Long vs. Basa

A religious corporation may expel a member without prior notice and hearing if its by-laws so provide, as the basis of membership is absolute adherence to a common religious belief, and civil courts will not interfere in such purely ecclesiastical matters.

In 1973, a religious group known as "The Church In Quezon City (Church Assembly Hall), Incorporated" was organized as a non-stock, non-profit religious corporation and registered with the Securities and Exchange Commission (SEC). Its Articles of Incorporation and By-laws decreed that its affairs be managed by a six-member Board of Directors. As a "brotherhood in Christ," the Church embraced specific Principles of Faith centered on the Holy Bible and the Trinity. To protect these principles, the members vested upon the Board of Directors the absolute power to admit and expel members. Admission was exacting, requiring members to be zealous of the Gospel and of sound knowledge of the Truth. Expulsion was prescribed under Article VII, paragraph 4 of the By-laws, which allowed the Board to expel a member by resolution without assigning any reason if the member's conduct was dishonorable, improper, or injurious to the institution. As early as 1988, the Board observed that certain members, including the petitioners, were introducing doctrines not based on the Holy Bible, such as worshiping Buddha or men. The Board repeatedly warned the erring members during Sunday worships, small group meetings, and one-on-one talks that continuing such conduct would result in their expulsion. The petitioners ignored these admonitions.

• The Church and its By-laws: The Church in Quezon City was registered in 1973 as a non-stock religious corporation. Its By-laws, particularly Article VII (paragraph 4), vested the Board of Directors with the power to expel members by resolution without assigning any reason if a member's conduct was dishonorable, improper, or injurious to the character and interest of the institution.
• The Deviation and Warnings: Since 1988, the Board observed that certain members, including the petitioners, exhibited conduct injurious to the Church by introducing doctrines not based on the Holy Bible and the Principles of Faith, such as worshiping Buddha or men. Respondents, as Board members, repeatedly advised and warned the erring members during Sunday worship gatherings, small group meetings, and one-on-one talks to correct their ways, warning them of potential expulsion.
• The Expulsion: On August 30, 1993, during a regular meeting to review and update the membership list, the Board of Directors passed a resolution removing the names of the erring members, including petitioners Joseph Lim, Liu Yek See, Alfredo Long, and Felix Almeria. The resolution was signed by the four directors constituting the majority, as the two other directors (petitioners Lim Che Boon and Tan Hon Koc) did not appear despite being informed. The updated list was filed with the SEC on September 13, 1993.
• The Contempt Incident: During the pendency of the Supreme Court cases, the Court issued a Special Order allowing petitioners entry into the Church building to participate in worship and religious activities as members. Petitioners filed a petition to cite respondents in contempt for denying them the use of the worship halls for a special conference involving 1,800 college students. Respondents countered that the conference was not a Church activity and the participants were not Church members.

• Due Process: Petitioners insisted that the expulsion was void for having been executed without prior notice to them or a hearing, violating their right to due process.
• Lack of Actual Notice: Petitioners contended that the expelled members were not actually notified and warned of their impending expulsion, citing the testimony of Director Anthony Sayheeliam that they were not notified of the grounds for expulsion or given an opportunity to defend themselves.

• Validity under By-laws: Respondents asserted that the expulsion was in accordance with the Church's By-laws, which did not require the Board of Directors to give prior notice to the erring members or state the reasons for expulsion.
• Finality of Prior Judgment: Respondents argued that the validity of the expulsion had already been resolved with finality by the SEC en banc in SEC EB Case No. 389.
• Sufficient Notice Factually: Respondents maintained that the erring members were given more than sufficient warning of their impending ouster through repeated admonitions since 1988.

• Finality of Judgment: Whether the validity of the expulsion was already settled with finality in a prior SEC proceeding, precluding relitigation of the issue.
• Validity of Expulsion: Whether the expulsion of members from a religious corporation without prior notice and hearing is valid and in accordance with law.
• Scope of TRO: Whether respondents committed contempt by denying petitioners the use of the church premises for a conference involving non-members.

• Finality of Judgment: The validity of the expulsion was conclusively settled in SEC EB Case No. 389, which affirmed Hearing Officer Perea's ruling and became final and executory due to petitioners' failure to appeal. The SEC en banc's subsequent order in SEC EB Case No. 484, which reopened and reversed the final ruling on the expulsion's validity, was a gross disregard of the rules on finality of judgments. The Court of Appeals correctly voided the 1996 SEC order.
• Validity of Expulsion: The expulsion was valid and in accordance with law. Article VII, paragraph 4 of the Church By-laws only requires that the Board of Directors be notified of the member's injurious conduct and that a resolution be passed; it does not require prior notice to the erring member. Membership in a religious corporation is based on absolute adherence to a common religious belief; once this basis ceases, membership must also cease. Civil courts will not interfere in purely ecclesiastical matters such as the expulsion of members for espousing contrary doctrines. Petitioners waived the requirement of prior notice by voluntarily joining the Church and subscribing to its By-laws. Moreover, the factual finding that petitioners were given more than sufficient actual notice through five years of repeated warnings belied the claim of a due process violation.
• Scope of TRO: No contempt was committed. The Special Order allowed petitioners entry to participate in Church activities as members; it did not grant unlimited or unrestrained access to host conferences for non-members.

• Ecclesiastical Abstention Doctrine — In matters purely ecclesiastical, the decisions of the proper church tribunals are conclusive upon the civil courts. A church member expelled by church authorities for espousing doctrines contrary to the faith is without remedy in the civil courts, which will not inquire into the correctness of the ecclesiastical tribunal's decisions.
• Finality of Judgments — Judgments, orders, or resolutions of a judicial or quasi-judicial body must reach a point of finality. The rule on finality is not a question of technicality but of substance and merit, designed to write finis to disputes and protect the vested rights of the winning party.
• Waiver of Notice in Religious Corporations — Members of a religious corporation who voluntarily enter into its covenant and subscribe to its rules are bound by their consent. By adhering to by-laws that do not require prior notice for expulsion, members waive the necessity of such notice.

• "[I]n matters purely ecclesiastical the decisions of the proper church tribunals are conclusive upon the civil tribunals. A church member who is expelled from the membership by the church authorities, or a priest or minister who is by them deprived of his sacred office, is without remedy in the civil courts, which will not inquire into the correctness of the decisions of the ecclesiastical tribunals."
• "The basis of the relationship between a religious corporation and its members is the latter’s absolute adherence to a common religious or spiritual belief. Once this basis ceases, membership in the religious corporation must also cease. Thus, generally, there is no room for dissension in a religious corporation."
• "What due process contemplates is freedom from arbitrariness; what it requires is fairness and justice; substance, rather than the form, being paramount. What it prohibits is not the absence of previous notice but the absolute absence thereof."

• United States vs. Canete, 38 Phil. 253 (1918) — Followed. Established the principle that in purely ecclesiastical matters, the decisions of church tribunals are conclusive upon civil courts, and expelled members have no remedy in the civil courts.
• Fortich vs. Corona, 289 SCRA 624 (1998) — Followed. Cited for the doctrine that the rule on finality of decisions is a fundamental principle in the justice system, constituting a matter of substance rather than technicality, aimed at protecting the vested rights of the prevailing party.
• Lions Club International vs. Amores, 121 SCRA 621 (1983) — Discussed in dissent. Recognized exceptions to the rule of non-interference in the internal affairs of associations, such as when proceedings violate the laws of the society or the law of the land, or deprive a person of due process.

• Section 91, Corporation Code — Provides that membership shall be terminated in the manner and for the causes provided in the articles of incorporation or the by-laws, and that termination extinguishes all rights of a member in the corporation or its property. Applied to affirm that the Church's by-laws governed the expulsion of its members.
• Second Paragraph, Section 109, Corporation Code — Makes the provisions on non-stock corporations (including Section 91) explicitly applicable to religious corporations.
• Article VII, Paragraph 4, Church By-laws — Prescribed the procedure for expulsion, allowing the Board of Directors to expel a member by resolution without assigning any reason if the member's conduct was injurious to the institution. Applied to validate the expulsion without prior notice to the erring members.
• Article 19, Civil Code — Cited in the dissent. Requires every person to act with justice, give everyone their due, and observe honesty and good faith, argued as a basis for requiring notice and hearing before expulsion.

Vitug, and Panganiban, JJ.

• Melo, J. — Argued that civil courts can and should interfere in the internal affairs of a religious corporation when the acts complained of contravene the laws of the land or violate the civil and property rights of its members, such as the fundamental right to due process. The dissent highlighted that the Church's own incorporators explained during the 1973 SEC hearing that an erring member would be "given a chance to explain" before expulsion, contradicting the majority's interpretation of the by-laws. It was further contended that the Board meeting where the expulsion was approved was invalid for lack of notice to two directors, violating Section 53 of the Corporation Code, and that the expulsion caused serious emotional and spiritual deprivation to the petitioners.