Case Digest (G.R. No. L-5917)
Facts:
Santiago A. Fonacier v. Court of Appeals and Isabelo de los Reyes, Jr., G.R. No. L-5917, January 28, 1955, the Supreme Court En Banc, Bautista Angelo, J., writing for the Court.The Iglesia Filipina Independiente (IFI), through its then Supreme Bishop Gerardo M. Bayaca, sued Bishop Santiago A. Fonacier in the Court of First Instance of Manila to compel an accounting and recovery of temporal properties alleged to be in Fonacier’s possession on the ground that he had ceased to be Supreme Bishop. After the complaint was filed, Isabelo de los Reyes, Jr. was elected Supreme Bishop by Bayaca’s faction and later joined as co-plaintiff in a supplemental complaint. Fonacier defended by denying he had been validly removed, asserting that Juan Jamias was his lawful successor (elected by Fonacier’s faction), that he had already rendered an accounting to Jamias and transferred properties, and that De los Reyes had joined the Protestant Episcopal Church of the United States and therefore lacked capacity; he further alleged that Bayaca and De los Reyes had abandoned IFI faith and constitution and so lacked standing.
On May 17, 1950 the trial court declared Mons. Isabelo de los Reyes, Jr. the sole and legitimate Obispo Maximo of the IFI and ordered Fonacier to render an accounting of his administration of church temporalities “from the time he began occupying the position of Secretario de Economia Temporal … until the present time.” The Court of Appeals affirmed the trial court’s decision in toto after an extensive review of the oral and documentary evidence, finding (inter alia) that Fonacier had been validly forced to resign on January 22, 1946, that the ousters of certain bishops alleged by Fonacier (notably Aguilar and Remollino) were invalid for lack of constitutionally required procedure, that Bayaca’s and later De los Reyes’ elections were valid, and that alleged doctrinal changes and consecrations in the American Episcopal Church did not, on the record, deprive the appellees of IFI membership or capacity to sue. Fonacier sought relief in the Supreme Court by a petition for review (raising twelve assignments of error), asking reversal of the Court of Appeals’ factual and legal conclusions.
The Supreme Court accepted the appeal as a Rule 45-type review of the Court of Appeals’ judgment but emphasized that findings of fact by the Court of Appeals are conclusive on the Supreme Court and limited its review largely to questions of law and to whether the Court of Appeals properly applied governing rules (citing Moran on the Rules of Court and section 2, Rule 46). The Court summarized the salient factual findings of the Court of Appeals: Fonacier had been elected Obispo Maximo in 1940; wartime delays produced interim arrangements; postwar councils in 1945–46 produced conflicts, charges, and an internal proceeding that culminated in a January 21–22, 1946 Supreme Council/Asamblea meeting which, the Court of Appeals...(Subscriber-Only)
Issues:
- Did the civil courts have authority to review and set aside the alleged ecclesiastical ousters of bishops (Aguilar and Remollino) where the claimed removals allegedly violated the IFI constitution?
- Was the forced resignation of Mons. Fonacier and the January 21–22, 1946 meetings of the Supreme Council and Asamblea (which resulted in election of Mons. Bayaca) legally constituted and therefore valid?
- Were the episcopal consecrations performed by Fonacier (and the consecrations relied upon by Fonacier’s faction) valid under the IFI constitution and sufficient to make the consecrated persons members of the legitimate governing bodies?
- Did the later doctrinal amendments and the consecrations of De los Reyes, Bayaca and Aguilar by the Protestant Episcopal Church of the United States constitute abandonment of faith or a...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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