Saturday, February 7, 2009

FONACIER VS. COURT OF APPEALS [96 PHIL 417; G.R. L-

5917; 28 JAN 1955]

Facts: Case was filed by Iglesia Filipina Independiente

(IFI), represented by its supreme bishop Gerardo Bayaca,
against Bishop Fonacier seeking to render an accounting of
his administration of all the temporal properties and to
recover the same on the ground that he ceased to be the
supreme bishop of IFI. Isabelo De los Reyes Jr. had been
elected as the Supreme Bishop.

Petitioner claims that he was not properly removed as

Supreme Bishop and his legal successor was Juan Jamias.
He claims that the there was an accounting of his
administration and was turned over to bishop Jamias. Also,
that Isabelo De los Reyes and Bayaca have abandoned
their faith and formally joined the Prostestant Episcopal
Church of America.

CFI rendered judgment declaring Isabelo De Los Reyes, Jr.

as the sole and legitimate Supreme Bishop of IFI and
ordered Fonacier to render an accounting of his
admistration

CA affirmed the decision of the CFI

Issue: Whether or not the petitioner should still be

regarded as the legitimate supreme bishop of IFI.
Held: Supreme Court affirmed CA’s decision. The
legitimate Supreme Bishop of IFI is Isabelo De los Reyes,
Jr. The Supreme Court affirms the validity of the election of
Bishop Delos Reyes as the Supreme Bishop based on their
internal laws

To finally dispose of the property issue, the Court, citing

Watson v. Jones,368 declared that the rule in property
controversies within religious congregations strictly
independent of any other superior ecclesiastical association
(such as the Philippine Independent Church) is that the
rules for resolving such controversies should be those of
any voluntary association. If the congregation adopts the
majority rule then the majority should prevail; if it adopts
adherence to duly constituted authorities within the
congregation, then that should be followed