G.R. Nos. 134963-64, 135152-53, & 137135. September 27, 2001.
ALFREDO LONG, FELIX ALMERIA, LIM CHE BOON, TAN HON KOC, JOSEPH LIM, and LIU YEK SEE, petitioners, vs. LYDIA BASA, ANTHONY SAYHEELIAM, and YAO CHEK, respondents.

FACTS

The Church in Quezon City (Church Assembly Hall), Inc. is a non-stock, non-profit religious corporation. Its Articles of Incorporation and By-laws grant its Board of Directors the absolute power to admit and expel members to preserve the church’s faith. Specifically, the By-laws authorize the Board to expel any member by resolution without assigning any reason if the member’s conduct is dishonorable, improper, or injurious to the character and interest of the institution. Starting in 1988, the Board observed that certain members, the petitioners, were introducing doctrines and teachings not based on the Holy Bible and contrary to the church’s declared Principles of Faith. The Board repeatedly admonished petitioners to correct their ways during worship gatherings and personal talks.
Despite years of warnings, petitioners persisted. Consequently, during a regular meeting on August 30, 1993, the Board of Directors resolved to update the official membership list. The updated list excluded the names of petitioners Joseph Lim, Liu Yek See, Alfredo Long, and Felix Almeria for espousing doctrines inimical to the church’s faith, effectively expelling them. Petitioners challenged this expulsion before the Securities and Exchange Commission (SEC), arguing the expulsion was invalid for lack of due process and that the Board’s action constituted an ultra vires act.

ISSUE

Whether the Board of Directors of a religious corporation validly expelled the petitioner-members on purely religious grounds without a formal hearing.

RULING

Yes, the expulsion was valid. The Supreme Court ruled that the expulsion of members from a religious corporation on doctrinal or spiritual grounds falls within the ecclesiastical jurisdiction of the church and its governing bodies. Civil courts must exercise restraint and avoid delving into matters of faith, doctrine, and ecclesiastical discipline. The Court emphasized the constitutional guarantee of free exercise of religion, which includes the right of religious groups to independently manage their own affairs. The power to expel was explicitly granted to the Board by the corporate By-laws, which the members agreed to upon joining. The requirement for a formal trial-type hearing is not necessary in such ecclesiastical matters. The years of repeated admonitions and warnings given to the petitioners constituted sufficient opportunity for them to be heard and conform, satisfying the fundamental fairness required. The Court held that the Board acted within its authority to protect the church’s doctrinal integrity from perceived injurious conduct. The SEC and the Court of Appeals correctly refused to interfere with this internal ecclesiastical action.