Taruc vs. De la Cruz

Civil courts have no jurisdiction over the expulsion or excommunication of members of a religious institution, as such matters are purely ecclesiastical in nature and fall outside the province of civil authority, unless civil or property rights are implicated.

Petitioners were lay members of the Philippine Independent Church (PIC) in Socorro, Surigao del Norte. Respondent Bishop Porfirio de la Cruz headed the diocese, and respondent Fr. Rustom Florano served as parish priest. A political rivalry existed between petitioner Taruc's family and Fr. Florano's wife's family, which fueled petitioners' demand for Fr. Florano's transfer. The PIC operates under its own laws and canons, with an internal hierarchy culminating in the Obispo Maximo, to whom members may appeal ecclesiastical decisions.

Petitioners were lay members of the Philippine Independent Church (PIC) in Socorro, Surigao del Norte. Respondent Bishop Porfirio de la Cruz headed the diocese, and respondent Fr. Rustom Florano served as parish priest. Petitioners, led by Dominador Taruc, clamored for the transfer of Fr. Florano to another parish, but Bishop de la Cruz denied the request. The family of Fr. Florano's wife belonged to a political party opposed to that of petitioner Taruc, and Fr. Florano was identified with his wife's political camp. Bishop de la Cruz found this too flimsy a reason for transferring the parish priest.

Hostility among the PIC members worsened when Taruc attempted to organize an open mass to be celebrated by a certain Fr. Renato Z. Ambong during the town fiesta. When Taruc informed Bishop de la Cruz of the plan, the Bishop tried to dissuade him because Fr. Ambong was not a member of the clergy of the diocese of Surigao and his credentials as a parish priest were in doubt. The Bishop also appealed to Taruc to refrain from acts inimical to the best interests of the PIC and advised petitioners to air their grievances before the higher authorities of the church. Despite these pleas and warnings, Taruc and his sympathizers proceeded to hold the open mass with Fr. Ambong as celebrant on June 19, 1993, at around 3:00 p.m.

On June 28, 1993, Bishop de la Cruz declared petitioners expelled and excommunicated from the PIC for three reasons: disobedience to duly constituted church authority; inciting dissension and division in the parish by celebrating an open mass at the plaza on June 19, 1993; and threatening to forcibly occupy the parish church, causing anxiety and fear among the general membership. Petitioners appealed to the Obispo Maximo, who opined that Fr. Florano should step down voluntarily to avert hostility but stated that he would not intervene in the diocesan decision. Bishop de la Cruz was later reassigned and replaced by Bishop Rhee M. Timbang, who likewise found no valid reason to transfer Fr. Florano and issued a circular denying petitioners' persistent clamor. Petitioners nonetheless continued to celebrate mass and hold religious activities through Fr. Ambong, who had been restrained from performing priestly functions in the PIC parish.

Because of the order of expulsion and excommunication, petitioners filed a complaint for damages with preliminary injunction against Bishop de la Cruz before the RTC of Surigao City, impleading Fr. Florano and Delfin Bordas on the theory that they conspired with the Bishop to have petitioners expelled. Petitioners contended that their expulsion was illegal because it was done without trial, thus violating their right to due process.

• Due Process Violation: Petitioners contended that their expulsion from the PIC was illegal because it was done without trial, thereby violating their right to due process of law.
• Conspiracy: Petitioners impleaded Fr. Florano and Delfin Bordas on the theory that they conspired with Bishop de la Cruz to have petitioners expelled and excommunicated from the PIC.
• Jurisdiction of Civil Courts: Petitioners maintained that the civil courts had jurisdiction to hear their complaint for damages arising from their expulsion.

• Lack of Jurisdiction: Respondents filed a motion to dismiss before the lower court on the ground of lack of jurisdiction, arguing that the expulsion/excommunication was a purely ecclesiastical matter outside the province of civil courts.

• Jurisdiction over Ecclesiastical Matters: Whether civil courts have jurisdiction to hear a case involving the expulsion or excommunication of members of a religious institution.

• Jurisdiction over Ecclesiastical Matters: No. Civil courts have no jurisdiction over the expulsion or excommunication of members of a religious institution, such matters being purely ecclesiastical and outside the province of civil authority, absent any violation of civil or property rights.

• Jurisdiction over Ecclesiastical Matters: The Court anchored its ruling on the constitutional principle of separation of Church and State, as embodied in Section 5, Article III of the 1987 Constitution, which prohibits any law respecting an establishment of religion or prohibiting the free exercise thereof. Drawing from the 1928 case of Gonzales vs. R. Archbishop, the Court reiterated that in a government where complete separation of civil and ecclesiastical authority is insisted upon, civil courts must not intrude unduly in matters of an ecclesiastical nature. The expulsion or excommunication of church members is a matter best left to the discretion of church officials and the laws and canons of the institution. All who unite themselves to an ecclesiastical body do so with implied consent to submit to church government and are bound to submit to it. The Court cited Fonacier vs. Court of Appeals for the doctrine that doctrinal and disciplinary differences — including the power of excluding from the church those allegedly unworthy of membership — are unquestionably ecclesiastical matters outside the province of civil courts. As to petitioners' claim of denial of due process, the Court noted that Bishop de la Cruz had pleaded with petitioners several times not to commit acts inimical to the PIC and had warned them of the consequences, including expulsion. These pleas and warnings fell on deaf ears, and petitioners proceeded to defy their Bishop and foment dissension. No civil or property right was violated, and thus the civil courts could not acquire jurisdiction.

• Separation of Church and State — The State is separate and distinct from the Church, and civil courts must not intrude unduly in matters of an ecclesiastical nature. The free exercise and enjoyment of religious profession and worship, without discrimination or preference, shall forever be allowed under Section 5, Article III of the 1987 Constitution. The Court applied this doctrine to hold that the expulsion or excommunication of church members is a purely ecclesiastical matter beyond the jurisdiction of civil courts.
• Ecclesiastical Matters Doctrine — In disputes involving religious institutions or organizations, doctrinal and disciplinary differences — including the power of excluding from the church those allegedly unworthy of membership — are ecclesiastical matters outside the province of civil courts. Civil courts will not interfere in the internal affairs of a religious organization except for the protection of civil or property rights. The Court applied this doctrine to affirm that petitioners' expulsion from the PIC involved no violation of a civil or property right, precluding civil court jurisdiction.
• Implied Consent to Church Government — All who unite themselves to an ecclesiastical body do so with implied consent to submit to the Church government and are bound to submit to it. The Court relied on this principle to hold that petitioners, as lay members of the PIC, were bound to conform to the church's laws and canons, including the bishop's disciplinary authority.

• "in a form of government where the complete separation of civil and ecclesiastical authority is insisted upon, the civil courts must not allow themselves to intrude unduly in matters of an ecclesiastical nature." — This passage, quoted from Gonzales vs. R. Archbishop (1928), articulates the foundational principle limiting civil court jurisdiction over ecclesiastical affairs and serves as the doctrinal anchor for the ruling.
• "The amendments of the constitution, restatement of articles of religion and abandonment of faith or abjuration alleged by appellant, having to do with faith, practice, doctrine, form of worship, ecclesiastical law, custom and rule of a church and having reference to the power of excluding from the church those allegedly unworthy of membership, are unquestionably ecclesiastical matters which are outside the province of the civil courts." — This passage from Fonacier vs. Court of Appeals defines the scope of ecclesiastical matters and is the canonical formulation of the doctrine that disciplinary actions such as expulsion fall outside civil court jurisdiction.
• "Civil Courts will not interfere in the internal affairs of a religious organization except for the protection of civil or property rights." — This formulation, adopted by the Court of Appeals and affirmed by the Supreme Court, establishes the exception to the rule of non-interference: civil courts may intervene only when civil or property rights are at stake.

• Gonzales vs. R. Archbishop, 51 Phil. 420 (1928) — Leading early case establishing that civil courts must not intrude unduly in ecclesiastical matters in a system of complete separation of civil and ecclesiastical authority. Followed and quoted as the doctrinal foundation for the ruling.
• Fonacier vs. Court of Appeals, 96 Phil. 417 (1955) — Leading case enunciating the doctrine that doctrinal and disciplinary differences, including the power to exclude unworthy members, are ecclesiastical matters outside the province of civil courts. Followed and quoted extensively.
• Watson vs. Jones, 13 Wall. 679 (U.S.) — American case quoted for the principle that those who unite with an ecclesiastical body impliedly consent to submit to its government. Cited as supporting authority through Gonzales.

• Section 5, Article III, 1987 Constitution — Provides that no law shall be made respecting an establishment of religion or prohibiting the free exercise thereof, and that the free exercise and enjoyment of religious profession and worship shall forever be allowed. The Court relied on this provision as the constitutional basis for the separation of Church and State and the consequent lack of civil court jurisdiction over ecclesiastical matters.

Panganiban (Chairman) and Sandoval-Gutierrez, JJ., concurred. Carpio-Morales, J., was on leave. Garcia, J., took no part.