The governing body of Washington area Presbyterianism has opened the way for one dissident congregation to move, with its property, to another more conservative denomination, but set the stage for a possible legal battle with a second rebel congregation.

The National Capital Union Prebytery voted overwhelmingly Tuesday to permit the Church of the Atonement in Silver Spring to transfer from the mainline Presbyterian body into the smaller and more conservative Associate Reformed Presbyterian Church.

But the presbytery took steps to reclaim the property of Wallace Memorial Presbyterian Church in Hyattsville by empowering a special commission "to take such emergency action as may be necessary. . . ."

In Presbyterism, the property of a local congregation is considered to be held in trust for the denomination and, should the congregation withdraw, the property reverts to the denomination unless the governing body makes an exception.

Both Atonement and Wallace Memorial congregations voted earlier this spring to sever ties with the United Presbyterian Church in the USA and the Presbyterian Church in the US, the two national denominations of which the National Capital Union Presbytery is a local unit.

Their respective actions were taken because of growing differences with the parent denominations over theology and stands on social issues, such as the role of women in church and society.

Atonement's decision, however, was made in a March 15 congregational meeting after considerable consultation with the presbytery. Wallace Memorial's vote on March 30 to pull out came as a surprise to denominational officials.

The Rev. Dr. Edward White, presbytery executive, said that "is the difference between divorce and desertion."

There were no official representatives from Wallace Memorial at Tuesday's presbytery meeting, even though, presbytery officials said, the church had been notified that the future of the congregation was on the agenda. But a member of Wallace Memorial, Morris Snyder, told the withdrawing from the denomination "had to do with the way some churches [withdrawing from the denomination] have been treated in other presbyteries," where, he charged, presbytery officials have taken over the property and locked out dissidents.

The Rev. Glen Knecht, pastor of Wallace Memorial, said yesterday that the congregation intends "to carry on our work right here." Asked if the church would involve itself in a legal battle for the property, he said, "That's something we have to discover."