Case Digest (G.R. No. 224521) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Bishop Shinji Amari of Abiko Baptist Church, represented by Shinji Amari and Missionary Baptist Institute and Seminary, represented by its Director Joel P. Nepomuceno, petitioners, vs. Ricardo R. Villaflor, Jr., respondent (G.R. No. 224521, February 17, 2020), the controversy arose from a Letter dated November 24, 2011 informing respondent of his removal as missionary of Abiko Baptist Church, cancellation of his American Baptist Association recommendation, and exclusion from church membership in Japan. Respondent, who since 1999 served as a missionary and was later appointed instructor at MBIS, refused to vacate church property where he had built a house and to obey reassignment orders. He claimed illegal dismissal and filed a complaint with the National Labor Relations Commission (NLRC) on September 10, 2012. The Labor Arbiter (LA) on February 12, 2013 found an employer-employee relationship based on respondent’s Appointment Paper, regularized status, and the November 24, 20 Case Digest (G.R. No. 224521) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedents
- On November 24, 2011, Ricardo R. Villaflor, Jr. (respondent) received a letter from Bishop Shinji Amari of Abiko Baptist Church (BSAABC) and Missionary Baptist Institute and Seminary (MBIS) informing him of:
- Removal as missionary of Abiko Baptist Church
- Cancellation of American Baptist Association (ABA) recommendation as national missionary
- Exclusion from Abiko Baptist Church membership in Japan
- Believing his dismissal was without due process or valid cause—and following the cutoff of his “love gift” support—respondent filed on September 10, 2012 a complaint for illegal dismissal before the National Labor Relations Commission (NLRC).
- Petitioners’ Allegations
- Respondent became a BSAABC-sponsored missionary in 1999 and was appointed instructor at MBIS effective June 1999; a 2006–2007 certification by MBIS Director Joel Nepomuceno states his teaching appointment was canceled due to distance between San Carlos City mission and MBIS in Minglanilla, Cebu.
- BSAABC contended that its mission at San Carlos City was completed; respondent refused reassignment, having constructed a personal house on church land without consent. On November 20, 2011, BSAABC members voted to remove him and, by letter dated November 24, 2011, demanded he vacate the property (offering to purchase his house).
- Proceedings Below
- Labor Arbiter (February 12, 2013): Exercising jurisdiction, found an employer-employee relationship (Appointment Paper as evidence), held removal a de facto termination without valid cause, and awarded backwages, separation pay, 13th-month pay, moral and exemplary damages, and attorney’s fees.
- NLRC (July 15, 2013): Reversed the Labor Arbiter for lack of jurisdiction, ruling respondent’s expulsion an ecclesiastical affair.
- Court of Appeals (October 27, 2015; Resolution April 26, 2016): Reinstated the Labor Arbiter’s decision, distinguishing secular termination as missionary from ecclesiastical exclusion, and applying the four-fold test to find an employment relationship and lack of just cause.
Issues:
- Whether the Court of Appeals erred in ruling that respondent was illegally dismissed when his removal as a missionary involved an ecclesiastical affair beyond civil-court jurisdiction.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)