BISHOP SHINJI AMARI of ABIKO BAPTIS CHURCH vs. RICARDO VILLAFLOR, JR.

GR No. 224521 | February 17, 2020 | Gesmundo, J.

Statement of the issue

Whether or not Private Respondent’s dismissal from Abiko Baptist Church is invalid on the
ground that there exists no employer-employee relationship because the dispute falls within the
ambit of religious congregation which is an ecclesiastical matter

Petitioner’s arguments

Petitioner avers that there exists no employer-employee relationship between BSAABC/MBIS

and respondent on the ground that the dispute involves ecclesiastical affair.

Respondent’s Arguments
Respondent was appointed as instructor of MBIS and his membership in the Abiko Baptists
Church of Japan was only incidental to his main duties and responsibilities as an instructor. It
also alleged that there exists employer-employee relationship and he cannot be dismissed unless
for a cause provided for by the law.
Decision of the Court

YES. The Court ruled that respondent’s appointment as instructor of petitioners’ own
educational institution was by virtue of his membership with Abiko Baptist Church. It is one of
his duties as a missionary/minister of the same. These are considered as ecclesiastical in nature
which the State cannot regulate unless there is clear violation of secular laws. Therefore, the
Court finds that the dismissal is inherent in religious congregations as they have the power to
discipline their members.

Instruction Learned
Respondent’s exclusion of membership from Abiko Baptist Church are purely ecclesiastical
matters. The Court has no authority to meddle in these affairs since the Church has the discretion
to choose members who live up to their religious standards. In this case, the ABA
recommendation as a national missionary is likewise discretionary upon the church since it is a
matter of governance of congregation.
Ratio
It is a settled rule that before a provision of the labor code, such as illegal dismissal, may be
invokes, it is essential that there exists an employer-employee relationship before the parties. In
this case, the employer-employee relationship was not established on the ground that the case
involves ecclesiastical matters and falls under the ambit of religious congregation.