Taruc v. De la Cruz
REITERATIONFacts
1. The Antecedents: Petitioners, lay members of the Philippine Independent Church (PIC) in Socorro, Surigao del Norte, sought the transfer of respondent Fr. Rustom Florano due to alleged animosity stemming from political affiliations of Fr. Florano's wife. Bishop Porfirio B. de la Cruz denied this request. The dispute escalated when petitioner Dominador Taruc proceeded with an open mass during the town fiesta, officiated by Fr. Renato Z. Ambong, despite Bishop de la Cruz's dissuasion due to Fr. Ambong's questionable credentials and the potential for dissension within the church. 2. Procedural History: Following the unauthorized mass, Bishop de la Cruz excommunicated the petitioners for disobedience, inciting dissension, and threatening to occupy the church. An appeal to the Obispo Maximo did not result in the reversal of the excommunication, though it was suggested Fr. Florano might step down. Bishop de la Cruz was reassigned and his successor, Bishop Rhee M. Timbang, also denied the petitioners' request for Fr. Florano's transfer. The petitioners then filed a complaint for damages with preliminary injunction against Bishop de la Cruz, Fr. Florano, and Delfin Bordas before the Regional Trial Court (RTC) of Surigao City, alleging illegal expulsion without due process. The RTC denied the respondents' motion to dismiss for lack of jurisdiction. The Court of Appeals (CA) reversed this decision, dismissing the case for lack of jurisdiction, holding that the excommunication was a purely ecclesiastical matter outside the purview of civil courts. 3. The Petition: This case is an appeal under Rule 45 of the Revised Rules of Court, brought by the petitioners who seek to overturn the Court of Appeals' decision. They argue that the courts should have jurisdiction over their case, particularly concerning the alleged violation of their right to due process through illegal expulsion. The core issue presented to the Supreme Court is whether civil courts possess the authority to hear cases involving the expulsion or excommunication of members from a religious institution, with the petitioners implicitly contending that their civil rights were violated by the ecclesiastical action.
Issue(s)
Whether the courts have jurisdiction to hear a case involving the expulsion/excommunication of members of a religious institution. Whether the expulsion/excommunication of the petitioners from the Philippine Independent Church was illegal for violation of due process.
Ruling
The petition is denied for lack of merit. The Supreme Court affirmed the Court of Appeals' decision dismissing the case for lack of jurisdiction.
Ratio Decidendi
On the jurisdiction of courts over expulsion/excommunication from religious institutions: The Supreme Court reiterated the principle of separation of church and state, emphasizing that civil courts must not unduly intrude into matters of an ecclesiastical nature. Citing Section 5, Article III of the 1987 Constitution, the Court affirmed that the free exercise and enjoyment of religious profession and worship shall be allowed. The Court held that the expulsion or excommunication of members from a religious institution is a matter best left to the discretion of the officials and the laws and canons of that institution. It is not for civil courts to exercise control over church authorities in the performance of their discretionary and official functions. Members who unite with an ecclesiastical body do so with an implied consent to submit to the church government. On the alleged violation of due process: The Court noted that the records showed Bishop de la Cruz had repeatedly pleaded with the petitioners not to commit acts inimical to the PIC and warned them of the consequences, including expulsion. Despite these pleas and warnings, the petitioners proceeded with their plans, defying their Bishop and causing dissension. Therefore, the Court found that the petitioners could not claim a violation of due process, as they were aware of the potential repercussions of their actions and chose to proceed, effectively accepting responsibility for the chaos they caused. The Court reiterated the doctrine from Fonacier v. Court of Appeals that matters concerning faith, practice, doctrine, and the power of excluding from the church those deemed unworthy are unquestionably ecclesiastical matters outside the province of civil courts.
Main Doctrine
Civil courts generally do not have jurisdiction over purely ecclesiastical matters, including the expulsion or excommunication of members of a religious institution, unless civil or property rights are involved.