Case Digest (G.R. No. 171905) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In United Church of Christ in the Philippines, Inc. v. Bradford United Church of Christ, Inc. (G.R. No. 171905, June 20, 2012), the petitioner, United Church of Christ in the Philippines, Inc. (UCCP), a national religious corporation organized in 1948 under Philippine law and governed by its 1980 and amended 2005 Constitution, assailed the separate incorporation and amendments of the respondent, Bradford United Church of Christ, Inc. (BUCCI), and the right of its officers—Patrizio Ezra, Geronimo Nazareth, Ruperto Mayuga, Sr., Robert Schaare, Henry Cariat, Reynaldo Ferrenal, and John Does—to disaffiliate from UCCP and continue using the name “BUCCI.” BUCCI, originally Bradford Memorial Church founded early in the 20th century and incorporated on December 14, 1979, had been a constituent local church of UCCP under a congregationalist system that respected local autonomy. Conflict arose in late 1989 when BUCCI erected a fence encroaching on UCCP-allocated right-of-way in Cebu. Foll Case Digest (G.R. No. 171905) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and corporate identities
- Petitioner: United Church of Christ in the Philippines, Inc. (UCCP), a national confederation of evangelical churches incorporated in 1949.
- Respondents: Bradford United Church of Christ, Inc. (BUCCI), a separate Protestant congregation incorporated on December 14, 1979, and its individual members (Ezra, Nazareth, Mayuga, Schaare, Cariat, Ferrenal, et al.).
- Historical background and union
- Early 20th-century missionary activity led to the Evangelical Union (1901), precursor to the National Council of Churches.
- Formation of the United Evangelical Church in 1929 from Presbyterian and Congregational bodies.
- On May 25, 1948, the Evangelical Church, Philippine Methodist Church, and United Evangelical Church federated to form UCCP; registered April 12, 1949.
- Bradford Memorial Church transferred its synodical connection to UCCP, later registering as BUCCI in 1979.
- Governance dispute and disaffiliation
- UCCP’s three governing bodies: General Assembly, Conference, Local Church; BUCCI belonged to the Cebu Conference.
- Late 1989 dispute when BUCCI built an encroaching fence; Cebu Conference Judicial Commission ruled for CCI on April 7, 1990.
- Series of retaliatory actions: stripping of pastoral authority, unlawful detainer suit by UCCP/CCI, labor suit by Ezra.
- Church Council Resolution dated June 21, 1992 retroactively disaffiliated BUCCI effective September 16, 1990; ratified by referendum July 19, 1992.
- BUCCI amended its Articles of Incorporation and By-Laws to reflect disaffiliation; SEC approved amendments on July 2, 1993.
- Procedural history
- UCCP filed SEC Case No. C-00194 challenging (a) validity of disaffiliation, (b) amendments to BUCCI’s charter, and (c) BUCCI’s continued use of its name.
- SEC en banc dismissed UCCP’s petition on January 27, 2004, upholding BUCCI’s disaffiliation rights and name usage.
- UCCP appealed to the Court of Appeals; decision dated June 17, 2005 affirmed SEC’s ruling; motion for reconsideration denied February 21, 2006.
- UCCP filed the present petition for review under Rule 45, 1997 Rules of Civil Procedure.
Issues:
- Whether BUCCI’s disaffiliation from UCCP is valid or appeals to purely ecclesiastical jurisdiction.
- Whether amendments to BUCCI’s Articles of Incorporation and By-Laws comply with the Corporation Code.
- Whether BUCCI may continue using its corporate name without confusing similarity to UCCP.
- Whether UCCP has locus standi to challenge BUCCI’s corporate acts.
- Whether UCCP complied with the mandatory requirements of Rule 45 in this petition.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)