Peralta v. Phil.

Postal Corporation
G.R. No. 223395, December 4, 2018

FACTS:
 On May 10, 2014, respondent Philippine Postal Corporation (PhilPost) issued a stamp commemorating
Iglesia ni Cristo's (INC's) Centennial Celebration.
 The design of the stamp showed a photo of INC founder, the late Felix Y. Manalo (Manalo) with the
designation on 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 a two concentric circles
containing the words "IGLESIA Nl CRISTO CENTENNIAL 1914-2014".
 On June 16, 2014, petitioner Renato V. Peralta (petitioner) filed a complaint for injunction with the
Regional Trial Court (RTC), Br. 33 of 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.

ISSUE: Did the printing of the INC centennial commemorative stamps of the PPC undermine the inviolability of
the separation of Church and State?
RULING:
 No, the printing of the INC centennial commemorative stamps did not amount to a violation of the non-
establishment clause.
 There is no quibbling that as to the 50,000 stamps ordered, printed, and issued to the INC, the same did
not violate the Constitutional prohibitions separating State matters from religion.
 Per paragraph 5 and 6 of the MOA between Philpost and INC, the cost for the printing and issuance of the
aforesaid 50,000 stamps were all paid by INC. Any perceived use of government property, machines, or
otherwise, is de minimis and certainly do not amount to a state sponsorship of a specific religion.
 The centennial celebration of the Iglesia ni Cristo, though arguably involves religious institution, has a
secular aspect.
 The printing of the INC commemorative stamp is simply an acknowledgment of INC’s existence for a
hundred years. It does not necessarily equate to the State sponsoring the INC.
 The design of the INC commemorative stamp is merely an acknowledgment of the historical and cultural
contribution of the INC to the Philippine society.
 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 Y. Manalo is a Filipino
and that the INC is a Filipino institution. It bears to emphasize that the constitution establishes separation
of Church and state, not separation of religion and state.

Pasay City Alliance Church v. Benito

G.R. No. 226908

Facts:
Petitioner Pasay City Alliance Church (PCAC) is one of the local churches of its co-petitioner, Christian and
Missionary Alliance Churches of the Philippines (CAMACOP), a religious society registered with the Securities and
Exchange Commission.5

Respondent Fe P. Benito (Benito), on the other hand, is a licensed Christian Minister of CAMACOP.6 After
completing a degree in Religious Education from CAMACOP's Ebenezer Bible College and Seminary as one of
PCAC's scholars, Benito eventually served as PCAC's Head of Fellowship and Discipleship.7 In 2005, Benito was
appointed Head of PCAC's Membership and Evangelism Ministry, which was renamed Pastoral Care and
Membership in 2009.8 Benito served without a written contract.9 Pastoral Care and Membership is under the
supervision of the Church Ministry Team (CMT) and co-petitioner Reverend William Cargo (Rev. Cargo).10
The present controversy stemmed from CAMACOP and PCAC's policy requiring pastors or ministers without
written contracts to tender a courtesy resignation every year.

Issue:
By assuming jurisdiction of the termination case, did the NLRC violate the separation of the church and the State?

Ruling:
YES.
We disagree with the CA's interpretation that the non-renewal of Benito's appointment was due to her inefficiency
as an administrative officer for her ministry and, thus, purely secular. This conclusion ignores the significance of
Benito's position under contention, as the Head of Pastoral Care and Membership, fom1erly known as
Membership and Evangelism Ministry. It also overlooks the fine line between efficiency and effectiveness. Here,
the CMT cited failure on Benito's part to "share" with new attendees, Benito's inaction on the death of a member,
and several other administrative lapses that impact on the conduct of PCAC's ecclesiastical activities, such as
evangelism, baptism and Sunday praise or worship activities.

We hold that the termination of a religious minister's engagement at a local church due to administrative lapses,
when it relates to the perceived effectivity of a minister as a charismatic leader of a congregation, is a prerogative
best left to the church affected by such choice. If a religious association enacts guidelines that reserve the right to
transfer or reassign its licensed ministers according to what it deems be t for a particular congregation, ministry or
undertaking in pursuit of its mission, then the State cannot validly interfere.

CoTesCUP vs. Sec. of Education, G.R. No. 216930, Oct. 09, 2018
Facts:
 Petitioners in G.R. No. 218045 also claim that the provision on the use of MT violates the natural and
primary right and duty of parents in the rearing of the youth, recognized under Section 12, Article II of the
1987 Philippine Constitution. Petitioners aver that by using the MT in teaching the students, it compels
parents to do something utterly redundant, inefficient, and wasteful, as the students are presumably
already fluent in speaking their MT. In other words, they no longer need to be taught their native
language.

Issue: Does the provision of the K to 12 law (R.A. No. 10533) on the use of "mother tongue" violate the natural and
primary right and duty of parents in the rearing of the youth?

Ruling:
NO.
There is no conflict between the use of MT as a primary medium of instruction and the right of parents in rearing
their children.

While Section 12, Article II grants parents the primary right to rear and educate their children, the State, as parens
patriae, has the inherent right and duty to support parents in the exercise of this constitutional right. In other
words, parents' authority and the State's duty are not mutually exclusive but complement each other. 221 In the
matter of education, a parent is always the first teacher. The language first learned by the child or his "mother
tongue", which the child understands best and hence, an effective tool for further learning, is first and foremost
taught by the parent. The inclusion in the K to 12 Program of the MT as a medium of instruction and a subject in
the early years of learning is, therefore, not intended to curtail the parents' right but to complement and enhance
the same.

Moreover, despite the provision on the use of MT as primary medium of instruction for kindergarten and Grades 1
to 3, Filipino and English remain as subjects in the curriculum during the earlier stages of schooling and will later on
be used as primary medium of instruction from Grade 4 onwards. In other words, in addition to the MT, the basics
of Filipino and English will still be taught at the early stages of formal schooling; and should the parents, in the
exercise of their primary right and duty to rear their children, so desire to give additional Filipino and English
lessons to their children, they have the absolute right to do so. Nothing in the K to 12 Law prohibits the parents
from doing so.

Zabal vs. Duterte, G.R. No. 238467, February 12, 2019

FACTS:
 Petitioners filed a petition for prohibition and mandamus with application for TRO, Preliminary Injunction,
and/or Status Quo Ante Order against respondent Pres. Duterte, Executive Secretary Salvador C.
Medialdea, and Secretary Eduardo M. Año of the Department of Interior and Local Government (DILG).
 Sometime Feb. 2018, President Duterte first made public his plan to shut it down during a business forum
held in Davao.
 True to his words, President Duterte ordered the shutting down of the island in a cabinet meeting held on
April 4, 2018. This was confirmed by then Presidential Spokesperson Harry L. Roque, Jr. in a press briefing
the following day wherein he formally announced that the total closure of Boracay would be for a
maximum period of six months starting April 26, 2018.
 Petitioners, who were earning a living from the tourist activities in Boracay, claim that ever since the news
of Boracay's closure came about, fewer tourists had been engaging the services of Zabal and Jacosalem
such that their earnings were barely enough to feed their families. They fear that if the closure pushes
through, they would suffer grave and irreparable damage. 
 In their supplemental position, petitioners alleged the subject issue.

ISSUE: By issuing Proc. No 475, did the President intrude into the autonomy of the LGUs concerned?
RULING: No. The alleged intrusion of the President into the autonomy of the LG Us concerned is likewise too trivial
to merit this Court's consideration. Contrary to petitioners' argument, RA 10121 recognizes and even puts a
premium on the role of the LG Us in disaster risk reduction and management as shown by the fact that a number
of the legislative policies set out in the subject statute recognize and aim to strengthen the powers decentralized
to LGUs. This role is echoed in the questioned proclamation. (You can stop in this part)
The fact that other government agencies are involved in the rehabilitation works does not create the inference
that the powers and functions of the LGUs are being encroached upon. The respective roles of each government
agency are particularly defined and enumerated in Executive Order No. 53 and all are in accordance with their
respective mandates. Also, the situation in Boracay can in no wise be characterized or labelled as a mere local issue
as to leave its rehabilitation to local actors. Boracay is a prime tourist destination which caters to both local and
foreign tourists. Any issue thereat has corresponding effects, direct or otherwise, at a national level. This, for one,
reasonably takes the issues therein from a level that concerns only the local officials.