SC cites Bible passage in ruling on labor case of a church minister
By Rey Panaligan
“Give to Caesar what is Caesar’s and to God what is God’s.”
This biblical passage was re-echoed by the Supreme Court (SC) in its decision that reiterated the constitutionally protected policy of non-interference by the State in purely ecclesiastical affairs of a church.
Supreme Court (SC) (MANILA BULLETIN)
It defined an ecclesiastical affair as one “involving the relationship between the church and its members and relates to matters of faith, religious doctrines, worship and governance of the congregation.”
Cited as examples of ecclesiastical affairs to which the State cannot meddle are “proceedings for excommunication, ordinations of religious ministers, administration of sacraments, and other activities attached with religious significance.”
With its decision written by Associate Justice Jose C. Reyes Jr., the SC reversed the ruling of the Court Appeals as it upheld the prerogative of the Pasay City Alliance Church (PCAC) to withhold the extension of the engagement of Fe P. Benito, a licensed Christian minister, as PCAC’s head of Pastoral Care and Membership.
PCAC is one of the local churches of the Christian and Missionary Alliance Churches of the Philippines (CAMACOP), a religious society registered with the Securities and Exchange Commission (SEC).
It has a policy which requires pastors and ministers without written contracts to tender a courtesy resignation every year.
A case summary issued by the SC’s public information office (PIO) stated that the SC ruled that the National Labor Relations Commission (NLRC) had no jurisdiction to hear the case rationalizing that “the termination of a religious minister’s engagement at a local church due to administrative lapses, when it relates to the perceived effectivity of a minister as a charismatic leader of a congregation, is a prerogative best left to the church affected by such choice.”
Quoting from the decision, the summary stated that “if a religious association enacts guidelines that reserve the right to transfer or reassign its licensed ministers according to what it deems best for a particular congregation, ministry or undertaking in pursuit of its mission, then the State cannot validly interfere.”
The summary stated that Benito filed a complaint for illegal dismissal, damages, and attorney’s fees before the Labor Arbiter when PCAC decided on the non-extension of her engagement as head of Pastoral Care and Membership.
Benito claimed that she had attained regular status by operation of law and thus, entitled to security of tenure in view of her service to the PCAC since 2005 when she was appointed Head of Membership and Evangelism Ministry.
For its part, PCAC challenged the jurisdiction of the labor tribunal contending that the determination of fitness to be one of the congregation’s ministers is an ecclesiastical affair over which our labor tribunals have no jurisdiction.
It also argued that Benito’s insistence on her supposed right to security of tenure undermines their church’s guidelines in continuously assigning their licensed ministers from one local church or ministry to another.
The labor arbiter ruled in favor of Benito’s complaint and ordered her reinstatement. On appeal, the NLRC reversed the labor arbiter with a ruling that Benito’s case should be treated as an ecclesiastical matter outside of the labor tribunal’s jurisdiction.
Benito elevated the case to the Court of Appeals (CA) which reversed the NLRC and remanded the case to the commission to determine the validity of her dismissal from employment.
PCAC and CAMACOP appealed the CA’s ruling before the SC.
Supreme Court (SC) (MANILA BULLETIN)
It defined an ecclesiastical affair as one “involving the relationship between the church and its members and relates to matters of faith, religious doctrines, worship and governance of the congregation.”
Cited as examples of ecclesiastical affairs to which the State cannot meddle are “proceedings for excommunication, ordinations of religious ministers, administration of sacraments, and other activities attached with religious significance.”
With its decision written by Associate Justice Jose C. Reyes Jr., the SC reversed the ruling of the Court Appeals as it upheld the prerogative of the Pasay City Alliance Church (PCAC) to withhold the extension of the engagement of Fe P. Benito, a licensed Christian minister, as PCAC’s head of Pastoral Care and Membership.
PCAC is one of the local churches of the Christian and Missionary Alliance Churches of the Philippines (CAMACOP), a religious society registered with the Securities and Exchange Commission (SEC).
It has a policy which requires pastors and ministers without written contracts to tender a courtesy resignation every year.
A case summary issued by the SC’s public information office (PIO) stated that the SC ruled that the National Labor Relations Commission (NLRC) had no jurisdiction to hear the case rationalizing that “the termination of a religious minister’s engagement at a local church due to administrative lapses, when it relates to the perceived effectivity of a minister as a charismatic leader of a congregation, is a prerogative best left to the church affected by such choice.”
Quoting from the decision, the summary stated that “if a religious association enacts guidelines that reserve the right to transfer or reassign its licensed ministers according to what it deems best for a particular congregation, ministry or undertaking in pursuit of its mission, then the State cannot validly interfere.”
The summary stated that Benito filed a complaint for illegal dismissal, damages, and attorney’s fees before the Labor Arbiter when PCAC decided on the non-extension of her engagement as head of Pastoral Care and Membership.
Benito claimed that she had attained regular status by operation of law and thus, entitled to security of tenure in view of her service to the PCAC since 2005 when she was appointed Head of Membership and Evangelism Ministry.
For its part, PCAC challenged the jurisdiction of the labor tribunal contending that the determination of fitness to be one of the congregation’s ministers is an ecclesiastical affair over which our labor tribunals have no jurisdiction.
It also argued that Benito’s insistence on her supposed right to security of tenure undermines their church’s guidelines in continuously assigning their licensed ministers from one local church or ministry to another.
The labor arbiter ruled in favor of Benito’s complaint and ordered her reinstatement. On appeal, the NLRC reversed the labor arbiter with a ruling that Benito’s case should be treated as an ecclesiastical matter outside of the labor tribunal’s jurisdiction.
Benito elevated the case to the Court of Appeals (CA) which reversed the NLRC and remanded the case to the commission to determine the validity of her dismissal from employment.
PCAC and CAMACOP appealed the CA’s ruling before the SC.