UCCP v.

Bradford
674 SCRA 92 | June 20, 2012
PEREZ. J.

Doctrine: UCCP and BUCCI, being corporate entities and grantees of primary franchises, are
subject to the jurisdiction of the SEC in matters that are legal and corporate. The Supreme Court
owes recognition to BUCCI’s decision as it concerns its legal right as a religious corporation to
disaffiliate from another religious corporation via legitimate means is a secular matter well within
the civil courts’ purview.

FACTS

United Church of Christ in the Philippines, Inc. is a religious corporation duly organized
under the laws of the Philippines. It is a confederation of incorporated and unincorporated self-
governing Evangelical churches of different denominations, devised for fellowship, mutual
counsel and cooperation. On the other hand, Bradford United Church of Christ, Inc. is likewise a
religious corporation with a personality separate and distinct from UCCP. Private respondents are
members of BUCCI. UCCP has three governing bodies: General Assembly, Conference, and Local
Churches. BUCCI belonged to the Cebu Conference Inc. (CCI) and enjoyed a peaceful co-
existence until late 1989 when BUCCI constructed a fence that encroached upon the right of way
allocated by UCCP for CCI.

The General Assembly attempted to settle the dispute and rendered a decision in favor of
CCI. This triggered a series of events, which further increased enmity and led to the formal break-
up of BUCCI from UCCP. Consequently, BUCCI filed its Amended Article of Incorporation and
By-Laws, which provided for and affected its disaffiliation from UCCP. SEC approved the same.
UCCP filed a complaint before SEC to reject the same but SEC dismissed UCCP’s petition. CA
affirmed SEC, hence, this petition for review on certiorari.

ISSUES AND HOLDING

1. Whether or not the separation of BUCCI and UCCP is valid. Yes

The Securities and Exchange Commission defended the right of BUCCI to disassociate
itself from UCCP in recognition of its constitutional freedom to associate and disassociate. SEC
also pointed out that since UCCP used the fact of BUCCI’s disaffiliation to consolidate its claim
over the property subject of unlawful detainer case against BUCCI before the RTC, UCCP cannot
now deny the validity of said disaffiliation. The Supreme Court ruled that the matter at hand is not
purely an ecclesiastical affair. BUCCI has the power under the law to effect disaffiliation such that
it should be given legal consequence and granted recognition.

UCCP and BUCCI, being corporate entities and grantees of primary franchises, are subject
to the jurisdiction of the SEC in matters that are legal and corporate. The Supreme Court owes
recognition to BUCCI’s decision as it concerns its legal right as a religious corporation to
disaffiliate from another religious corporation via legitimate means is a secular matter well within
the civil courts’ purview.

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 SEC also found that UCCP is not the real party in interest to question the amendments
made by BUCCI to its Articles of Incorporation and By-Laws. UCCP’s control an authority over
its local churches is not full and supreme; memberships of the local churches in the UCCP is
voluntary and not perpetual; local churches enjoy independence and autonomy and may maintain
or continue church-life with or without UCCP. Under the law and UCCP polity, BUCCI may
validly bring about its disaffiliation from UCCP through the amendment of its Articles of
Incorporation and By-Laws. SEC approved the amendments, which approval has in its favor the
presumption of regularity. The Supreme Court is not a trier of facts. Moreover, UCCP, not being
a member of BUCCI, has no locus standi to question the amendments.

SEC upheld the right of BUCCI to continue using its corporate name. The Court of Appeals
also ruled that BUCCI’s history show that it has a better right to use its corporate name on the
ground of priority of adoption. It has acquired the right to make use of its corporate name. It also
held that it is not confusing or deceptively similar to UCCP as to mislead a person of ordinary care
and discrimination. The Supreme Court sustained the said rulings.

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