Taruc vs. Bishop Dela Cruz Facts: Petitioners were lay members of the Philippine Independent Church (PIC).

On June 28, 1993, Bishop de la Cruz declared petitioners expelled/excommunicated from the Philippine Independent Church. Because of the order of expulsion/excommunication, petitioners filed a complaint for damages with preliminary injunction against Bishop de la Cruz before the Regional Trial Court.They contended that their expulsion was illegal because it was done without trial thus violating their right to due process of law.

Issue: What is the role of the State, through the Courts, on matters of religious intramurals?

Held: The expulsion/excommunication of members of a religious institution/organization is a matter best left to the discretion of the officials, and the laws and canons, of said institution/organization. It is not for the courts to exercise control over church authorities in the performance of their discretionary and official functions. Rather, it is for the members of religious institutions/organizations to conform to just church regulations.

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.

Obviously, there was no violation of a civil right in the present case.

G.R. No. 112193. March 13, 1996Aruego Jr. vs Court of AppealsCase Digest by Justine Mae C. Sales FACTS: On March 7, 1983, a complaint for compulsory recognition andenforcement of successional rights was filed before RTC Manila by the minorsAntonia Aruego and alleged the sister Evelyn Aruego represented by theirmother Luz Fabian. The complaint was opposed by the legitimate children of Jose Aruego Jr. The RTC rendered judgment in favor of Antonia Aruego. A petition forprohibition and

certiorari with prayer for a writ of preliminary injunction wasthen filed alleging that the Family Code of the Philippines which took effect onAugust 3, 1988 shall have a retroactive effect thereby the trial court lost jurisdiction over the complaint on the ground of prescription. ISSUE: Whether or not the Family Code shall have a retroactive effect in thecase. HELD: It was adopted that the fact of filing of the petition already vested in thepetitioner her right to file it and to have the same proceed to final adjudicationin accordance with the law in force at the time, and such right can no longer beprejudiced or impaired by the enactment of a new law. The Supreme Court upheld that the Family Code cannot be given retroactiveeffect in so far as the instant case is concerned as its application will prejudicethe vested rights of respondents to have her case be decided under Article 285of the Civil Code. It is a well settled reception that laws shall have a retroactiveeffect unless it would impair vested rights. Therefore, the Family Code in thiscase cannot be given a retroactive effect.Prescinding from this, the conclusion then ought to be that the action was notyet barred, notwithstanding the fact that it was brought when the putativefather was already deceased, since private respondent was then still a minorwhen it was filed, an exception to the general rule provided under Article 285of the Civil Code. Hence, the trial court, which acquired jurisdiction over thecase by the filing of the complaint, never lost jurisdiction over the same despitethe passage of E.O. No. 209, also known as the Family Code of the Philippines. The ruling herein reinforces the principle that the jurisdiction of a court,whether in criminal or civil cases, once attached cannot be ousted bysubsequent happenings or events, although of a character which would haveprevented jurisdiction from attaching in the first instance, and it retains jurisdiction until it finally disposes of the case.

Subido vs sandiganbayan (G.R. No. 122641; January 20, 1997) Facts: On June 25, 1992, Bayani Subido Jr., then a Commissioner of the Bureau of Immigration and Deportation (BID) and Rene Parina, a BID special agent, while in the performance of their official functions, issued and implemented a warrant of arrest against James J. Maksimuk, knowing fully well that the BID decision requiring Maksimuks deportation was not yet final and executory. This resulted to the detention of Maksimuk for a period of 43 days, causing him undue injury. Subido and Parina were charged with Arbitrary Detention defined and punished by Article 124 of the Revised Penal Code. For their part, the petitioners filed a Motion to Quash, contending that the Sandiganbayan had no jurisdiction over the case since when it was filed, Subido was no longer part of the service and Parina was not occupying a position corresponding to salary grade 27. Issue:

Whether or not the Sandiganbayan had jurisdiction over the case Ruling: Yes. The Sandiganbayan had jurisdiction over the case by virtue of Section 2 of R.A. 7975, which amended Section 4 of P.D. No. 1606 Section 2: Section 4 of P.D. No. 1606 is hereby further amended to read as follows: Section 4: Jurisdiction The Sandiganbayan shall exercise original jurisdiction in all cases involving: a. Violations of Republic Act No. 3019, as amended, otherwise known as the Anti-Graft and Corrupt Practices Act, Republic Act No. 1379, and Chapter II, Section 2, Title VII of the Revised Penal Code, where one or more of the

principal accused are officials occupying the following positions in the government, whether in permanent, acting or interim capacity, at the time of the commission of the offense; 1)Officials of the executive branch occupying positions of regional director and higher, otherwise classified as grade 27 and higher, of the Compensation and Position Classification Act of 1989 (R.A. 6758), specificially including: xxx 5)All other national and local officials classified as Grade 27 and higher under the Compensation and Position Classification Act of 1989. b. Other offenses or felonies committed by the public officials and employees mentioned in subsection (a) of this section in relation to the office. c. Civil and criminal cases filed pursuant to and in connection with the Executive Order Nos. 1,2, 14, and 14-A. In cases where none of the principal accused are occupying positions corresponding to salary grade 27 or higher, as prescribed in said R.A. 6758, or PNP officers occupying the rank of superintendent or higher, or their equivalent, exclusive jurisdiction thereof shall be vested n the proper Regional Trial Court, Metropolitan Trial Court, Municipal Trial Court, and Municipal Circuit Trial Court, as the case may be, pursuant to their respective jurisdiction as provided in Batas Blg. 129. Contrary to the claims of the petitioners, R.A. 7975 applies since what is considered is the time of the commission of the crime, during which Subido was still Commissioner of BID. Similarly, although Parina was holding a position with a classification lower than salary grade 27, it still applies to him since he is prosecuted as a coconspirator of Subido, the principal accused. Jurisdiction is only vested on the other courts if none of the principal accused where occupying positions corresponding to salary grade 27.