Case Digest (G.R. No. 171905)
Facts:
United Church of Christ in the Philippines, Inc. v. Bradford United Church of Christ, Inc., G.R. No. 171905, June 20, 2012, Second Division, Perez, J., writing for the Court.
Petitioner United Church of Christ in the Philippines, Inc. (UCCP) is a national religious corporation; respondent Bradford United Church of Christ, Inc. (BUCCI) is a local religious corporation incorporated on December 14, 1979. Individual respondents are BUCCI members Patricio Ezra, Geronimo Nazareth, Ruperto Mayuga, Sr., Robert Schaare, Henry Cariat, Reynaldo Ferrenal and others. UCCP alleges that BUCCI’s disaffiliation and later amendments to BUCCI’s Articles of Incorporation and By‑Laws violated UCCP polity and sought annulment and injunctive relief before the Securities and Exchange Commission (SEC).
After BUCCI’s Church Council Resolution of June 21, 1992 (retroactive to September 16, 1990) and ratifying referenda, BUCCI amended its Articles and By‑Laws and secured SEC approval on July 2, 1993. UCCP filed an action (eventually amended) with SEC contesting the validity of the disaffiliation, the amendments, and BUCCI’s continued use of the corporate name; SEC en banc dismissed UCCP’s petition in a decision dated January 27, 2004. UCCP sought review in the Court of Appeals; the Court of Appeals, in a decision promulgated June 17, 2005 (authored by Isaias P. Dicdican, with Lanzanas and Bruselas, JJ., concurring), affirmed the SEC. UCCP moved to drop BUCCI as a respondent on September 16, 2005; its motion for reconsideration was denied on February 21, 2006.
UCCP then filed a petition for review on certiorari under Rule 45 before this Court. The parties disputed (among other things) whether the issues were purely ecclesiastical and therefore nonjusticiable, whether BUCCI validly effected disaffiliation and amendments, wh...(Subscriber-Only)
Issues:
- Is the determination of BUCCI’s disaffiliation from UCCP a purely ecclesiastical (nonjusticiable) matter?
- Does petitioner UCCP have locus standi (is it the real party in interest) to challenge the amendments to BUCCI’s Articles of Incorporation and By‑Laws?
- Did the petition comply with the mandatory requirements of Rule 45 of the 1997 Rules of Civil Procedure?
- Were the amendments effectuating BUCCI’s disaffiliation valid and properly approved by the SEC?
- May BUCCI continue to use the corporate name “Bradford United Church of Christ, Inc.” (B...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)