Constitutional Law 1

Case: PASAY CITY ALLIANCE CHURCH/CAMACOP/REV. WILLIAM CARGO, PETITIONERS, VS.

FE BENITO, RESPONDENT | G.R. No. 226908, November 28, 2019
Digested by: Rizzie P. Soliman

Recit-Ready Doctrine (Simplified Take Away):

Summary of the Case:

This case involves a dispute between Pasay City Alliance Church (PCAC) and Fe Benito, a licensed
Christian Minister of Christian and Missionary Alliance Churches of the Philippines (CAMACOP). PCAC is
one of the local churches of CAMACOP, a religious society registered with the Securities and Exchange
Commission.

The controversy arose from CAMACOP and PCAC's policy requiring pastors or ministers without written
contracts to submit a courtesy resignation every year. Benito, as the Head of Pastoral Care and
Membership at PCAC, complied with this policy by submitting her courtesy resignation. However, the
Church Ministry Team (CMT) decided not to renew her appointment the following year, citing various
reasons, including alleged inefficiency in her administrative duties.

Benito filed a complaint for illegal dismissal, damages, and attorney's fees against PCAC, asserting that
she had attained regular status and security of tenure due to her long years of service.

The Labor Arbiter initially ruled in favor of Benito, declaring an employer-employee relationship between
the parties and finding her illegally dismissed. However, the National Labor Relations Commission (NLRC)
overturned this decision, stating that the matter fell under ecclesiastical affairs and was outside the labor
tribunal's jurisdiction.

Benito then sought relief from the Court of Appeals (CA), which annulled the NLRC's resolutions, arguing
that the termination was a secular matter. The CA remanded the case to the NLRC for further
proceedings.

The main issue brought before the Supreme Court was whether the termination of Benito's appointment
was an ecclesiastical affair or a matter within the labor tribunal's jurisdiction.

Decision of the Court:

The Supreme Court ruled in favor of the petitioners, stating that the termination of a religious minister's
engagement, when related to the perceived effectiveness of the minister in a congregation, is a
prerogative best left to the church affected by such choice. The Court emphasized that it should not
interfere with church authorities' discretionary functions.
In this case, Benito was aware of CAMACOP's policy requiring annual courtesy resignations, and the
Court found that PCAC's decision not to renew her appointment was a matter of internal church policy
related to its mission. Therefore, the State had no valid reason to interfere.

The Court upheld the CA's interpretation that the termination was secular and not an ecclesiastical affair,
as it was based on administrative lapses. It dismissed Benito's complaint for want of jurisdiction and
reversed the CA's decision to remand the case to the NLRC.

Conclusion:
The Supreme Court ruled that the termination of a religious minister's appointment, when related to the
perceived effectiveness of the minister in a congregation and governed by internal church policies, is an
ecclesiastical affair. Therefore, the labor tribunal had no jurisdiction over the matter, and the complaint
was dismissed.

Facts:

● Parties: The case involves two parties:

● Petitioners: Pasay City Alliance Church (PCAC), Christian and Missionary Alliance Churches of the
Philippines (CAMACOP), and Reverend William Cargo.

● Respondent: Fe P. Benito.
Background of PCAC and CAMACOP: PCAC is one of the local churches affiliated with CAMACOP,
a religious society registered with the Securities and Exchange Commission.

● Fe P. Benito: Fe P. Benito is a licensed Christian Minister of CAMACOP. She completed a degree in

Religious Education from CAMACOP's Ebenezer Bible College and Seminary and served in various
positions at PCAC.

● Policy on Courtesy Resignations: CAMACOP and PCAC had a policy requiring pastors or ministers
without written contracts to submit a courtesy resignation every year. This policy aimed to allow
the reassignment of ministers as needed.

● Benito's Tenure: Benito served as the Head of Pastoral Care and Membership at PCAC without a
written contract. She submitted her courtesy resignation as per the policy on January 30, 2011,
and was reappointed for another year.

● Decision Not to Reappoint Benito: In February 2012, the Church Ministry Team (CMT) decided
not to reappoint Benito for the same position. They cited various reasons, including alleged
inefficiency in her duties.
 ● Second Courtesy Resignation and Decision: On February 17, 2013, Benito submitted another
courtesy resignation, and the CMT evaluated her performance. On December 15, 2013, Benito
was informed that her engagement as the Head of Pastoral Care and Membership would not be
extended.

● Benito's Complaint: Dissatisfied with the decision, Benito filed a complaint for illegal dismissal,
damages, and attorney's fees against PCAC, arguing that she had attained regular status and
security of tenure due to her long years of service.

● Labor Arbiter's Decision: The Labor Arbiter initially ruled in favor of Benito, declaring an
employer-employee relationship between the parties and finding her illegally dismissed. The
Labor Arbiter ordered PCAC to pay separation pay and backwages.

● NLRC's Reversal: The National Labor Relations Commission (NLRC) overturned the Labor Arbiter's
decision, stating that the matter fell under ecclesiastical affairs and was outside the labor
tribunal's jurisdiction.

● CA's Decision: Benito challenged the NLRC's resolutions before the Court of Appeals (CA), which
annulled the NLRC's resolutions, arguing that the termination was a secular matter. The CA
remanded the case to the NLRC for further proceedings.

● Supreme Court's Decision: The case reached the Supreme Court, which ruled that the
termination of a religious minister's engagement related to perceived effectiveness in a
congregation and governed by internal church policies was an ecclesiastical affair. The Court
upheld the CA's interpretation that the termination was secular and dismissed Benito's
complaint for want of jurisdiction.

Issue:

The main issue in the case of Pasay City Alliance Church/CAMACOP/Rev. William Cargo, Petitioners, vs. Fe
Benito, Respondent is:

Whether the termination of Fe Benito's appointment as Head of Pastoral Care and Membership at Pasay
City Alliance Church (PCAC) is an ecclesiastical affair or a matter within the jurisdiction of labor tribunals.

This issue revolves around the question of whether the decision not to renew Fe Benito's position at
PCAC, based on internal church policies and perceived effectiveness, falls under ecclesiastical matters,
which are exempt from the jurisdiction of labor tribunals, or whether it is a secular issue subject to labor
laws and regulations. The resolution of this issue determines whether the complaint for illegal dismissal
filed by Fe Benito should be dismissed for lack of jurisdiction or proceed for further consideration by
labor authorities.
Ruling:

The petition is hereby GRANTED. The May 13, 2016 Decision and the September 8, 2016 Resolution of
the Court of Appeals in CA-G.R. SP No. 140572 are REVERSED and SET ASIDE. Accordingly, Fe P. Benito's
illegal dismissal complaint before the National Labor Relations Commission is DISMISSED for want of
jurisdiction.