Political Law

Gregorio Aglipay vs Juan Ruiz

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G.R. No. L-45459 – 64 Phil. 201 – Political Law – Separation of Church and State – Religious Freedom

Political Law – Constitutional Law – The Legislative Department – Powers of Congress – Power of Appropriation – Appropriation for religious purposes not allowed

The 33rd International Eucharistic Congress organized by the Roman Catholic Church took place sometime in 1936. In commemoration thereof, then Director of Posts, Juan Ruiz, initiated the production of certain stamps the design of which would have in their center a chalice, with grape and stalks of wheat as border design. Eventually, the stamps were produced and some were sold pursuant to Act No. 4052, which provides for appropriation.

Gregorio Aglipay, the head of the Philippine Independent Church, assailed the production and sale of such stamps. Aglipay contends that the funding of said stamps commemorative to a particular religious event is in violation of Sec 13, Article 6 of the Philippine Constitution which prohibits the appropriation or usage of public money for the use or benefit of any church or denomination.

ISSUE: Whether or not the production of the said stamps violate the Constitution.

HELD: No. The sale of stamps is not in violation of the Constitution. In fact, what was emphasized on the stamps was not the religious event itself but rather the City of Manila as being the seat of such event. Act No. 4052 on the other hand did not appropriate any public money to a religious event. Act No. 4052 appropriated the sum of P60,000.00 for the cost of plates and printing of postage stamps with new designs and other expenses incident thereto, and merely authorizes the Director of Posts, with the approval of the Secretary of Public Works and Communications, to dispose of the amount appropriated in the manner indicated and “as often as may be deemed advantageous to the Government”. The fact that the fund is being used for such is only incidental to the function of Director of Posts and under his discretion.

On religious freedom

The Supreme Court noted however that the elevating influence of religion is recognized here as elsewhere. Evidence would be our preamble where we implored the aid of divine providence to establish an ideal government. If should also be further noted that religious freedom as a constitutional mandate is not an inhibition of profound reverence to religion.

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