Petitioners were lay members of the Philippine Independent Church (PIC) in Socorro, Surigao del Norte. Respondents Porfirio de la Cruz and Rustom Florano were the bishop and parish priest, respectively, of the same church in that locality. Petitioners, led by Dominador Taruc, clamored for the transfer of Fr. Florano to another parish but Bishop de la Cruz denied their request. It appears from the records that the family of Fr. Florano’s wife belonged to a political party opposed to petitioner Tarucs, thus the animosity between the two factions with Fr. Florano being identified with his wife’s political camp. Bishop de la Cruz, however, found this too flimsy a reason for transferring Fr. Florano to another parish.Because of the order of expulsion/excommunication, petitioners filed a complaint for damages with preliminary injunction against Bishop de la Cruz before the RTC.They contended that their expulsion was illegal because it was done without trial thus violating their right to due process of law.
ISSUE: What is the role of the State, through the Courts, on matters of religious intramurals?
The expulsion/excommunication of members of a religious institution/organization is a matter best left to the discretion of the officials, and the laws and canons, of said institution/organization.
It is not for the courts to exercise control over church authorities in the performance of their discretionary and official functions. Rather, it is for the members of religious institutions/organizations to conform to just church regulations.
“Civil Courts will not interfere in the internal affairs of a religious organization except for the protection of civil or property rights. Those rights may be the subject of litigation in a civil court, and the courts have jurisdiction to determine controverted claims to the title, use, or possession of church property.”
Obviously, there was no violation of a civil right in the present case.