Judicial Council Decisions Search
Decision No. 124
April 25 1956
In Re: Ruling of Bishop Jose L. Valencia in the Ses- sion of the Philippines Annual Conference on the Election of Lay Delegates to the Philip- pines Central Conference
Digest of Case
A preacher On Trial in an Annual Conference cannot serve as Lay Delegate in a Central Conference.
Statement of Facts
Dr. Juan Nabong came to the 1956 session of the Philippines Annual Conference as a Lay member of the Conference from the Knox Memorial Church in Manila. On February 3, he was elected by the Lay members of the Annual Conference as Delegate to the Philippines Central Conference. The next day, February 4, Dr. Nabong was Received On Trial in the Philippines Annual Conference. After his Admission On Trial, the question was raised as to whether Dr. Nabong could remain a Lay Delegate to the Central Conference, and the Bishop was requested to make a ruling on this question. Bishop Valencia based his ruling on the statement concerning Delegates to the Central Conference in Paragraph 562 of the 1952 Discipline which states that "for the first meeting their qualifications shall be the same as provided in Paragraphs 24 and 25, and the Annual Conference shall determine the manner of their choice. Thereafter, their qualifications and the manner of election shall be determined by the Central Conference itself." After quoting the above sentences, Bishop Valencia ruled that the election of Dr. Juan Nabong as Lay Delegate to the Philippines Central Conference stands until the said Central Conference shall determine his qualifications and manner of election. JURISDICTION The ruling of Bishop Valencia is properly before the Judicial Council under Paragraphs 43 (3) and 909 of the 1952 Discipline. ANALYSIS As stated above, Bishop Valencia based his ruling on Paragraph 562 of the 1952 Discipline, which he interpreted as meaning that the Central Conference had the sole authority to pass upon the qualifications and manner of electing its members. In this connection attention is called to the fact that the Constitution in Paragraphs 23, 24 and 25 of the 1952 Discipline prescribes both the qualifications and manner of electing Delegates to the Central Conferences. Said Paragraph 562 of the 1952 Discipline, therefore, cannot be interpreted as giving to the Central Conferences the unlimited right to determine the qualifications and manner of election of its members. Such an interpretation would be in violation of the Constitutional provisions above quoted, and would be void. Said Paragraph 562, however, is subject to an interpretation that is not in conflict with the Constitutional provisions above set out. Apparently that Paragraph was intended to give to the Central Conferences the right to inquire into the qualifications and manner of the election of its members to see if they meet the qualifications and were elected in the manner prescribed by the Constitution. That interpretation would not give to a Central Conference the right to seat a Delegate who did not possess the Constitutional qualifications, or was not elected in the manner prescribed by the Constitution. The Judicial Council, in Decision No. 120, held that in determining the qualifications of a Delegate elected to a Jurisdictional Conference his qualifications as such at the time the service was to be rendered was the controlling factor. The same rule would apply to membership in a Central Conference. The Judicial Council assumes that Dr. Nabong intends to remain in the ministry. This assumption is based upon his request to be Admitted into the Annual Conference On Trial, and the action of the Annual Conference in Admitting him into the Annual Conference On Trial.
It is the Decision of the Judicial Council that a preacher On Trial in an Annual Conference cannot serve as Lay Delegate in a Central Conference. After being Admitted On Trial in the Philippines Annual Conference, Dr. Juan Nabong was no longer eligible to serve as Lay Delegate to the Philippines Central Conference. The ruling of Bishop Jose L. Valencia is therefore reversed.