Case Digest (G.R. No. 144801) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Dominador L. Taruc et al. v. Bishop Porfirio B. de la Cruz et al. (G.R. No. 144801, March 10, 2005), the petitioners—lay members of the Philippine Independent Church (PIC) in Socorro, Surigao del Norte—sought the transfer of their parish priest, Rev. Fr. Rustom Florano, whom they believed was aligned with an opposing political faction. Their local ordinary, Bishop Porfirio B. de la Cruz, refused this request on the ground that political affiliations were insufficient cause for reassignment. Undeterred, the petitioners organized an open Mass on June 19, 1993, to be celebrated by Fr. Renato Z. Ambong, whose priestly credentials the Bishop questioned. On June 28, 1993, Bishop de la Cruz issued an order of expulsion/excommunication against the petitioners for (1) disobedience to ecclesiastical authority, (2) inciting dissension by holding the open Mass, and (3) threatening to occupy the parish church. An appeal to the Obispo Maximo resulted only in a nonintervention stance, and a Case Digest (G.R. No. 144801) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Parties
- Petitioners were lay members of the Philippine Independent Church (PIC) in Socorro, Surigao del Norte, led by Dominador L. Taruc.
- Respondents were Bishop Porfirio B. de la Cruz and Rev. Fr. Rustom Florano (clergy of the same PIC parish) and Delfin T. Bordas (alleged co-conspirator).
- Chronology of Events
- Petitioners sought the transfer of Fr. Florano, allegedly due to political factionalism; Bishop de la Cruz denied the request as unfounded.
- Petitioners organized an open Mass on June 19, 1993, to be celebrated by Fr. Renato Z. Ambong, despite the Bishop’s warnings regarding Ambong’s credentials.
- On June 28, 1993, Bishop de la Cruz issued an order expelling/excommunicating petitioners for:
- Disobedience to duly constituted church authority.
- Inciting dissension and division in the parish by holding an unauthorized Mass.
- Threatening to forcibly occupy the parish church, causing fear among members.
- Petitioners appealed to the Obispo Máximo, who advised voluntary resolution but declined to overturn the diocesan decision; a new bishop, Rhee M. Timbang, similarly refused to transfer Fr. Florano.
- Petitioners continued religious activities via Fr. Ambong and filed a complaint for damages with preliminary injunction in RTC Surigao City, alleging expulsion without due process.
- The RTC denied respondents’ motion to dismiss; the Court of Appeals reversed, holding that civil courts lack jurisdiction over purely ecclesiastical matters absent civil or property rights issues.
Issues:
- Jurisdictional Question
- Whether civil courts have authority to hear claims arising from the expulsion and excommunication of members of a religious institution.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)