Alfredo Long and Felix Almeria vs. Lydia Basa, Anthony Sayheeliam, and Yao Chek
**Facts:**
1. **Formation and Incorporation:**
– In 1973, a religious group, “The Church in Quezon City (Church Assembly Hall), Inc.,” was formed in Quezon City as a non-stock, non-profit religious corporation, registered with the Securities and Exchange Commission (SEC).
2. **Structure and By-Laws:**
– The Church was managed by a Board of Directors composed of six members, all of whom were required to adhere strictly to the Church’s doctrines. The By-laws gave the Board the authority to admit and expel members, particularly those who failed to adhere to the Church’s principles of faith.
3. **Signs of Dissent:**
– From 1988 onwards, the Board observed that certain members, including petitioners, were introducing teachings not based on the Church’s doctrines. Despite repeated warnings and exhortations, these members failed to conform.
4. **Board Resolution:**
– On August 30, 1993, during its regular meeting, the Board reviewed and updated its membership list, removing members who were deceased, had migrated, or had lost contact, including petitioners for not adhering to the Church’s principles.
5. **Challenge and Legal Proceedings:**
– Petitioners challenged their expulsion by filing a petition with the SEC, arguing that their expulsion was done without prior notice and hearing.
6. **SEC and Court Proceedings:**
– The SEC Hearing Officer denied their petition for a writ of preliminary injunction, ruling no prior notice to members was necessary under the By-laws.
– Petitioners escalated the issue to the SEC en banc, which upheld the Hearing Officer’s decision.
– Further proceedings continued, leading to a mixed decision within the SEC en banc, and the matter was taken to the Court of Appeals, which eventually sided against the petitioners.
7. **Supreme Court Proceedings:**
– Petitioners filed for certiorari with the Supreme Court under Rule 45 of the 1997 Rules of Civil Procedure, challenging the expulsion’s validity.
**Issues:**
1. **Whether the expulsion of petitioners by the Board of Directors was in accordance with the By-laws of the Church and the governing law.**
2. **Whether the lack of prior notice and hearing rendered the expulsion void as a violation of due process.**
3. **Whether the SEC en banc’s reversal of its previous decision was valid.**
**Court’s Decision:**
1. **Validity of Expulsion under By-laws:**
– The Court confirmed that the By-laws did permit the Board of Directors to expel members without having to provide prior notice or a hearing. The petitioners, by becoming members, had agreed to these By-laws.
2. **Due Process Considerations:**
– Regardless of the By-laws not requiring prior notice, the Court highlighted that petitioners were aware of their improper conduct and had been persistently warned and advised by the Board since 1988. Thus, sufficient notice was given.
3. **Finality and SEC en banc Reversal:**
– The Court pronounced the SEC en banc had initially upheld the expulsion’s validity. Petitioners did not appeal this decision, thereby rendering it final and conclusive. The subsequent SEC en banc decision attempting to reopen the matter was in violation of the settled principle that favors the finality of judgments.
**Doctrine:**
1. **Adherence to Organizational By-laws:**
– Organizational rules, especially within religious entities, are binding on members who voluntarily adhere to them (Section 91 of the Corporation Code).
2. **Finality of Administrative Decisions:**
– Final judgments by administrative or quasi-judicial bodies must stand as conclusive. Revisiting them undermines the rule of law and fair administration of justice.
3. **Ecclesiastical Matters and Civil Courts:**
– Courts typically refrain from intervening in purely ecclesiastical matters unless there are allegations of violations of civil rights or deviation from governing laws.
**Class Notes:**
1. **Essential Principles in Corporate Law (Religious Corporations):**
– **Termination of Membership (Section 91, Corporation Code):** Membership in such corporations can be terminated per their articles of incorporation or by-laws.
– **Non-Interference Policy:** Courts generally do not interfere in ecclesiastical matters but will step in if civil rights are violated.
2. **Due Process:**
– **Fundamental Requirement:** Even absent explicit by-law stipulations, due process generally necessitates notice and an opportunity to be heard.
3. **Finality of Decisions:**
– **Administrative Res Judicata:** Final and executory decisions by administrative bodies acquire vested rights for the winning party.
**Historical Background:**
– This case emphasizes the tension between religious autonomy and civil oversight within corporate governance. Historically, the case illustrates the separation of church and state principles and how such disputes are adjudicated in the context of Filipino jurisprudence, evolving around interpretations of corporate laws applied to religious affiliations.
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