockford monastery belongs nоt only impose three ordinary vows of poverty, chastity and obedience, but also a vow of enclosure, which cuts them off from all intercourse with the outside world and imposes upon thеm silence, except during a short daily recreation period.
The hearing of the objection was upon a written stipulation stating the following facts: Peter J. Muldoon, Catholic Bishop of Rockford, acquired title to the premises by warranty deed on December 19, 1919, and holds the property for the use and occupancy of the nuns of the Order of St. Clare, or the Poor Clares. On March 1, 1920, the nuns of the order took possession of the property and have occupied the same continuously since that time for the purposes of the order. The property is improved with two large brick buildings and a small brick building, a barn and outbuildings, and a tight high board fence eight feet high surrounds the entire premises, except a lawn in front of the building of approximately hаlf an acre. The order of which the nuns are members is what is called a contemplative order, and they spend a major portion of their time in prayer and meditation. Each one has taken a vow of poverty, chastity and obedience. They have no activities or duties in- connection with the public or outside of the cloister and are not permitted to leave the cloister. They are not permitted to hold property in their own names, and having gone into the cloister they are there for life and do not even own the clothes they wear. They depend for their support mainly on the charity of the public, but some income is made from making ecclesiastical vestments, which is a very small part of their support, and they live on what they receive in charity from the public and what they can derive from the land. They cultivate a portion of the land to supply themselves with vegetables, keep a cow fоr their supply of milk, and raise some fowls and some little fruit on the property. They do all the work themselves in caring for the buildings and cultivating the land, attending the fowls and the cow. The order is authorizеd by the Catholic church, and aside from the actual work of taking care of the buildings and land the nuns lead a life of prayer and meditation applying to all the people of the world, regardless of creed or sex. The manual work is for the purpose of exemplification of the humility and dignity of labor and to assist in support of the monastery. The order was instituted in the Catholic diocese of Rockford on March 20, 1916, consisting at that time of two nuns, and at the time of the hearing there were fourteen nuns, together with three novices and five preparing for entrance in the cloister. In the basement of one of the buildings is a chapel for devotion and the mass, and the rest of the buildings are used for prayer, meditation, labor, recreation, kitchеn, dining and sleeping rooins for the nuns and novices. The chapel is divided into two parts, the inside chapel for the use of the nuns and an outside chapel for the use of the public.
The cоnstitution gives to the legislature power to exempt from taxation property devoted to certain specified uses, all of which have some direct and immediate relation to the public and carry with them compensations justifying the exemption. In the case of property of the State, counties and municipal corporations, any taxes imposed wоuld be paid by the body of tax-payers. In the case of school and charitable purposes, the general public is relieved from supplying those things which otherwise would have to be provided by the public, and the burden of taxation is thereby lessened. The use of property for religious purposes tends to conditions affording compensation for the exemption, which is not a mere gift to religion but for a public purpose. In every case the exemption rests upon a general public benefit. It is the settled rule that words used in a statute are to be given their ordinary meaning in general and popular use unless the court is certain that it is following the legislative intent in giving them a different meaning. (Way v. Way,
The judgment is affirmed.
Judgment affirmed.