Austria vs.

National Labor Relations Commission

Case

G.R. No. 124382

Ponente

KAPUNAN, J

Decision Date

Aug 16, 1999

Pastor Dionisio V. Austria is illegally dismissed by the Central Philippine Union Mission Corporation of the Seventh-Day
Adventists (SDA) due to allegations of misappropriation of funds, but the court rules in favor of the pastor, stating that the
dismissal lacked valid grounds and violated proper procedures.

Facts:

 Pastor Dionisio V. Austria was illegally dismissed by the Central Philippine Union Mission Corporation of the Seventh-
Day Adventists (SDA).

 The dismissal was due to allegations of misappropriation of funds.

 The case was brought before the National Labor Relations Commission (NLRC), which initially dismissed the case for
lack of jurisdiction, citing the separation of church and state.

 Pastor Austria had worked with the SDA for 28 years before he was terminated.

 Prior to his termination, he was asked to admit accountability for the church offerings collected by his wife, which
amounted to P15,078.10.

 He refused, stating that it was Pastor Buhat and Mr. Ibesate who authorized his wife to collect.

 He requested a meeting with Pastor Buhat to settle a dispute with Pastor Rodrigo, but the request was denied.

 This led to a heated argument between Pastor Austria and Pastor Buhat, during which Pastor Austria banged Pastor
Buhat's attaché case on the table, scattered books, and threw the phone.

 Later, an Executive Committee meeting was held to discuss the non-remittance of church collections and the events
that transpired.

 Subsequently, Pastor Austria received a letter of dismissal citing grounds for termination.

Issue:

 Whether the Labor Arbiter and the NLRC have jurisdiction to decide on the complaint filed by Pastor Austria against
the SDA.

Ruling:

 The dismissal of Pastor Austria was illegal.

 Pastor Austria is entitled to reinstatement with full backwages.

Ratio:

 The case does not concern a purely religious affair and is within the jurisdiction of the labor tribunals.

 The relationship between the church and its minister is purely secular and does not involve matters of faith,
worship, or doctrine.
  The requirement of giving a written notice specifying the grounds for termination and giving the employee a
reasonable opportunity to explain his side was not complied with.

 There was no valid basis for the loss of confidence and breach of trust alleged by the SDA.

 The grounds of serious misconduct, commission of an offense against the person of the employer's representative,
and gross and habitual neglect of duties were unmeritorious and did not warrant dismissal.

 The Labor Arbiter and the NLRC have jurisdiction to decide on employment disputes involving religious corporations,
as long as the dispute is purely secular in nature and does not involve matters of faith, worship, or doctrine.

 Due process in termination cases is important, and the burden of proof is on the employer to show a valid cause for
dismissal.

SUMMARY

Background of the Case

 The case involves the illegal dismissal of Pastor Dionisio V. Austria by the Central Philippine Union Mission
Corporation of the Seventh-Day Adventists (SDA).

 The SDA terminated Pastor Austria's services due to allegations of misappropriation of funds.

Pastor Austria's Employment and Dismissal

 Pastor Austria had worked with the SDA for 28 years before his termination.

 He was asked to admit accountability for the church offerings collected by his wife, but he refused since it was
authorized by Pastor Buhat and Mr. Ibesate.

 Pastor Austria requested a settlement through the Executive Committee, but his request was denied.

 A heated argument between Pastor Austria and Pastor Buhat ensued, during which Pastor Austria displayed
aggressive behavior.

 An Executive Committee meeting was held to discuss the non-remittance of church collections and the events
that transpired.

 Pastor Austria received a letter of dismissal citing grounds for termination.

Legal Proceedings

 Pastor Austria filed a complaint for illegal dismissal, which was initially ruled in his favor by the Labor Arbiter.

 The SDA appealed the decision to the NLRC, which dismissed the case for lack of jurisdiction, claiming it involved
an ecclesiastical affair.

 The court disagreed with the NLRC's ruling, stating that the case involved the relationship between the church as
an employer and the minister as an employee, which is purely secular.

 The court noted that the SDA had fully participated in the proceedings before the Labor Arbiter and the NLRC,
waiving their right to question jurisdiction.

Validity of the Dismissal

 The court found that the SDA failed to comply with the requirement of giving a written notice specifying the
grounds for termination and giving the employee a reasonable opportunity to explain his side.

 The court found no basis for the alleged loss of confidence and breach of trust, as it was Pastor Austria's wife who
collected the money and failed to remit it.
  The grounds of serious misconduct and commission of an offense against the person of the employer's duly
authorized representative were also deemed unmeritorious.

 There was no proof of gross and habitual neglect of duties.

Court's Decision

 The court concluded that Pastor Austria was illegally dismissed.

 Pastor Austria was entitled to reinstatement with full backwages.