Case Summary (G.R. No. 144801)
Factual Antecedents
Petitioners repeatedly requested the transfer of Fr. Florano on grounds of political animus, but Bishop de la Cruz found no canonical basis. Undeterred, Taruc arranged an open Mass on June 19, 1993, celebrated by an external cleric, Fr. Renato Z. Ambong, despite warnings that Ambong lacked diocesan credentials. Hostility between factions intensified, prompting the Bishop to threaten disciplinary measures.
Ecclesiastical Discipline and Excommunication
On June 28, 1993, Bishop de la Cruz issued an expulsion/excommunication decree against the ten petitioners for (1) disobedience to church authority; (2) inciting dissension by holding an open Mass; and (3) threatening to occupy the parish church. Petitioners sought reconsideration from the Obispo Máximo, who declined to overturn the diocesan decision, and the new bishop, Rhee M. Timbang, likewise refused to transfer Fr. Florano.
Procedural History
Petitioners filed a civil complaint for damages with a preliminary injunction before the Regional Trial Court (RTC) of Surigao City, naming the Bishop, Fr. Florano and Bordas. The RTC denied respondents’ motion to dismiss for lack of jurisdiction. On appeal, the Court of Appeals reversed and dismissed the action, holding that ecclesiastical expulsions fall outside civil jurisdiction absent a property or civil right dispute. The Supreme Court granted review via Rule 45.
Issue
Whether civil courts have jurisdiction to entertain a suit challenging the expulsion or excommunication of members by a religious organization.
Applicable Law
Under Article III, Section 5 of the 1987 Constitution, no law shall prohibit the free exercise of religion or allow state interference in ecclesiastical matters. Judicial precedents—Gonzales v. R. Archbishop (1928), Fonacier v. Court of Appeals (1955), and the U.S. watershed case Watson v. Jones—establish that doctrinal and disciplinary controversies are nonjusticiable.
Court’s Analysis
The Supreme Court reaffirmed the doctrine of church–state separation: ecclesiastical decisions on membership and discipline are exclusive internal matters.
...continue readingCase Syllabus (G.R. No. 144801)
Facts and Antecedents
- Petitioners were lay members of the Philippine Independent Church (PIC) in Socorro, Surigao del Norte, led by Dominador Taruc.
- Respondent Porfirio de la Cruz was Bishop, and Rustom Florano parish priest, of the same PIC parish.
- Petitioners demanded the transfer of Fr. Florano; Bishop de la Cruz denied the request, finding no sufficient reason.
- Political animosity arose because Fr. Florano’s wife belonged to a party opposed to Taruc’s faction.
- Petitioners arranged an open Mass on June 19, 1993, to be celebrated by Fr. Renato Z. Ambong, whose clerical credentials the Bishop doubted.
- Bishop de la Cruz repeatedly warned petitioners against acts “inimical and prejudicial” to PIC and advised them to appeal to higher church authorities.
- Petitioners proceeded with the open Mass despite warnings; on June 28, 1993, Bishop de la Cruz issued an expulsion/excommunication order against petitioners for:
• Disobedience to church authority
• Inciting dissension and division by holding the open Mass
• Threatening to forcibly occupy the parish church
Intermediate Church Proceedings
- Petitioners sought reconsideration from the Obispo Maximo, who suggested Fr. Florano step down but declined to override the Bishop’s diocesan decision.
- Bishop de la Cruz was later reassigned and succeeded by Bishop Rhee M. Timbang, who also refused to transfer Fr. Florano.
- Petitioners continued to hold religious activities under Fr. Ambong despite