B2-ATACADOR, CRISTIAN GREGOR E.

Case Digest 5 (October 1, 2022 Session)

G.R. NO. 223395 I DECEMBER 4, 2018 I PERALTA VS. PHIL. POSTAL CORPORATION
On the reason for the doctrine of Separation of Church and State
FACTS:
On May 10, 2014, respondent Philippine Postal Corporation (PhilPost) issued a stamp
commemorating Iglesia ni Cristo's (INC's) Centennial Celebration. Renato V. Peralta (petitioner)
filed a complaint assailing the constitutionality of the printing, issuance and distribution of the
INC commemorative centennial stamps, allegedly paid for by respondent PhilPost using public
funds. 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.
ISSUE/S:
Whether the printing of the INC centennial commemorative stamps by the PPC undermine
freedom of religion?
RULES & APPLICATION
Fundamental to the resolution of this case is the policy of the State on the inviolability of the
principle of separation of the church and the state. Justice Isagani Cruz explained the rationale of
this principle in this wise:
The rationale of the rule is summed up in the familiar saying, "Strong fences make good
neighbors." The idea is to delineate the boundaries between the two institutions and, thus, avoid
encroachments by one against the other because of a misunderstanding of the limits of their
respective exclusive jurisdictions. The demarcation line calls on the entities to "render therefore
unto Caesar the things that are Caesar's and unto God the things that are God's."
The 1987 Constitution expressly provides for the following provisions, giving life to the policy
of separation of the Church and the State.
CONCLUSION:
The petition is denied. The printing and issuance of the assailed commemorative stamps were not
inspired by any sectarian denomination. 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.