4/14/2021 E-Library - Information At Your Fingertips: Printer Friendly In Austria v. National Labor Relations Commission[16] (Austria), this Court reached a conclusion which is different from that of the ponencia. The difference in conclusion, however, lies in the allegations put forward by the church to justify the removal of its employee-minister. In Austria, the employee-minister received a letter terminating his services on the grounds of misappropriation of denominational funds, willful breach of trust, serious misconduct, gross and habitual neglect of duties, and commission of an offense against the person of employer's (the church) duly authorized representative. This Court found that the church removed the minister as its employee and not as its church official or even its church member. Moreover, the church belatedly questioned the jurisdiction of the administrative bodies and actively participated in the hearings. Austria’s distinction between secular and ecclesiastical affairs provides an enlightening discussion: The rationale of the principle of the separation of church and state is summed up in the familiar saying, "Strong fences make good neighbors." The idea advocated by this principle is to delineate the boundaries between the two institutions and thus avoid encroachments by one against the other because of a misunderstanding of the limits of their respective exclusive jurisdictions. The demarcation line calls on the entities to "render therefore unto Ceasar [sic] the things that are Ceasar's [sic] and unto God the things that are God's." The Church is likewise barred from meddling in purely secular matters. The case at bar does not concern an ecclesiastical or purely religious affair as to bar the State from taking cognizance of the same. An ecclesiastical affair is "one that concerns doctrine, creed or form or worship of the church, or the adoption and enforcement within a religious association of needful laws and regulations for the government of the membership, and the power of excluding from such associations those deemed unworthy of membership." Based on this definition, an ecclesiastical affair involves the relationship between the church and its members and relate to matters of faith, religious doctrines, worship and governance of the congregation. To be concrete, examples of this so-called ecclesiastical affairs to which the State cannot meddle are proceedings for excommunication, ordinations of religious ministers, administration of sacraments and other activities which attached religious significance. The case at bar does not even remotely concern any of the abovecited examples. While the matter at hand relates to the church and its religious minister it does not ipso facto give the case a religious significance. Simply stated, what is involved here is the relationship of the church as an employer and the minister as an employee. It is purely secular and has no relation whatsoever with the practice of faith, worship or doctrines of the church. In this case, petitioner was not excommunicated or expelled from the membership of the SDA but was terminated from employment. Indeed, the matter of terminating an employee, which is purely secular in nature, is different from the ecclesiastical act of expelling a member from the religious congregation. As pointed out by the OSG in its memorandum, the grounds invoked for petitioner's dismissal, namely: misappropriation of denominational funds, https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/66079 19/24