Case Summary (G.R. No. 224521)
Petitioner
- Bishop Shinji Amari of Abiko Baptist Church, represented by Shinji Amari
- Missionary Baptist Institute and Seminary, represented by Joel P. Nepomuceno
Respondent
- Ricardo R. Villaflor Jr.
Key Dates
- November 24, 2011: Letter notifying Villaflor of removal as missionary, cancellation of church membership and recommendation
- September 10, 2012: Complaint for illegal dismissal filed before NLRC
- February 12, 2013: Labor Arbiter decision in favor of Villaflor
- July 15, 2013: NLRC decision dismissing complaint for lack of jurisdiction
- October 27, 2015: Court of Appeals decision reinstating Labor Arbiter ruling
- February 17, 2020: Supreme Court decision
Applicable Law
- 1987 Philippine Constitution (Art. III, Sec. 5 – separation of Church and State)
- Labor Code provisions on illegal dismissal
Background of the Dispute
Villaflor served as a missionary of Abiko Baptist Church (sponsored in 1999) and as an instructor at the Seminary (appointed June 1999). In a November 24, 2011 letter, petitioners removed him as missionary, revoked his national missionary recommendation, and excluded him from church membership. They also demanded he vacate church-owned property. Villaflor challenged his removal as illegal dismissal for lack of due process and cause.
Labor Arbiter Decision
The Arbiter found an employer-employee relationship based on Villaflor’s Appointment Paper as seminary instructor, deeming his missionary status incidental. It ruled his removal illegal, ordering backwages, separation pay, damages, and attorney’s fees.
NLRC Ruling
The NLRC held it lacked jurisdiction, treating Villaflor’s dispute as a purely ecclesiastical affair (exclusion from church membership), not subject to civil remedy, and dismissed the complaint.
Court of Appeals Ruling
The CA reversed the NLRC, reinstating the Arbiter’s decision. It distinguished secular employment termination from ecclesiastical exclusion, found separate secular and religious incidents in the removal letter, and applied the four-fold test (selection, payment, control, dismissal) to conclude Villaflor was an employee of both church and seminary. It held no valid cause for termination.
Issue on Jurisdiction and Employment Relationship
Whether Villaflor’s removal as missionary—an ecclesiastical act—falls outside labor jurisdiction absent proof of an employer-employee relationship with petitioners.
Supreme Court Analysis on Ecclesiastical vs Secular Matter
Under the 1987 Constitution’s separation of Church and State and free-exercise clause, civil courts must abstain from “purely ecclesiastical affairs” (doctrine, worship, governance, membership). Termination of employment is ordinarily secular. Three acts in the removal letter were classified:
- Removal as missionary (to be examined)
- Cancellation of recommendation (ecclesiastical)
- Exclusion from membership (ecclesiastical)
Supreme Court Findings on Employer-Employee Relationship
Re-examining evidence under the four-fold test, the Court found:
- Selection/Engagement: Appointment Paper concerned seminary instructor role, not missionary position. Missionary status arose from a separate Mission Policy Agreement.
- Payment of Wages: Alleged “love gifts” came from American Baptist Association and church in
Case Syllabus (G.R. No. 224521)
Antecedents
- On November 24, 2011, Abiko Baptist Church (ABC) informed Ricardo R. Villaflor, Jr. (respondent) by letter of three acts: removal as church missionary, cancellation of his American Baptist Association (ABA) recommendation, and exclusion from church membership.
- Respondent claimed illegal dismissal without due process or valid cause after he refused to sign a resignation and to vacate church property where he had constructed his house and church building.
- Respondent filed a Complaint for Illegal Dismissal before the National Labor Relations Commission (NLRC) on September 10, 2012.
- Petitioners explained that respondent had been a missionary of ABC since 1999, and from June 1999 served as a volunteer instructor at Missionary Baptist Institute and Seminary (MBIS).
- In school year 2006–2007, respondent told church leadership he could no longer teach at MBIS due to distance; his teaching appointment was thereafter cancelled.
- ABC alleged respondent defied orders to transfer to other mission areas, built a personal house on ABC land without consent, and refused to vacate when asked—leading to the November 24, 2011 letter and demand to vacate, with an offer to buy the house materials.
Procedural History
- Labor Arbiter (LA): February 12, 2013 Decision found illegal dismissal; awarded backwages, separation pay, 13th-month pay, moral and exemplary damages, and attorney’s fees.
- NLRC: July 15, 2013 Decision and September 30, 2013 Resolution reversed the LA for lack of jurisdiction, treating the dispute as ecclesiastical.
- Court of Appeals (CA): October 27, 2015 Decision and April 26, 2016 Resolution set aside the NLRC, reinstated the LA, and ordered recomputation of awards from the CA decision’s finality.
- Supreme Court: Petitioners filed a petition for certiorari under Rule 45 to reverse the CA.
Labor Arbiter’s Ruling
- Held it had jurisdiction over respondent’s illegal dismissal claim, treating his MBIS instructor appointment as the basis of employment.
- Found the November 24, 2011 letter to be an illicit termination of a regular employee without just cause.
- Ordered payment of backwages, separation pay, 13th-month pay, moral a