Posted by Rio Vie C. Dumalag on 25 July 2018
FACTS:
United Church of Christ in the Philippines, Inc. (UCCP) is a religious corporation duly organized and existing under the laws of the Philippines. It is a national confederation of incorporated and unincorporated self-governing Evangelical churches of different denominations, devised for fellowship, mutual counsel and cooperation. Bradford United Church of Christ, Inc. (BUCCI), is likewise a religious corporation with a personality separate and distinct from UCCP.
UCCP has 3 governing bodies: the General Assembly, the Conference and the Local Churches. BUCCI belonged to the Cebu Conference Inc. and enjoyed a peaceful co-existence until late 1989 when the BUCCI constructed a fence that encroached upon the right of way allocated by the UCCP for CCI.
The General Assembly attempted to settle the dispute and rendered a decision in favor of CCI. This triggered a series of events, which further increased enmity and led to the formal break-up of BUCCI from UCCP. Consequently, BUCCI filed its amended Articles of Incorporation and By-Laws, which provided for and affected its disaffiliation from UCCP. SEC approved the same. UCCP filed a complaint before SEC to reject the same but SEC dismissed UCCP's petition.
ISSUE:
Whether or not, SEC has the jurisdiction over matters involving UCCP and BUCCI.
RULING:
YES. Being corporate entities and grantees of primary franchises, are subject to the jurisdiction of the SEC. Section 3 of Presidential Decree No. 902-A provides that SEC shall have absolute jurisdiction, supervision and control over all corporations. Even with their religious nature, SEC may exercise jurisdiction over them in matters that are legal and corporate. Well-settled is the judicial dictum that factual findings of quasi-judicial agencies, such as SEC, which have acquired expertise because their jurisdiction is confined to specific matters, are generally accorded not only respect but even finality. They are binding upon this Court which is not a trier of facts. Only upon clear showing of grave abuse of discretion, or that such factual findings were arrived at arbitrarily or in disregard of the evidence on record will this Court step in and proceed to make its own independent evaluation of the facts. No cogent reason exists in the instant cases to deviate from this settled rule. #END
FACTS:
United Church of Christ in the Philippines, Inc. (UCCP) is a religious corporation duly organized and existing under the laws of the Philippines. It is a national confederation of incorporated and unincorporated self-governing Evangelical churches of different denominations, devised for fellowship, mutual counsel and cooperation. Bradford United Church of Christ, Inc. (BUCCI), is likewise a religious corporation with a personality separate and distinct from UCCP.
UCCP has 3 governing bodies: the General Assembly, the Conference and the Local Churches. BUCCI belonged to the Cebu Conference Inc. and enjoyed a peaceful co-existence until late 1989 when the BUCCI constructed a fence that encroached upon the right of way allocated by the UCCP for CCI.
The General Assembly attempted to settle the dispute and rendered a decision in favor of CCI. This triggered a series of events, which further increased enmity and led to the formal break-up of BUCCI from UCCP. Consequently, BUCCI filed its amended Articles of Incorporation and By-Laws, which provided for and affected its disaffiliation from UCCP. SEC approved the same. UCCP filed a complaint before SEC to reject the same but SEC dismissed UCCP's petition.
ISSUE:
Whether or not, SEC has the jurisdiction over matters involving UCCP and BUCCI.
RULING:
YES. Being corporate entities and grantees of primary franchises, are subject to the jurisdiction of the SEC. Section 3 of Presidential Decree No. 902-A provides that SEC shall have absolute jurisdiction, supervision and control over all corporations. Even with their religious nature, SEC may exercise jurisdiction over them in matters that are legal and corporate. Well-settled is the judicial dictum that factual findings of quasi-judicial agencies, such as SEC, which have acquired expertise because their jurisdiction is confined to specific matters, are generally accorded not only respect but even finality. They are binding upon this Court which is not a trier of facts. Only upon clear showing of grave abuse of discretion, or that such factual findings were arrived at arbitrarily or in disregard of the evidence on record will this Court step in and proceed to make its own independent evaluation of the facts. No cogent reason exists in the instant cases to deviate from this settled rule. #END
