Case Summary (G.R. No. L-21812)
Petitioner
Santiago A. Fonacier, defending his status as legitimate Obispo Maximo and resisting demands to render an accounting or surrender church properties.
Respondents
The Iglesia Filipina Independiente (through Supreme Bishop Gerardo M. Bayaca) and Bishop Isabelo de los Reyes Jr., asserting their legitimate leadership and entitlement to church assets.
Key Dates
• October 14, 1940 – Fonacier elected Obispo Maximo.
• December 16, 1941 & September 1, 1945 – Extensions of Fonacier’s term due to World War II.
• September 2, 1945 – Supreme Council meeting triggering initial conflict.
• October 8 & 16, 1945 – Fonacier’s decrees of expulsion against Aguilar and Remollino.
• January 21–22, 1946 – Supreme Council and Asamblea Magna convened charges against Fonacier, forced his resignation, and elected Bayaca.
• September 1, 1946 – Asamblea Magna of Bayaca’s faction elected de los Reyes as Obispo Maximo; Fonacier’s group elected Jamias.
• February 9, 1946 – Original complaint filed; subsequent appeals up to Supreme Court decision in 1955.
Applicable Law
• 1955 Philippine judicial practice: Civil courts respect factual findings of the Court of Appeals (Rule 46, Sec. 2, Rules of Court).
• Iglesia Filipina Independiente Constitution – Governs election, term, discipline, and appellate ecclesiastical process (Curia de Apelaciones; Supreme Council approval; right to notice and hearing).
• American jurisprudence on church property disputes – Civil courts may examine jurisdiction and procedural fairness of ecclesiastical decrees when civil or property rights are implicated.
• Corporation Law (Articles 154–164) – Registration of “corporation sole” for church temporalities.
Factual Background
- Upon Aglipay’s death, Fonacier became Obispo Maximo in 1940; wartime conditions delayed the mandated 1943 successor election.
- Post-liberation attempts to convene Asamblea Magna failed quorum; Fonacier’s term extended to September 1946.
- In September 1945, disagreements over episcopal assignments prompted Fonacier to expel two bishops without constitutionally required notice, hearing, or Curia opinion.
- December 1945–January 1946, Aguilar filed formal charges; Supreme Council and Asamblea Magna convicted and forced Fonacier’s resignation, electing Bayaca.
- Fonacier refused to surrender church assets, convened a rival council, expelled Bayaca and others, and elected Jamias.
- De los Reyes’s faction grew numerically and obtained civil recognition for administrative purposes; Fonacier’s group sought licenses to solemnize marriages.
Procedural History
• Trial Court (Court of First Instance of Manila) declared de los Reyes sole legitimate Supreme Bishop and ordered Fonacier to account and deliver church properties.
• Court of Appeals affirmed in toto, finding law and evidence supported the ouster of Fonacier, invalidating his expulsions of Aguilar/Remollino, and confirming de los Reyes’s and Bayaca’s authority.
• Supreme Court review limited to questions of law; findings of fact by Court of Appeals are conclusive.
Issues
- Validity of Fonacier’s expulsion of Aguilar and Remollino.
- Legality of charges, proceedings, quorum, and forced resignation of Fonacier.
- Legitimacy of subsequent elections of Bayaca, de los Reyes, and Jamias.
- Civil courts’ jurisdiction over ecclesiastical decisions.
- Impact of later doctrinal amendments and consecrations by the Protestant Episcopal Church on IFI membership and property rights.
Analysis
• Civil-court review is confined to legal questions; factual findings on quorums and member status stand.
• Fonacier’s unilateral ouster of Aguilar and Remollino violated IFI constitution: no notice, hearing, Curia de Apelaciones opinion, or Supreme Council action—thus null and void.
• Charges against Fonacier were properly filed by the President of the Supreme Council; adequate notice and hearing were afforded in council (seven of 13 bishops constituted a quorum) and in the Asamblea Magna (31 delegates exceeded the 25-member quorum).
• Forced resignation of Fonacier and election of Bayaca were consistent with constitutional provisions on discipline and succession.
• Election of de los Reyes by Bayaca’s legitimately convened Asamblea Magna was valid; election of Jamias by Fonacier’s rump assembly
Case Syllabus (G.R. No. L-21812)
Background of the Dispute
- Iglesia Filipina Independiente (IFI), through its Supreme Bishop Gerardo M. Bayaca, sued Bishop Santiago A. Fonacier for accounting and recovery of temporal church properties.
- Fonacier, initially elected Obispo Máximo in 1940, was alleged to have ceased as Supreme Bishop and held church assets improperly.
- After Bayaca’s election, Isabelo de los Reyes, Jr. was later elected Supreme Bishop and added as co-plaintiff.
Pleadings and Defenses
- Petitioners sought Fonacier’s accounting from the time he became Secretario de Economía Temporal.
- Fonacier’s defenses:
- He was never validly removed; his successor was Juan Jamias.
- He already rendered an accounting to Jamias and turned over all properties.
- De los Reyes, Jr. had joined the Protestant Episcopal Church (USA) and ceased to be IFI member.
- Bayaca and De los Reyes, Jr. abandoned IFI’s faith, doctrines, practices, losing capacity to sue.
Court of First Instance Decision (May 17, 1950)
- Declared Isabelo de los Reyes, Jr. as sole and legitimate Supreme Bishop.
- Ordered Fonacier to account for all properties from his tenure as Secretario de Economía Temporal to present.
Court of Appeals Affirmation
- Found findings and judgment of the trial court “in accordance with law and evidence.”
- Affirmed in toto the dismissal of Fonacier’s defenses and his obligation to account and surrender properties.
Supreme Court Petition for Review
- Fonacier appealed to the Supreme Court raising twelve assignments of error.
- Key procedural rule: only questions of law may be reviewed; factual findings of the Court of Appeals are conclusive.
Standard of Review on Certiorari
- Under Rule 46, Sec. 2, only legal questions are open on certiorari.
- Facts as found by the Court of Appeals may not be disturbed by the Supreme Court.
Restatement of Facts by the Supreme Court
- Fonacier elected Obispo Máximo upon Aglipay’s death (Oct. 14, 1940).
- Wartime hold-over arrangements for IFI leadership until proper Asamblea Magna post-war.
- September 2, 1945: Consejo Supremo assigns bishops; conflict over Remollino’s Cavite appointment led to expulsion decrees against Remollino and Aguilar (Oct. 1945).
- January 21–22, 1946: Charges by Aguilar led Supreme Council and Asamblea Magna to force Fonacier’s resignation and elect Bayaca.
- September 1, 1946: Faction under De los Reyes, Jr. elected him Obispo Máximo; Fonacier group elected Jamias, producing two rival IFI factions.
- Public instruction recognized De los Reyes, Jr. for administrative per