FONACIER VS. COURT OF APPEALS [96 PHIL 417; G.R. L-5917; 28 JAN 1955]
FONACIER VS. COURT OF
APPEALS [96 PHIL 417; G.R. L-5917; 28 JAN 1955]
Facts:
Case was filed by
Iglesia Filipina Independiente (IFI), represented by its supreme bishop Gerardo
Bayaca, against Bishop Fonacier seeking to render an accounting of his
administration of all the temporal properties and to recover the same on the
ground that he ceased to be the supreme bishop of IFI. Isabelo De los Reyes Jr.
had been elected as the Supreme Bishop. Petitioner Fonacier claims that he was
not properly removed as Supreme Bishop and his legal successor was Juan Jamias.
He claims that the there was an accounting of his administration and was turned
over to Bishop Jamias. Also, that Isabelo De los Reyes and Bayaca have
abandoned their faith and formally joined the Prostestant Episcopal Church of
America.
CFI rendered judgment
declaring Isabelo De Los Reyes, Jr. as the sole and legitimate Supreme Bishop
of IFI and ordered Fonacier to render an accounting of his admistration.
CA affirmed the
decision of the CFI
Issue: Whether or not
the petitioner should still be regarded as the legitimate supreme bishop of
IFI.
Held: Supreme Court
affirmed CA’s decision. The legitimate Supreme Bishop of IFI is Isabelo De los
Reyes, Jr. The Supreme Court affirms the validity of the election of Bishop
Delos Reyes as the Supreme Bishop based on their internal laws To finally
dispose of the property issue, the Court, citing Watson v. Jones, 368 declared
that the rule in property controversies within religious congregations strictly
independent of any other superior ecclesiastical association (such as the
Philippine Independent Church) is that the rules for resolving such
controversies should be those of any voluntary association. If the congregation
adopts the majority rule then the majority should prevail; if it adopts
adherence to duly constituted authorities within the congregation, then that
should be followed.
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