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Fonacier v. CA, 96 Phil 417 (1955)
The Iglesia Filipina Independiente (IFI), represented by its Supreme Bishop Gerardo M. Bayaca, filed a case with the Court of First Instance (CFI) of Manila against Bishop Santiago A. Fonacier. The IFI sought to require Bishop Fonacier to render an accounting of his administration of all the temporal properties in his possession belonging to the church and to recover the properties from him. The IFI claimed that Fonacier had ceased to be its Supreme Bishop.
Bishop Isabelo de los Reyes, Jr., having been elected as Supreme Bishop after the filing of the original complaint, was later made a co-plaintiff in a supplementary complaint.
Fonacier claimed in his defense that: (a) he has not been properly removed as Supreme Bishop;(b) his legal successor was Juan Jamias who had been elected in accordance with the church constitution ; (c) Bishop De los Reyes, Jr. formally joined the Protestant Episcopal Church of America and for this reason ceased to be a member of the Iglesia Filipina Independiente; (d) Bishops De los Reyes and Bayaca having abandoned the faith, fundamental doctrines and practices of the Iglesia Filipina Independiente, ceased to be members and consequently, have no personality in filing the complaint.
On May 17, 1950, the court rendered judgment declaring Mons. Isabelo de los Reyes, Jr. as the sole and legitimate Supreme Bishop of the Iglesia Filipina Independiente, and ordering Mons. Fonacier to render an accounting of his administration of the properties and funds of the church. The Court of Appeals affirmed the decision of the CFI. Fonacier then filed a petition for review with the Supreme Court.
Whether The Court of Appeals erred “in holding that the ouster of Bishops Manuel Aguilar, Alejandro Remollino, Isabelo de los Reyes Jr., Gerardo Bayaca, Juan Quijano and Pablo Tablante decreed by the Supreme Council and the petitioner as Obispo Maximo was illegal.
The civil courts have jurisdiction to review the action regarding the ouster.
(A) “Where a decision of an ecclesiastical court plainly violates the law it professes to administer, or is in conflict with the laws of the land, it will not be followed by the civil courts.”
(B) “Expulsion of a member without notice or an opportunity to be heard is not conclusive upon the civil courts when a property right is involved.”
Since it is claimed that the ouster was made by an unauthorized person, or in a manner contrary to the constitution of the church, and that the ousted bishops were not given notice of the charges against them nor were they afforded an opportunity to be heard, the civil courts, have jurisdiction to review the action regarding the ouster.
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