Title
Supreme Court
Pasay City Alliance Church vs. Benito
Case
G.R. No. 226908
Decision Date
Nov 28, 2019
A church minister's non-renewal, based on internal policy requiring annual courtesy resignations, was deemed an ecclesiastical matter, exempt from labor tribunal jurisdiction.

Case Digest (G.R. No. 226908)
Expanded Legal Reasoning Model

Facts:

  • Parties and Organizational Background
    • Petitioner:
      • Pasay City Alliance Church (PCAC) – one of the local churches affiliated with Christian and Missionary Alliance Churches of the Philippines (CAMACOP), a religious society registered with the Securities and Exchange Commission.
      • Co-petitioner: CAMACOP, which provides the doctrinal and administrative framework for its member churches.
    • Respondent:
      • Fe P. Benito – a licensed Christian minister of CAMACOP who served various roles in PCAC.
  • Appointment and Position
    • Educational and Ministerial Background:
      • Benito graduated from CAMACOP’s Ebenezer Bible College and Seminary as one of PCAC’s scholars.
      • She initially served as Head of Fellowship and Discipleship before assuming a higher administrative role.
    • Professional Assignment:
      • In 2005, Benito was appointed as the Head of Membership and Evangelism Ministry, later renamed to Head of Pastoral Care and Membership in 2009.
      • Her service was rendered without a formal written contract despite her significant responsibilities.
  • Implementation of the Church Policy on Courtesy Resignation
    • Internal Policy:
      • CAMACOP and PCAC observed a policy, expressed in Article VII, Section 3(2) of the Amended Local Church Administrative and Ministry Guidelines, mandating that ministers without written contracts tender a courtesy resignation annually.
      • The policy provides for the minister’s re-evaluation and potential reassignment based on mutual agreement and pastoral fitness.
    • Application of the Policy:
      • Though adopted in 2005, the practice in PCAC began in 2009 under the leadership of Reverend William Cargo.
      • Ministers, including Benito, were expected to tender their courtesy resignations as a prelude to their reappointment or reassignment.
  • Chronology of Events Leading to the Dispute
    • Initial Compliance and Reappointment:
      • Benito tendered her courtesy resignation on January 30, 2011, in compliance with the policy, and was reappointed to her position for another year.
    • Decision Not to Renew Appointment:
      • During the CMT meeting on February 12, 2012, the Church Ministry Team recommended that Benito not be reappointed due to alleged lapses including:
        • Failure to effectively share ministry responsibilities with new attendees.
ii. Delays and discrepancies in the disbursement of speaker’s honoraria and related administrative shortcomings. iii. Inadequate response to critical incidents (e.g., the handling of a member’s death).
  • Despite the recommendation, Benito continued serving and tendered another courtesy resignation on February 17, 2013, along with additional credentials as required by the CMT.
  • Additional Administrative Directives:
    • On May 29, 2013, Benito was instructed to endorse her workload and turn over the prayer ministry to another pastor.
    • On December 15, 2013, she was formally notified that her term would not be extended as per the earlier CMT recommendation.
  • Labor Case and Subsequent Proceedings
    • Filing of Complaint:
      • Aggrieved by the non-renewal of her appointment, Benito filed a complaint for illegal dismissal, damages, and attorney’s fees before the Labor Arbiter.
      • She claimed that she had attained regular status by operation of law, thus entitling her to security of tenure.
    • Labor Arbiter’s Ruling:
      • The Labor Arbiter found that an employer-employee relationship existed based on various letters, directives regarding work hours, assignments, and evidenced through payslips and statutory deductions (SSS, Philhealth, and Pag-ibig).
      • The Arbiter ruled in her favor, declaring her dismissal illegal and awarding separation pay and backwages.
    • Reversal by the NLRC and Subsequent Appeal:
      • The National Labor Relations Commission (NLRC) reversed the Labor Arbiter’s ruling, asserting that the non-renewal was tied to a church policy, thereby constituting an ecclesiastical matter outside the tribunal’s jurisdiction.
      • The NLRC’s January 12, 2015 Resolution (later denied in its reconsideration on February 27, 2015) set aside the Arbiter’s decision.
      • The Court of Appeals (CA) later annulled the NLRC resolutions, holding that the termination had secular facets related to employment, and denied the petitioners’ motion for reconsideration.
    • Supreme Court Involvement:
      • Petitioners elevated the case to the Supreme Court via a Petition for Review on Certiorari.
      • The central issue pertained to whether the termination of Benito was an ecclesiastical matter beyond the reach of labor tribunals or a dismissal under the Labor Code.
  • Arguments of the Parties
    • Petitioners’ (PCAC/CAMACOP) Contentions:
      • The non-renewal or non-extension of Benito’s appointment was the result of enforcing a valid religious policy aimed at ensuring ministerial fitness.
      • The decision was akin to the reassignment practices in other religious institutions (e.g., the reassignment of Catholic priests) and was purely an internal ecclesiastical matter.
      • The enrollment of ministers in government benefit schemes does not transform the nature of their ministerial role into that of a standard employment relationship.
    • Respondent’s (Benito’s) Assertions:
      • Benito argued that she was “hired,” received directives, and had benefits that collectively established an employer-employee relationship.
      • She maintained that the termination or non-renewal of her appointment constituted an illegal dismissal subject to labor protections.

Issues:

  • Jurisdictional Determination
    • Whether the termination of Fe P. Benito by PCAC, enforced through the policy of annual courtesy resignations, is an ecclesiastical matter over which labor tribunals lack jurisdiction.
    • Whether adjudicating this matter would constitute undue state interference in church affairs, violating the constitutional separation of church and state.
  • Characterization of the Ministerial Relationship
    • Whether the evidence—such as work directives, schedules, and statutory contribution deductions—establishes a conventional employer-employee relationship under the Labor Code.
    • Whether such tangibles, notwithstanding the absence of a written contract, are sufficient to render Benito’s engagement as a typical employment relationship.
  • Nature and Implications of the Termination
    • Whether the non-renewal of Benito’s appointment was a termination based on administrative inefficiencies (a secular matter) or a manifestation of internal ecclesiastical discipline.
    • Whether enforcement of internal church guidelines regarding ministerial reassignment is subject to review under labor jurisprudence.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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