Case Digest (G.R. No. 232968) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Santiago A. Fonacier v. Court of Appeals and Isabelo de los Reyes, Jr., G.R. No. L-5917, decided January 28, 1955, the Iglesia Filipina Independiente (IFI), through its Supreme Bishop Gerardo M. Bayaca, sued Bishop Santiago A. Fonacier in the Court of First Instance of Manila. The church sought an accounting and recovery of all temporal properties in Fonacier’s possession after he allegedly ceased to be its Obispo Máximo. While the case was pending, Isabelo de los Reyes, Jr. was elected Obispo Máximo and joined as co-plaintiff. Fonacier defended on multiple grounds: (1) he had not been properly removed as Supreme Bishop; (2) his legal successor was Bishop Juan Jamias, not De los Reyes; (3) he had already rendered accounts to Jamias and turned over church properties; (4) De los Reyes had joined the Protestant Episcopal Church of America and thus lost IFI membership and personality to sue; (5) Bayaca and De los Reyes had abandoned IFI faith and practices. On May 17, 1950, the t Case Digest (G.R. No. 232968) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Proceedings
- Iglesia Filipina Independiente (IFI), through Sup. Bishop Gerardo M. Bayaca, sued Bishop Santiago A. Fonacier in the CFI-Manila for accounting and recovery of IFI temporal properties, alleging Fonacier had ceased to be Obispo Maximo.
- Bishop Isabelo de los Reyes, Jr. joined as co-plaintiff after his election as Supreme Bishop; Fonacier petitioned to review CA’s affirmance of CFI judgment.
- Succession and Wartime Hold-Over
- Upon Aglipay’s death, Fonacier elected Obispo Maximo on Oct. 14, 1940; successor election due Sept. 1, 1943 was deferred by Bishops’ agreement (Dec. 16, 1941) due to WWII emergency.
- Post-liberation (Sept. 1, 1945) attempt to elect Obispo Maximo failed for lack of quorum; Fonacier’s term extended to Sept. 1, 1946.
- Internal Conflict and Expulsions
- Sept. 2, 1945: Consejo Supremo assigned Alejandro Remollino to Cavite; Fonacier enjoined him (Sept. 18) pending Obispo Maximo’s approval; Remollino insisted on his rights; Fonacier issued expulsion decrees (Oct. 8 and 16) against Remollino and Manuel Aguilar without full due-process.
- Dec. 1, 1945: Aguilar filed charges; Jan. 21–22, 1946: Consejo Supremo and Asamblea Magna “forced” Fonacier’s resignation and elected Bayaca as Obispo Maximo; Fonacier refused to turn over properties.
- Factional Split and Subsequent Elections
- Sept. 1, 1946: IFI divided. Faction A (De los Reyes) elected Isabelo de los Reyes, Jr. as Obispo Maximo; Faction B (Fonacier) elected Juan Jamias.
- May 22, 1947: National Library recognized De los Reyes faction (19 bishops, 252 priests) as sole IFI head; SC later denied Sec. of Public Instruction’s power to refuse marriage licenses to Fonacier group.
- Jan. 22, 1948: De los Reyes‘ group grew to 293 clergy; duly registered as corporation sole under Corp. Law.
Issues:
- Were the expulsions of Bishops Aguilar and Remollino by Fonacier valid under IFI constitution?
- Was Fonacier validly removed as Obispo Maximo by the Jan. 21–22, 1946 meetings of Consejo Supremo and Asamblea Magna?
- Were the elections of Bayaca (Jan. 22, 1946) and de los Reyes (Sept. 1, 1946) as Supreme Bishop valid, and was the election of Jamias invalid?
- Do civil courts have jurisdiction to review ecclesiastical actions affecting property and internal procedure?
- Did subsequent doctrinal amendments and consecrations in the Protestant Episcopal Church abrogate de los Reyes’ and Bayaca’s IFI membership and capacity to sue?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)