Indictment of the PCA Standing Judicial Commission | Exhibit 13

The Ministerial Obligation is provided in the PCA Handbook for Presbytery Clerks, year after year. All teaching elders must sign the same Confessional Subscription (BCO 13-7) corresponding to the same ordination vows (BCO 21-5) in order to be ordained, and their presbyteries must retain these contracts on file.

“What are we? Your grumbling is not against us but against the LORD.”
[Who am I? Your grumbling is not against me but against the LORD.] 

— Exodus 16:8

“Who is this that darkens counsel by words without knowledge?
Dress for action like a man;
I will question you, and you make it known to me.” 

— Job 38:2-3 

“Malicious witnesses rise up;
they ask me of things that I do not know.
They repay me evil for good;
my soul is bereft.” 

— Psalm 35:11-12 

“But Jesus, aware of their malice, said, ‘Why put me to the test, you hypocrites?’” 

— Matthew 22:18 

“Woe to you, when all people speak well of you, for so their fathers did to the false prophets.” 

— Luke 6:26 

What does the second petition mean?
‘Your kingdom come’ means: Rule us by your Word and Spirit in such a way that more and more we submit to you. Preserve and increase your church. Destroy the devil’s work; destroy every force which revolts against you and every conspiracy against your holy Word.
Do all this until your kingdom fully comes, when you will be all in all.” 

— Heidelberg Catechism, Q. 123

“I have been crucified with Christ. It is no longer I who live, but Christ who lives in me. And the life I now live in the flesh I live by faith in the Son of God, who loved me and gave himself for me.” 

— Galatians 2:20, a text very frequently quoted in various writings of J. Gresham Machen 

“Evidence in support of this assertion was adduced in my argument … The charges against the policy … that were made in the argument have never been refuted. …
Obedience to the order … would involve the substitution of a human authority for the authority of the Word of God.” 

— J. Gresham Machen, “Statement to the Presbytery of New Brunswick,” 1935 

“A distressing aspect of the entire controversy is that the charges … were often made by men who simply by-passed the issue of honesty. …
In the last analysis … he … was willing to labour in season and out of season regardless of personal cost. He was bound therefore to be identified prominently with that cause, and to be attacked by those who were attacking it. But there were also several times when [he] became the victim of false charges and rumours that were widely circulated, and so his good name was besmirched. Dr Macartney once characterized the abusive letters which he and other valiant defenders of the faith received as ‘the liturgy of execration.’ But the letters themselves could easily be destroyed. It was not so easy to destroy the evil effects of slander and false rumour. …
One of the most astonishing features of the situation was that Dr Eerdman never acknowledged, at least not in print, that Machen had been unfairly attacked. …
What has been added in these few pages is thought advisable only because of a concern to put to silence once and for all malicious and irresponsible false witness by means of disclosure of the facts. It has indeed been a sordid piece of business that, in the name of religion, men have resorted to the spread of false rumours in order to weaken Machen’s testimony and to belittle the cause for which he suffered and toiled. But he bore this trial with self-denial and patience, and with such single-minded dedication to the cause of the truth, that the nobility of his character shone forth the more brightly because of the ignominy that was heaped upon him.” 

J. Gresham Machen: A Biographical Memoir, Ned B. Stonehouse, circa 1925-1926, pp. 388, 428, 434, 454 

“[Machen] has borne himself in the midst of these slanders with amazing Christian patience, and that while in his case this patience is a virtue, silence and patience on the part of myself and his colleagues, I would regard as ignoble … If the time has come when a man cannot make a bold and noble defence of the truth without being subjected to abuse, then indeed the darkness of medieval intolerance threatens to overwhelm the Presbyterian Church, and to stifle its witness to the truth of God.” 

— Dr. Caspar Wistar Hodge Jr., professor of Systematic Theology at Princeton Theological Seminary, in his statement of support for Machen following the 1927 PCUSA General Assembly 

“But Peter and the apostles answered, ‘We must obey God rather than men.’” 

— Acts 5:29 

“Question 3. … We obey lawful (and not tyrannical) governors, according to the Fifth Commandment, and in doing so, obey God. …
Question 30. Are those citizens of a tyrannical government called to a passive obedience? And what if they flee the despotic powers? Is that lawful by God and Nature (the revelation written on our hearts and observed as ‘common sense’)?
While the Apostle Peter, in 1 Peter 2:18, admonishes the people to show patience and bear up under persecution, and while Jesus’ own non-resistance is a virtue for us, yet these do not require that we give up self-defense. We must resist if given an unlawful order. If one flees in order to obey God rather than Man, this is not a sin.” 

Lex, Rex, Samuel Rutherford, 1644 

“Tyranny was defined as ruling without the sanction of God. Rutherford held that a tyrannical government is always immoral. He said that ‘a power ethical, politic, or moral, to oppress, is not from God, and is not a power, but a licentious deviation of power.’ It follows from Rutherford’s thesis that citizens have a moral obligation to resist unjust and tyrannical government.” 

— Francis Schaeffer, as quoted in Foundations for a Moral Government: Samuel Rutherford’s Lex, Rex, A New Annotated Version in Standard English, Michael Milton, p. 39 

“That to resist a misled King, is not to resist God, nor yet his Ordinance …” 

— “THE FOVRTH BOOK OF The Progresse and Continuance of true Religion within SCOTLAND,” Historie of the Reformation of the Church of Scotland, John Knox, circa 1644, p. 394 

“Resistance to tyranny becomes the Christian and social duty of each individual. … Continue steadfast and, with a proper sense of your dependence on God, nobly defend those rights which heaven gave, and no man ought to take from us.” 

— John Hancock, first signatory of the Declaration of Independence, History of the United States of America, Vol. II, p. 229 

“Rebellion to tyrants is obedience to God.” 

— Thomas Jefferson, first signatory of the Declaration of Independence, 1776


03/25/2022, 03/30/2022: St. Paul’s Presbyterian Church Senior Pastor Justin Louden Borger emails a letter on behalf of his Session to the Plaintiff that he is being “investigated” and “demands satisfactory explanations concerning reports affecting his Christian character.” Borger’s questions reveal that the Session has obtained (supposedly confidential) charges from the Presbytery, but the Session refuses to provide to the Plaintiff such alleged reports to which it demands response. The letter’s questions fixate on why the Plaintiff has filed charges, yet completely ignore their evidence. These “unlawful proceedings” (cf. BCO 32-6.b) spearhead the Court’s “fruit of the poisonous tree.” These interlopers seem to have confused Benyola’s gmail address for Benyola finds it rather ironic that St. Paul’s’ Session just now chooses to be involved in this issue, and makes interference its choice — especially since St. Paul’s is the particular church that TE R.C. Sproul helped to found, but then it suffered schism when Sproul later split to start Saint Andrew’s. 

Alleged violations (errors and/or delinquencies) by the St. Paul’s Presbyterian Church Senior Pastor, Moderator of the Session, et al. 

Primary standards: Exodus 20:16, II Chronicles 7:14, Psalms 11:1-3, 19:7-14, 24:3-6, 26:4-5, 40:4, 50:14-23, 52:1-4, 53:4, 56:5-7, 71:10-11, 74:4-5, 76:11, 78:72, 86:14, 94:16,20, 101:5-8, 106:3, 109:1-5, 116:18-19, 140:1-5,9-11, Proverbs 3:27, 10:23, 11:1, 12:19, 18:5,13,17, 24:11-12,23-25,28-29, 26:17, Ecclesiastes 3:16, 5:1-9, 7:7, 8:1-5,11, 9:17, 10:5,8-10, Jeremiah 11:18-20, 15:15-21, 20:10-13, 21:12, 36:27-32, Lamentations 3:34-36, 5:14, Ezekiel 9:4, 33:1-9, 34:1-10, Amos 5:7,10,14-15,23-24, Zechariah 8:16, Malachi 2:7, Matthew 3:8, 5:10-12, 18:16-17, 23:1-5,13-25,28, Luke 17:3-4, 19:14,27, 21:12-13, Acts 20:27-30, Romans 1:32, 2:1-3,17-21,23-24, I Corinthians 1:10-11, 13:6, II Corinthians 6:3-8, 11:26, 12:20, Ephesians 4:31, 5:6-12, I Timothy 3:2,15, Titus 1:5-7, Hebrews 12:15, James 1:19-25, 3:1,17-18, I Peter 2:1, 5:1-4 

Secondary standards: WCF 1.10; 15.6; 20.1-4; 22.1-6; 30.3; 31.1-3; WLC Q.99.6-8, 111-114, 130, 143-145, 151; WSC Q.14, 76-78; BCO 8-1,-2,-3; 10-3; 11-2,-4; 13-9.e,f; 21-5.7; 31-2; 32-2,-6.b,-17; 34-3; 35-3 

Tertiary standards: RONR (12th ed.) 61:22; 63:7-9, 13, 35 


04/01/2022: After twice being pressed by the same St. Paul’s pastor to respond to reports without receiving these alleged reports from the Session, Benyola files a formal Complaint against the St. Paul’s Session’s errors, which are obstruction of justice in a Presbytery case and prematurely acting on a case still being adjudicated, by ruling a formal investigation of the Plaintiff; and the Session’s delinquency to provide him sufficient information to respond to reports it claims to have obtained.

((first) Complaint of Peter Benyola versus the Session of St. Paul’s PCA


04/07/2022: The Senior Pastor of St. Paul’s transmits a letter to the Complainant on behalf of his Session communicating that this judicatory has ruled to deny his 04/01 Complaint for the reason that it has “intemperate language,” refusing to answer for any errors and delinquencies contested within the Complaint — apparently clearing a path for its escalation to Central Florida Presbytery. 

Alleged violations (errors and/or delinquencies) by the St. Paul’s Presbyterian Church Senior Pastor, Moderator of the Session, et al. 

Primary standards: Genesis 44:16, Exodus 20:16, Deuteronomy 10:16, II Chronicles 7:14, Psalms 7:12-16, 10:2,7,15-18, 11:1-3, 19:7-14, 24:3-6, 26:4-5, 34:11-22, 37:27-33, 40:4, 50:14-23, 52:1-4, 53:4, 55:2-3, 56:5-7, 71:10-11, 74:4-5, 76:11, 86:14, 94:16,20, 101:5-8, 106:3, 109:1-5, 116:18-19, 140:1-5,9-11, Proverbs 1:29-31, 3:27, 10:23, 11:1, 12:19, 18:5,13,17, 20:23, 22:22, 24:11-12,23-25,28-29, 26:17, 28:9,13, Ecclesiastes 3:16, 5:1-9, 7:7, 8:1-5,11, 9:17, 10:5,8-10, Jeremiah 11:18-20, 15:15-21, 20:10-13, 21:12, 36:27-32, Lamentations 3:34-36, 5:14, Ezekiel 9:4, 33:1-9, 34:1-10, Amos 5:7,10,14-15,23-24, Zechariah 1:2-6, 8:16, Malachi 2:7, Matthew 3:8, 5:10-12,22, 18:16-17, 23:1-5,13-25,28, Luke 17:3-4, 19:14,27, 21:12-13, Acts 20:27-30, Romans 1:32, 2:1-3,17-21,23-24, I Corinthians 1:10-11, 13:6, II Corinthians 6:3-8, 11:26, 12:20, Ephesians 4:31, 5:6-12, I Timothy 3:2,15, Titus 1:5-7, James 1:19-25, 3:1,17-18, I Peter 2:1, 5:1-4 

Secondary standards: WCF 15.6; 20.1-4; 22.1-6; 30.3; 31.1-3; WLC Q.99.6-8, 111-114, 130, 143-145, 151; WSC Q.14, 76-78; BCO Preface II.1,4; 8-1,-2,-3; 10-3; 11-2,-4; 13-9.e,f; 21-5.7; 31-2; 32-2,-6.b,-17; 34-3; 35-3 

Tertiary standards: RONR (12th ed.) 61:22; 63:7-9, 13, 35


RONR (12th ed.) 61:22; 63:7-9, 13, 35
Offenses Elsewhere Than in a Meeting; Trials
61:22 If improper conduct by a member of a society occurs elsewhere than at a meeting, the members generally have no first-hand knowledge of the case. Therefore, if disciplinary action is to be taken, charges must be preferred and a formal trial held before the assembly of the society, or before a committee—standing or special—which is then required to report its findings and recommendations to the assembly for action.
Steps in a Fair Disciplinary Process
63:7 For the protection of both the society and of its members and officers, however, the basic steps which, in any organization, make up the elements of fair disciplinary process should be understood. Any special procedures established should be built essentially around them, and the steps must be followed in the absence of such provisions. As set forth below, these are: (1) confidential investigation by a committee; (2) report of the committee, and preferral of charges if warranted; (3) formal notification of the accused; (4) trial; and (5) the assembly’s review of a trial committee’s findings (if the trial has been held in a committee instead of the assembly of the society).
63:8 Confidential Investigation by Committee. A committee whose members are selected for known integrity and good judgment conducts a confidential investigation (including a reasonable attempt to interview the accused) to determine whether to recommend that further action, including the preferring of charges if necessary, is warranted.
63:9 Accordingly, if the rules of the organization do not otherwise provide for the method of charge and trial, a member may, at a time when nonmembers are not present, offer a resolution to appoint an investigating committee.
63:13 Report of the Investigating Committee; Preferral of Charges. If after investigation the committee’s opinion is favorable to the accused, or if it finds that the matter can be resolved satisfactorily without a trial, it reports that fact. But if the committee from its investigations finds substance to the allegations and cannot resolve the matter satisfactorily in any other way, it makes a report in writing—which is signed by every committee member who agrees—outlining the course of its investigation and recommending in the report the adoption of resolutions preferring charges, arranging for a trial, and, if desired, suspending the rights of the accused …
63:35 Assembly’s Review of a Trial Committee’s Findings. If the trial has been held before a trial committee instead of the assembly of the society, this committee reports to the assembly in executive session (9) the results of its trial of the case, with resolutions—in cases where its finding is one of guilty—covering the penalty it recommends that the society impose. The report is prepared in writing and includes, to the extent possible without disclosing confidential information which should be kept within the committee, a summary of the basis for the committee’s finding. 

“Once you eliminate the impossible, whatever remains, no matter how improbable, must be the truth.” 

— Sir Arthur Conan Doyle 

“Now when an effect is more apparent to us than its cause, we reach a knowledge of the cause through its effect. Even though the effect should be better known to us, we can demonstrate from any effect that its cause exists, because effects always depend on some cause, and a cause must exist if its effect exists.” 

On Nature and Grace, Article Two, Thomas Aquinas 

“… we read, the priests sought false witnesses everywhere. At last two got up and said: ‘He said that he would rebuild the temple in three days.’
So we should not simply consider the words which may be said in evidence, but the intention of the speaker.
There is a good and useful lesson here, because men, we know, are so prone to malice and falsehood that any excuse is good enough for them. They think they are absolved in God’s sight when they falsely accuse someone in this way. We should not dwell only on what is said or on legal forms or ceremony: we must consider the merits of the case. Those who can always claim that the evidence they gave was strictly correct may nevertheless be counted as false witnesses before God, as we see here.”
Crucified and Risen: Sermons on Matthew 26-28, trans. Robert White, Sermon Three: “Arrest and Prosecution” (Matt. 26:51-66), pp. 47, 49  

“It was important that Judas should have made this confession: its effect was to make the priests even less excusable. The Evangelist thus relates this story so that we might understand more clearly the blindness which Satan inflicted on all these reprobates, and so that we might take thought to ourselves. When God presents us with such examples of his wrath and vengeance, and shows us men who in some ways are absolutely mad, deprived of sense or reason, and who are so brutish that they rush on with hellish rage, it is so that we might each bow our head and realize that often we too might end up there, if we were not preserved by God’s grace and goodness. Let us make sure that we do not fight against our consciences as the priests did, for all who harden their hearts against God will finally become so reprobate in mind that they will lose all reason; and having in God’s eyes exceeded all bounds, they will also cease in the eyes of men to feel the slightest shame. It is only right, therefore, that their depravity should be made known to everyone, and that they should suffer such disgrace that all should abhor their villainy. …
This is how hypocrites always seek to offer satisfaction, fancying that by these means they can redeem themselves. It is all a childish game.
We are told about this, however, so that when we do wrong we might truly acknowledge our faults and not beat around the bush, but freely and fully confess them. This is what we are taught here. And all the while let us pray that God may remove the blindfolds by which Satan tries to deprive us of our sight, so that we no longer languish in self-delusion and try to excuse our sin. Instead, may we more and more strive to examine all our failings honestly in order to condemn them and rightly to confess them. For the rest, we are also taught that God confounds the ideas of hypocrites, so that they fail in the end to attain their purpose. … And who did it? The priests and leaders of the people!
So we see that when hypocrites attempt to hide their misdeeds and to disguise themselves, God uncovers their evil all the more: he makes sure that their shame is made known to everyone, and that each of us abhors them. This was why I said that we should resolve to reveal all our transgressions, that God may be pleased to bury them in his and his angels’ sight, and in the sight of all men, once we have acknowledged them for ourselves.” 

— ibid., Sermon Four: Repentance and Remorse” (Matt. 26:67-27:14), pp. 66-68 

“The custom that a prisoner was released at the Passover shows us how far men will be led by their foolish devotions. It would seem that the feast was the more greatly honoured by the freeing of a prisoner, and that this was considered an act of worship to God. It was merely an abomination, for Scripture says that whoever justifies an offender is as guilty before God as the person who punishes the innocent (Prov. 17:15). Those whom God appoints to the seat of justice must be equitable, for in arming them with his sword God does not say to them, ‘Do as you please.’ His desire is that they take fatherly care of the people, and that they make sure they do not rise up and cruelly oppress others by misusing their influence and authority. They are to be merciful and compassionate.
Evildoers, however, must be punished, according to God’s command.” 

— ibid., Sermon Five: “This Man or Barabbas?” (Matt. 27:14-26), p. 79 

“God is the Master Engineer, He allows the difficulties to come in order to see if you can vault over them properly—‘By my God have I leaped over a wall.’ God will never shield you from any of the requirements of a son or daughter of His. Peter says—‘Think it not strange concerning the fiery trial which is to try you.’ Rise to the occasion; do the thing. It does not matter how it hurts as long as it gives God the chance to manifest Himself in your mortal flesh.” 

My Utmost for His Highest, Oswald Chambers, May 15 

Alex Krycek: “If Mulder is such a threat, why not eliminate him?”
The Cigarette Smoking Man: “That’s not our policy.”
Krycek: “It’s not? After what you had me do?”
CSM: “Kill Mulder and you risk turning one man’s religion into a crusade.” 

The X-Files, “Ascension,” Season 2, Episode 6