Case Summary (G.R. No. L-14116)
Petitioner
Monsignor Gregorio Aglipay, representing the Philippine Independent Church, alleges that the issuance and sale of the stamps violate the constitutional principle of separation of Church and State and constitute an improper appropriation of public property for sectarian purposes.
Respondent
Juan Ruiz, Director of Posts, who ordered the design, printing, issuance, and sale of the commemorative postage stamps under statutory authority.
Key Dates
• February 21, 1933 – Approval of Act No. 4052, appropriating funds for new postage-stamp designs.
• May 1936 – Public announcement of intended commemorative stamps.
• September 1, 1936 – Presidential approval of stamp issuance.
• March 13, 1937 – Decision date.
Applicable Law
• Constitution of the Philippines (Commonwealth), Article VI, Section 13(3): Prohibits appropriation of public money or property for sectarian purposes.
• Act No. 4052 (February 21, 1933): Appropriates ₱60,000 for plates and printing of postage stamps with new designs and authorizes the Director of Posts, with the Secretary’s approval, to dispose of funds “as often as may be deemed advantageous to the Government.”
• Code of Civil Procedure, Sections 516 and 226: Authorizes writ of prohibition against persons exercising functions “without or in excess of” jurisdiction.
Facts
The Director of Posts publicly solicited designs for stamps commemorating the Thirty-third International Eucharistic Congress and dispatched them to the United States for printing. Six denominations (2, 6, 16, 20, 36, 50 centavos) in various colors were produced, most remaining unsold. Aglipay sought a writ of prohibition to prevent further sale, asserting a constitutional violation. The Solicitor-General conceded that prohibition lies against ministerial acts beyond jurisdiction but contended this was not the proper remedy.
Issue
Whether the issuance and sale of postage stamps commemorating a Roman Catholic event constitute an unconstitutional use of public money or property for sectarian purposes, thereby exceeding statutory and constitutional authority.
Ruling
The petition for a writ of prohibition is denied. The Court finds no constitutional violation in the discretionary issuance and sale of the stamps.
Reasoning
- Scope of Writ of Prohibition – Under Sections 516 and 226 of the Code of Civil Procedure, the writ may issue against any officer whose acts exceed jurisdiction or violate the Constitution.
- Separation of Church and State – Article VI, Section 13(3) of the 1935 Constitution bars public funds or property for religious sects or clergy. This prohibition reflects a longstanding principle in Philippine charters and legislation.
- Statutory Authority – Act 4052 vested the Director of Posts, with cabinet approval, discretion to issue new-design stamps “advantageous to the Government.” The phrase does not authorize unconstitutional
Case Syllabus (G.R. No. L-14116)
Procedural History
- Petition filed by Mons. Gregorio Aglipay, Supreme Head of the Philippine Independent Church, seeking a writ of prohibition.
- Target of prohibition: Juan Ruiz, Director of Posts, to restrain issuance and sale of postage stamps commemorative of the Thirty-third International Eucharistic Congress.
- Solicitor-General’s position: writ of prohibition may restrain ministerial acts but questions its propriety in this context.
- Case submitted for decision with memoranda and correspondence between the parties, including Presidential approval letter (Exhibit A).
Facts of the Case
- In May 1936, the Director of Posts announced in Manila newspapers his intention to issue commemorative stamps for the Eucharistic Congress organized by the Roman Catholic Church.
- Petitioner’s reaction: Requested Vicente Sotto, Esq., to denounce the issuance to the President.
- Despite protest, respondent sent designs to the U.S. for printing: six denominations (2, 6, 16, 20, 36, 50 centavos) in various colors; design featured a chalice with grapevine and wheat border.
- Sales began; majority of printed stamps remained unsold at the time of the petition.
- Respondent estimated total revenue of ₱1,618,179.10, with ₱1,402,279.02 stamps unsold.
Legal Remedy and Statutory Basis
- Writ of prohibition: extraordinary remedy to restrain inferior tribunals, corporations, boards, or persons “without or in excess of jurisdiction” (Sections 516 and 226, Code of Civil Procedure).
- Distinction between judicial/quasi-judicial and ministerial acts recognized; statute covers both where jurisdiction is exceeded.
- Precedent: writ may issue to prevent oppressive or vindictive use of power or multiplicity of actions (Dimayuga and Fajardo vs. Fernandez, 43 Phil. 304).
Constitutional Provision Invoked
- Section 13, Subsection 3, Article VI, Constitution of the Philippines:
“No public money or property shall ever be appropriated, applied, or used, directly or indirectly, for the use, benefit, or support of any sect, ch