Dominador L.

Taruc, Wilberto Dacera, Nicanor Galanida, Renerio Canta, Jerry Canta, Cordencio Consigna, Susano
Alcala, Leonardo Dizon, Salvador Gelsano And Benito Laugo
vs.
Bishop Porfirio B. De La Cruz, Rev. Fr. Rustom Florano And Delfin Bordas
GR No. 144801, March 10, 2005

FACTS:
The petitioners filed a complaint against the respondents for they contended that their expulsion from the
Philippine Independent Church was illegal because it was done without trial thus violating their right to due
process of law.

The petitioners were lay members of the Philippine Independent Church (PIC), while the respondents were the
bishop and parish priest, respectively, of the same church. The petitioners led by Dominador Taruc, demanded
for the transfer of Fr. Florano to another parish. Because he was linked to his wife’s political group that
petitioner Taruc opposed, being the reason of hostility between two factions. Bishop de la Cruz found no
substantial reason for the transfer, hence, denied their request.

The hostility worsened when petitioner Taruc organized an open mass celebrated by certain Fr. Zambong,
even though the Bishop already dissuade him from carrying out his plans and advised to air their complaints
before the higher authorities of PIC if they believed they had valid grievances against him, the parish priest,
the laws and canons of the PIC.

Bishop de la Cruz declared petitioners expelled/excommunicated from the Philippine Independent Church for
these reasons:

(1) disobedience to duly constituted authority in the Church;

(2) inciting dissension when they celebrated an open Mass at the Plaza; and

(3) for threatening to forcibly occupy the Parish Church causing anxiety and fear among the general
membership.

Consequently, the petitioners filed a complaint before the lower court. The respondent filed a motion to
dismiss the case on the ground of lack of jurisdiction but it was denied. The case was elevated by the
respondent to the Court of Appeals.

ISSUE:
Whether or not the courts have jurisdiction to hear a case involving the expulsion/excommunication of
members of a religious institution.

RULING:
No. The court ruled that it is unnecessary to deal on the validity of the excommunication/expulsion of the
members, said acts being purely ecclesiastical matters which the Court considers to be outside the province of
the civil courts. Civil Courts will not interfere in the internal affairs of a religious organization except for the
protection of civil or property rights. Those rights may be the subject of litigation in a civil court, and the
courts have jurisdiction to determine controverted claims to the title, use, or possession of church property.
The Court is of the opinion and so holds that the instant case does not involve a violation and/or protection of
a civil or property rights in order for the court a quo to acquire jurisdiction in the instant case. 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. In our jurisdiction, the
Court held the Church and the State to be separate and distinct from each other.

Hence, the appellate court reversed the lower court’s decision and ordered for the dismissal of the case for
the lack of merit.