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29 Case Digest

The Supreme Court ruled that the production of stamps commemorating the 1936 International Eucharistic Congress held in Manila did not violate the Philippine Constitution. While the stamps featured religious symbols, their purpose was to promote Manila as the host city, not the religious event itself. Additionally, the public funds used came from an appropriation to the Director of Posts for stamp production expenses, not direct funding of the Congress. While the Constitution prohibits public funding of churches, it does not prevent incidental references to religion or implore divine guidance in governance.

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81 views

29 Case Digest

The Supreme Court ruled that the production of stamps commemorating the 1936 International Eucharistic Congress held in Manila did not violate the Philippine Constitution. While the stamps featured religious symbols, their purpose was to promote Manila as the host city, not the religious event itself. Additionally, the public funds used came from an appropriation to the Director of Posts for stamp production expenses, not direct funding of the Congress. While the Constitution prohibits public funding of churches, it does not prevent incidental references to religion or implore divine guidance in governance.

Uploaded by

Abju Haree
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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Aglipay v.

Ruiz,
G.R. No. L-45459, March 13, 1937

FACTS:
 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 this case, 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.
De Leon
What is guaranteed by the Constitution is religious liberty, not mere religious toleration.

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