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 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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