Long v. Basa
REITERATIONFacts
The Antecedents: The Church In Quezon City (CHURCH), a religious corporation, was organized in 1973. Its Articles of Incorporation and By-laws mandate adherence to its Principles of Faith and vest upon its Board of Directors the power to admit and expel members. Article VII, paragraph 4 of the By-laws allows the Board to expel a member by resolution without assigning any reason if their conduct is dishonorable, improper, or injurious to the institution, or if they fail to observe its regulations. Procedural History: Since 1988, the Board observed that certain members, including petitioners, introduced doctrines not based on the Holy Bible and the CHURCH's Principles of Faith. Despite repeated warnings and exhortations from 1988 onwards, petitioners persisted. On August 30, 1993, the Board, during a regular meeting, removed petitioners from the membership list for espousing doctrines inimical to the CHURCH's Principles of Faith. A resolution was adopted approving an updated membership list, superseding all previous lists. Petitioners questioned their expulsion before the SEC, alleging lack of prior notice and hearing. SEC Hearing Officer Perea denied their prayer for a preliminary injunction, ruling that the expulsion was in accordance with the By-laws, as the notice referred to was to the Board, not the erring members, and no reason was required. The SEC en banc affirmed this ruling in SEC EB Case No. 389 on July 11, 1994. Petitioners did not appeal this decision. Subsequently, further proceedings were held regarding counterclaims and third-party complaints. In SEC EB Case No. 484, the SEC en banc, on July 31, 1996, reversed its earlier decision and ordered the reinstatement of the expelled members, declaring the expulsion void. Respondents appealed this order to the Court of Appeals. The Petition: The Court of Appeals reversed the SEC en banc's July 31, 1996 order, upholding the expulsion. Petitioners then filed consolidated petitions for review by certiorari before the Supreme Court.
Issue(s)
Whether the expulsion of petitioners from the CHURCH was void for lack of prior notice and hearing. Whether the SEC en banc in SEC EB Case No. 484 could validly reverse its prior final and executory decision in SEC EB Case No. 389.
Ruling
The Supreme Court denied the petitions, affirming the decision of the Court of Appeals. The expulsion of the petitioners from the CHURCH was upheld, and the SEC en banc's order dated July 31, 1996, was declared void. The Special Order dated December 18, 1998, enjoining respondents from enforcing the Court of Appeals' decision, was lifted.
Ratio Decidendi
On the issue of whether the expulsion was void for lack of prior notice and hearing: The Court ruled against the petitioners. It emphasized that the By-laws of the CHURCH, to which members expressly adhered, did not require prior notice to erring members in cases of expulsion. Article VII, paragraph 4 of the By-laws allowed the Board of Directors to expel a member by resolution without assigning any reason, provided it was brought to the Board's notice that the member had failed to observe regulations or had engaged in dishonorable or improper conduct injurious to the institution. The Court noted that the nature of a religious corporation is peculiar, based on adherence to common religious beliefs, and that civil courts generally do not interfere in purely ecclesiastical matters. Furthermore, the Court found that even if prior notice were constitutionally required, petitioners had been given more than sufficient notice since 1988 through repeated admonitions, warnings, and discussions regarding their conduct and the doctrines they espoused. This period of approximately five years was deemed adequate for them to contemplate their covenant with the CHURCH. The Court clarified that the testimony of Anthony Sayheeliam, stating no notification of grounds for expulsion or opportunity to defend was given during the August 30, 1993 meeting, was taken out of context and referred to the actions taken on that specific day, not the prior warnings. On the issue of whether the SEC en banc in SEC EB Case No. 484 could validly reverse its prior final and executory decision in SEC EB Case No. 389: The Court held that the SEC en banc's order in SEC EB Case No. 484, which reopened and reversed its final and executory decision in SEC EB Case No. 389, was a gross disregard of the rules and the legal precept of finality of judgments. The Court reiterated the fundamental principle in the justice system that judgments must reach a point of finality to write finis to disputes. The decision in SEC EB Case No. 389 had affirmed the validity of the expulsion proceedings conducted on August 30, 1993, and since petitioners did not appeal it, it became final and binding. The subsequent proceedings in SEC EB Case No. 484, which attempted to re-litigate the same issue, were therefore erroneous. The Court cited Fortich vs. Corona to emphasize that the finality of decisions is not a mere technicality but a matter of substance and merit, protecting the vested rights of the winning party.
Main Doctrine
The expulsion of members from a religious corporation, conducted in accordance with its by-laws, is conclusive upon civil courts, especially when the validity of such expulsion has been previously affirmed by final judgment, and the by-laws do not require prior notice and hearing for expulsion.