AUSTRIA vs NLRC

FACTS: Private Respondent Central Philippine Union Mission Corporation of the Seventh-Day Adventists
is a religious corporation. Petitioner, on the other hand, was a Pastor of the SDA until ! "cto#er !$$!,
when his services were ter%inated. Pastor Dionisio &. Austria wor'ed with the SDA for twenty eight ()*+
years. ,e #egan his wor' with the SDA on !- .uly !$/ as a literature evangelist. 0ro% then on,
petitioner wor'ed his way up the ladder and got pro%oted several ti%es. "n !/ "cto#er !$$!, at around
123 a.%., petitioner went to the office of Pastor 4uhat, the president of the 5egros Mission. During said
call, petitioner tried to persuade Pastor 4uhat to convene the 67ecutive Co%%ittee for the purpose of
settling the dispute #etween hi% and the private respondent, Pastor David Rodrigo. 8hen news reached
petitioner that Pastor Rodrigo was a#out to file a co%plaint against hi% with the 5egros Mission, he
i%%ediately proceeded to the office of Pastor 4uhat on the date a#ove%entioned and as'ed the latter to
convene the 67ecutive Co%%ittee. Pastor 4uhat denied the re9uest of petitioner since so%e co%%ittee
%e%#ers were out of town and there was no quorum. :hereafter, the two e7changed heated argu%ents.
A fact-finding co%%ittee was created to investigate petitioner. Su#se9uently, on )$ "cto#er !$$!,
petitioner received a letter of dis%issal
!3
citing %isappropriation of deno%inational funds, willful #reach of
trust, serious %isconduct, gross and ha#itual neglect of duties, and co%%ission of an offense against the
person of e%ployer;s duly authori<ed representative, as grounds for the ter%ination of his services.
Reacting against the adverse decision of the SDA, petitioner filed a co%plaint
!!
on != 5ove%#er !$$!,
#efore the >a#or Ar#iter for illegal dis%issal against the SDA and its officers and prayed for reinstate%ent
with #ac'wages and #enefits, %oral and e7e%plary da%ages and other la#or law #enefits. >a#or Ar#iter
Cesar D. Side?o rendered a decision in favor of petitioner. :he SDA, through its officers, appealed the
decision of the >a#or Ar#iter to the 5ational >a#or >a#or Relations Co%%ission which vacated the
findings of the >a#or Ar#iter. Petitioner filed a %otion for reconsideration of the a#ove-na%ed decision.
5>RC issued a Resolution reversing its original decision. @n view of the reversal of the original decision of
the 5>RC, the SDA filed a %otion for reconsideration of the a#ove resolution. 5ota#le in the %otion for
reconsideration filed #y private respondents is their invocation that the >a#or Ar#iter has no Aurisdiction
over the co%plaint filed #y petitioner due to the constitutional provision on the separation of church and
state since the case allegedly involved an ecclesiastical affair to which the State cannot interfere. :he
5>RC, without ruling on the %erits of the case, reversed itself once again, sustained the argu%ent posed
#y private respondents and, accordingly, dis%issed the co%plaint of petitioner. ,ence, the recourse to
this Court #y petitioner.
ISSUE: )+ 8hether or not the ter%ination of the services of petitioner is an ecclesiastical affair, and, as
such, involves the separation of church and state
HELD: :he principle of separation of church and state finds no application in this case. :he case at #ar
does not concern an ecclesiastical or purely religious affair as to #ar the State fro% ta'ing cogni<ance of
the sa%e. 4ased on this definition, an ecclesiastical affair involves the relationship #etween the church
and its %e%#ers and relate to %atters of faith, religious doctrines, worship and governance of the
congregation. 8hile the %atter at hand relates to the church and its religious %inister it does not ipso
facto give the case a religious significance. Si%ply stated, what is involved here is the relationship of the
church as an e%ployer and the %inister as an e%ployee. @t is purely secular and has no relation
whatsoever with the practice of faith, worship or doctrines of the church. @n this case, petitioner was not
e7-co%%unicated or e7pelled fro% the %e%#ership of the SDA #ut was ter%inated fro% e%ploy%ent.
@ndeed, the %atter of ter%inating an e%ployee, which is purely secular in nature, is different fro% the
ecclesiastical act of e7pelling a %e%#er fro% the religious congregation. 0ro% all of these it is clear that
when the SDA ter%inated the services of petitioner, it was %erely e7ercising its %anage%ent prerogative
to fire an e%ployee which it #elieves to #e unfit for the Ao#. As such, the State, through the >a#or Ar#iter
and the 5>RC, has the right to ta'e cogni<ance of the case and to deter%ine whether the SDA, as
e%ployer, rightfully e7ercised its %anage%ent prerogative to dis%iss an e%ployee. :his is in consonance
with the %andate of the Constitution to afford full protection to la#or.