Peralta v. PhilPost

RENATO V. PERALTA, PETITIONER V.
PHILIPPINE COASTAL CORPORATION

(PHILPOST), REPRESENTED BY MA. JOSEFINA M. DELACRUZ IN HER CAPACITY AS
POSTMASTER GENERAL AND CHIEF EXECUTIVE OFFICER
G.R. No. 223395, December 4, 2018
(We will focus on the concept of separation of church and state and the application of the Lemon test to
determine if the non-establishment clause is violated)
Tijam, J.:
Facts
On May 10, 2014, respondent Philippine Postal Corporation (PhilPost) issued a stamp commemorating
Iglesia ni Cristo’s Centennial Celebration. The design of the stamp showed a photo of INC founder, the
late Felix Manalo (Manalo) with the designation of the left side containing the words “Felix Y. Manalo,
1886-1963 First Executive Minister of Iglesia ni Cristo,” with the Central Temple of the religious group at
the background. At the right side of Manalo’s photo is the INC’s centennial logo which contained a torch
enclosed by two concentric circles containing the words “Iglesia ni Cristo Centennial 1914-2014”.
On June 16, 2014, petitioner Renato Peralta filed a complaint for injunction with the RTC-Manila
assailing the constitutionality of the printing, issuance and distribution of the INC commemorative
centennial stamps, allegedly paid for by respondent PhilPost using public funds.
Petitioner alleged that the printing and issuance of the INC commemorative stamp involved disbursement
of public funds and violated Section 29 (2) of Article VI of the 1987 Constitution. He argued that
respondents’ act of releasing the said stamps was unconstitutional because it was tantamount to
sponsorship of a religious activity; it violated the separation of the Church and the State; and the
non-establishment of religion clause. Thus, petitioner prayed that respondents be restrained from issuing
and distributing the INC commemorative stamps.
RTC: denied the petitioner’s application for the issuance of a preliminary injunction
CA: affirmed the RTC decision; the Motion for Reconsideration was also denied.
Issue
1. Did the respondents (PhilPost) violate the non-establishment of religion clause (by printing of the
INC commemorative stamp) provided in the Art. III, Section 5 of the 1987 Constitution?
Ruling
Examination of jurisprudence, both here and in the United States, as well as the context over which this
stamp has been issued, inevitably leads this Court to agree with the CA, and uphold the issuance of the
INC commemorative stamp.
As apparent from the Constitution, the “wall” between the Church and the State exists along with the
recognition of freedom of religion. In fact, review of jurisprudence would reveal that this Court has
carefully weighed these principles as to allow the broadest exercise of religious freedom without
infringing the non-establishment clause.
Where the court has been asked to determine whether there has been an undue encroachment of this
Constitutionality forged “wall”, this Court has adopted a stance of “benevolent neutrality”. This
incorporates the Constitutional principle of separation of the Church and the State while recognizing the
people’s right to express their belief or non-belief of a Supreme being.
The “Lemon Test” which has been extensively applied by the U.S. Supreme Court in issues involving the
determination of non-establishment of religion clause. The Court used a three-pronged test to adjudge
whether the assailed governmental act violated the First Amendment, as follows:
1. The statute must have a secular legislative purpose;

2. Its principal or primary effect must be one that neither advances nor inhibits religion; and
3. The statute must not foster “an excessive government entanglement with religion.
Adopting the stance of benevolent neutrality, this Court deems the design of the INC commemorative
stamp constitutionally permissible. As correctly held by the CA, there is an intrinsic historical value in the
fact that Felix Manalo is a Filipino and that the INC is a Filipino institution.
Based on the foregoing, this Court is not convinced that PhilPost has actually used its resources to
endorse, nor encourage Filipinos to join INC or observe the latter's doctrines. On the contrary, this Court
agrees with respondents that the printing of the INC commemorative stamp was endeavored merely as
part of PhilPost's ordinary business.
All told, therefore, the Court finds no reason or basis to grant the petition. In refusing to declare
unconstitutional the INC's commemorative stamp, this Court is merely applying jurisprudentially
sanctioned policy of benevolent neutrality. To end, it bears to emphasize that the Constitution establishes
separation of the Church and the State, and not separation of religion and state.

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RENATO V. PERALTA, PETITIONER V.

PHILIPPINE COASTAL CORPORATION

1. The statute must have a secular legislative purpose;

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