G.R. No. 226908 , November 28, 2019
Pasay City Alliance Church/CAMACOP/Rev. William Cargo, Petitioners, vs. Fe Benito, Respondent.

FACTS

Respondent Fe Benito, a licensed Christian Minister of the Christian and Missionary Alliance Churches of the Philippines (CAMACOP), served the Pasay City Alliance Church (PCAC), a local church of CAMACOP, as Head of its Pastoral Care and Membership Ministry without a written contract. CAMACOP had a policy, expressed in its Amended Local Church Administrative and Ministry Guidelines, requiring ministers without written contracts to tender a courtesy resignation every year, with reappointment or reassignment subject to evaluation. Benito complied with this policy, tendering courtesy resignations in 2011 (after which she was reappointed) and 2013. Based on a 2012 evaluation citing performance issues (e.g., failure to perform evangelism duties, administrative lapses), the Church Ministry Team (CMT) ultimately decided not to renew her appointment to the position. Benito was informed of this decision in December 2013. She filed a complaint for illegal dismissal before the Labor Arbiter, claiming she had attained regular status and security of tenure. The Labor Arbiter ruled in her favor, finding an employer-employee relationship based on evidence like payslips, work directives, and deductions for SSS, PhilHealth, and Pag-IBIG, and declared her illegally dismissed. The NLRC reversed the Labor Arbiter, dismissing the complaint for lack of jurisdiction, ruling the non-renewal was an ecclesiastical matter. The Court of Appeals annulled the NLRC resolutions, holding the termination was secular and not an ecclesiastical affair, and remanded the case to the NLRC.

ISSUE

Whether the Court of Appeals erred in declaring that the termination of respondent Fe Benito by petitioner PCAC is not an “ecclesiastical affair” but instead a severance of an employer-employee relationship over which the Labor Arbiter has jurisdiction.

RULING

The Supreme Court GRANTED the petition, REVERSED and SET ASIDE the Decision and Resolution of the Court of Appeals, and DISMISSED Benito’s illegal dismissal complaint for want of jurisdiction. The Court held that the matter involves an ecclesiastical affair over which civil courts have no jurisdiction. The non-renewal of Benito’s appointment was a consequence of the enforcement of a validly enacted ecclesial regulation of CAMACOP—the policy requiring annual courtesy resignations for possible reassignment of its licensed ministers. This policy is integral to the church’s self-governance in matters of faith, doctrine, and ecclesiastical discipline. The power to assign, reassign, or transfer ministers according to what it deems best for its congregations and mission is a purely ecclesiastical prerogative. The State cannot interfere with this discretionary function without violating the constitutional principles of separation of church and state and religious freedom. The fact that Benito remains a licensed minister of CAMACOP and was only not reappointed to a specific local church underscores that the issue pertains to church administration, not secular employment termination. While the church enrolled its ministers in state benefit systems, this act of welfare does not negate the spiritual nature of the relationship or subject purely ecclesiastical decisions to state scrutiny.