Case Summary (G.R. No. 171905)
Ecclesiastical Affairs Versus Secular Corporate Questions
Matters purely ecclesiastical (doctrine, worship, sacraments, discipline) lie outside civil courts. However, BUCCI’s decision to disaffiliate and amend its charter involves secular corporate rights—legal steps subject to SEC review. Disputes over membership and affiliation in a corporate context are not purely religious.
Validity of BUCCI’s Disaffiliation
Under both UCCP’s 1974 and 2005 Constitutions and its Basis of Union, local churches enjoy autonomy. The power to withdraw from UCCP by amending articles and by-laws is consistent with the congregationalist polity expressly preserved in UCCP’s governing documents.
SEC Approval and Presumption of Regularity
SEC’s July 2, 1993 approval of BUCCI’s amended articles carries a presumption of regularity. Absent clear evidence of procedural defect or grave abuse of discretion, SEC’s factual determinations stand, and the Supreme Court will not substitute its own appraisal.
Right to Continued Use of the Corporate Name
Philippine law prohibits corporate names that are identical, confusingly similar, or deceptive. BUCCI’s long lineage and prior use established priority. The Court of Appeals correctly found no likelihood of confusion between “BUCCI” and “UCCP,” given distinct identities and naming conventions required by UCCP.
Locus Standi of UCCP to Challenge Amendments
A real party in interest must have a material stake in the outcome. Once disaffiliated, UCCP ceased to be a member of BUCCI and thus lacked standing to contest BUCCI’s charter amendments and corporate name usage. SEC and the Court of Appeals properly dismissed UCCP’s protest on standing grounds.
Noncompliance with Rule 45 Requirements
UCCP’s
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Parties and Nature of the Case
- Petitioner: United Church of Christ in the Philippines, Inc. (UCCP), a national confederation of self-governing Evangelical churches, ecclesiastical successor of three major Protestant bodies, organized May 25, 1948 and registered April 12, 1949.
- Respondents:
• Bradford United Church of Christ, Inc. (BUCCI), formerly Bradford Memorial Church, a religious corporation incorporated December 14, 1979 under SEC Reg. No. 90225.
• Individual respondents: Patrizio Ezra, Geronimo Nazareth, Ruperto Mayuga, Sr., Robert Schaare, Henry Cariat, Reynaldo Ferrenal and other John Does—members and officers of BUCCI. - Relief Sought: Annulment of BUCCI’s amended Articles of Incorporation and By-Laws, injunction against use of corporate name, and declaration that BUCCI remains an organic local church under UCCP.
Historical Background of Church Union
- Turn-of-the-century Protestant missions from Methodist, Presbyterian, Disciples, Congregational bodies formed the Evangelical Union in 1901.
- Multiple negotiations led to the 1929 union of Presbyterian, Congregational, United Brethren, and Manila churches as the United Evangelical Church.
- Post-World War II reconstitution split Evangelical Church; Bradford Memorial Church joined United Evangelical Church in Visayas and Mindanao, taking the name Bradford Evangelical Church.
- On May 25, 1948, three bodies (Evangelical Church in Luzon, Philippine Methodist Church, United Evangelical Church in VisMin) adopted a Basis of Union; UCCP was formally organized and registered in 1949.
- Over time, UCCP granted autonomy to local congregations, including BUCCI, under a congregationalist polity and multi-tier governance (General Assembly, Conference, Local Church).
Dispute and Procedural History
- Late 1989: BUCCI constructed a fence encroaching on right-of-way allocated by UCCP to Cebu Conference Inc. (CCI) and Visayas jurisdiction.
- April 7, 1990: Cebu Conference Judicial Commission ruled in favor of CCI; BUCCI disaffiliated by Church Council Resolution dated June 21, 1992, retroactive to September 16, 1990, ratified by referendum July 19,