Case Summary (G.R. No. 226908)
Applicable Law
The decision is based on principles found in the 1987 Philippine Constitution, particularly the tenets surrounding the separation of church and state and the jurisdictions of labor relations.
Case Background
Fe P. Benito, a licensed Christian minister, was appointed to various positions within the PCAC, serving without a written contract. In line with the policies of her supervising body, CAMACOP, ministers were expected to submit annual courtesy resignations in the absence of a formal contract. Following the implementation of this policy in PCAC, Benito tendered her resignation as required, but subsequently was not reappointed for another term. Instead, she was invited to apply for other positions due to perceived administrative lapses. Following unsuccessful attempts to seek reinstatement, Benito filed a complaint for illegal dismissal before the Labor Arbiter.
Labor Arbiter's Decision
The Labor Arbiter ruled that an employer-employee relationship existed due to the nature of Benito’s appointment, which included structured oversight from PCAC, regular remuneration, and associated benefits. The Arbiter concluded that Benito had been illegally dismissed, determining that there was no valid justification for her non-reappointment.
NLRC Ruling
The National Labor Relations Commission (NLRC) reversed the Labor Arbiter's decision, concluding that the non-renewal of Benito's appointment stemmed from church policy and thus was an ecclesiastical matter outside the jurisdiction of labor tribunals. The NLRC characterized the issue as one of governance regarding the church community rather than a labor dispute.
Court of Appeals' Findings
On appeal, the Court of Appeals annulled the NLRC's rulings, asserting that the termination of Benito’s engagement was not purely ecclesiastical but rather a severance of an employer-employee relationship. It mandated that the NLRC assess the validity of Benito's dismissal in light of employment law standards.
Supreme Court Review
The Supreme Court's review centered around whether the matter at hand was ecclesiastical, and thus outside the purview of secular labor jurisdictions. The Court reaffirmed that religious organizations possess autonomy over the supervision of their ministers. It emphasized that employment relationships within religious institutions often have dual roles including both spiritual guidance and administrative functions. As such, t
...continue readingCase Syllabus (G.R. No. 226908)
Case Overview
- This case revolves around a Petition for Review on Certiorari filed by the Pasay City Alliance Church (PCAC) and Christian and Missionary Alliance Churches of the Philippines (CAMACOP) seeking to reverse the Court of Appeals' (CA) Decision dated May 13, 2016, and Resolution dated September 8, 2016.
- The CA annulled the Resolutions dated January 12, 2015, and February 27, 2015, of the National Labor Relations Commission (NLRC), which had set aside the Labor Arbiter's ruling for lack of jurisdiction.
Parties Involved
- Petitioners:
- Pasay City Alliance Church (PCAC)
- Christian and Missionary Alliance Churches of the Philippines (CAMACOP)
- Reverend William Cargo
- Respondent:
- Fe P. Benito, a licensed Christian Minister of CAMACOP.
Background Facts
- Fe P. Benito served as the Head of Fellowship and Discipleship at PCAC after completing her degree in Religious Education.
- She was later appointed as the Head of Membership and Evangelism Ministry, later renamed Pastoral Care and Membership, without a formal written contract.
- CAMACOP and PCAC had a policy requiring pastors without written contracts to submit a yearly courtesy resignation.
- Benito tendered her courtesy resignation on January 30, 2011, and was reappointed for another year.
- The CMT decided not to reappoint her in 2012 due to perceived inefficiencies and administrative lapses, although her term was extended temporarily.
- A final decision to uphold the non-renewal of her engagement was communicated to her in December 2013.
Legal Proceedings
- Benito filed a complaint for illegal dismissal, claiming she had attained regular status and was enti