Case Digest (G.R. No. 223395) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Renato V. Peralta v. Philippine Postal Corporation, petitioner Renato V. Peralta challenged the printing, issuance, and sale of a commemorative stamp honoring the Iglesia ni Cristo (INC) Centennial, designed with the photo of its founder Felix Y. Manalo, the INC centennial logo, and the Central Temple in the background. On May 10, 2014, PhilPost issued the stamp. On June 16, 2014, Peralta filed with the Regional Trial Court (RTC), Branch 33, Manila, a complaint for injunction under Section 29(2), Article VI of the 1987 Constitution, arguing that public funds were used to “sponsor a religious activity” and to violate the non-establishment clause. After a hearing, the RTC denied his application for a temporary restraining order on June 23, 2014, and on July 25, 2014, denied his preliminary injunction and dismissed the suit. The Court of Appeals (CA), in CA-G.R. CV No. 103151, affirmed on July 24, 2015, and denied reconsideration on March 8, 2016. Peralta then filed this petitio Case Digest (G.R. No. 223395) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedents
- On May 10, 2014, the Philippine Postal Corporation (PhilPost) issued a commemorative stamp marking the 100th anniversary of Iglesia ni Cristo (INC), featuring:
- A portrait of INC founder Felix Y. Manalo (1886–1963) with the caption “First Executive Minister of Iglesia ni Cristo.”
- The INC Central Temple in the background and the INC centennial logo.
- On June 16, 2014, Renato V. Peralta (petitioner) filed with the RTC, Branch 33, Manila, a complaint for injunction alleging:
- Violation of Section 29(2), Article VI of the 1987 Constitution (use of public funds to benefit a religious sect).
- Breach of the non-establishment clause and separation of Church and State.
- Procedural History
- RTC denied petitioner’s application for a Temporary Restraining Order (June 23, 2014), then denied a preliminary injunction and dismissed the complaint (July 25, 2014).
- Petitioner appealed to the Court of Appeals (CA), which:
- Denied relief in its Decision dated July 24, 2015.
- Denied reconsideration in its Resolution dated March 8, 2016.
- Petitioner filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court (G.R. No. 223395, Dec. 4, 2018).
Issues:
- Substantive Constitutional Issues
- Whether the printing, issuance, and sale of the INC centennial stamps involved public funds in violation of Section 29(2), Article VI of the 1987 Constitution.
- Whether the design and distribution of the stamp breached the non-establishment clause (Article III, Section 5) and the inviolable separation of Church and State (Article II, Section 6).
- Justiciability and Standing
- Whether there was an actual case or controversy and the issue was ripe for adjudication.
- Whether petitioner, as a taxpayer, had the requisite standing to challenge the alleged misuse of public funds.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)