Taruc vs Dela Cruz & Islamic vs Exec Sec

Taruc vs. Dela Cruz G.R. No. 144801. March 10, 2005

Facts: Respondent Bishop de la Cruz petitioners expelled/excommunicated from the Philippine Independent Church for disobedience to duly constituted authority in the Church; inciting dissension, resulting in division in the Parish of Our Mother of Perpetual Help, Iglesia Filipina Independiente, Socorro, Surigao del Norte when they celebrated an open Mass at the Plaza on June 19, 1996; and for threatening to forcibly occupy the Parish Church causing anxiety and fear among the general membership reasons Petitioners filed a complaint contending that their expulsion was illegal because it was done without trial thus violating their right to due process of law.

Issue: Whether or not the courts have jurisdiction to hear a case involving the expulsion/excommunication of members of a religious institution.

Held: The case at bar is purely ecclesiastical matters which is considered to be outside the providence of the court due to the form of government where the complete separation of civil and ecclesiastical authority is insisted upon. Hence, the civil courts must not allow themselves to intrude unduly in matters of an ecclesiastical nature. Civil Courts will not interfere in the internal affairs of a religious organization except for the protection of civil or property rights. Those rights may be the subject of litigation in a civil court, and the courts have jurisdiction to determine controverted claims to the title, use, or possession of church property. Those who unite to an ecclesiastical body do so with implied consent to submit to the Church government and they are bound to submit to it. The power to exclude membership from the church of those considered unworthy lies solely to the Church thus it is outside the province of the civil court. The expulsion of membership of the petitioners was legally made. They have not violated the due process of law because they were given opportunity to be heard when they were also warned of the consequences of their actions.

IDCPI vs. Executive Secretary G.R. No. 153888 July 9, 2003

Facts: The office of the Executive Secretary issued EO 46 creating the Philippine Halal Certification Scheme and designating respondent Office of Muslim Affairs (OMA) to oversee its implementation. Under the EO, respondent OMA has the exclusive authority to issue halal certificates and perform other related regulatory activities. Petitioner, lost revenues after food manufacturers stopped securing certifications from it, filed a complaint praying to nullify the EO 46 and further implementation of it. The complaint contends that the EO 46 violate the constitutional provision on the separation of Church and State. The function of exclusive issuance of halal certificates is only for religious organization – a food becomes halal only after the performance of Islamic religious ritual and prayer. Issue: Whether or not EO 46 is unconstitutional thus, null and void.

Held: Classifying a food product as halal is a religious function because the standards used are drawn from the Qur'an and Islamic beliefs. Office of Muslim Affairs (OMA) deals with the societal, legal, political and economic concerns of the Muslim community as a "national cultural community" and not as a religious group. By giving OMA the exclusive power to classify food products as halal, EO 46 encroached on the religious freedom of Muslim organizations thus transgressing the preferred status of the freedom of religion. Interpretation of what food products are fit for Muslim consumption is vested exclusively on the conscience and belief of one person whether muslim or non-muslim. The protection and promotion of the muslim Filipinos' right to health are already provided for in existing laws and ministered to by government agencies charged with ensuring that food products released in the market are fit for human consumption, properly labeled and safe. Unlike EO 46, these laws do not encroach on the religious freedom of muslims. Therefore the EO 46 is null and void. Exception: When there is an immediate and grave danger to the security and welfare of the community can justify the infringement of religious freedom – accorded preferred status. NMIC [DA] - guarantees that the meat sold in the market has been thoroughly inspected and fit for consumption.

BFD - ensures that food products are properly categorized and have passed safety and quality standards. DTI - through the labeling provisions