Case Summary (G.R. No. 223395)
RTC Proceedings
• Petition for TRO (June 2014) denied.
• Respondents asserted no public funds were disbursed; costs borne by INC under a May 7, 2014 Memorandum of Agreement (MOA).
• PhilPost contended the stamp was a philatelic product promoting tourism; any sectarian benefit incidental.
• RTC denied preliminary injunction and dismissed the action (July 2014), ruling no violation of Article VI, Section 29(2) and that it was not a taxpayer suit.
CA Proceedings
• Petitioner appealed; CA classified it as a taxpayer suit but held no constitutional violation (July 24, 2015).
• CA found intrinsic historical value in the stamp design and upheld the MOA arrangement.
• Motion for reconsideration denied (March 8, 2016).
Issue Before the Supreme Court
Whether the issuance and sale of INC commemorative stamps violated the anti-establishment provisions (Article III, Section 5) and the prohibition on using public funds for religious benefit (Article VI, Section 29(2)) under the 1987 Constitution.
Justiciability
• Actual case or controversy existed: petitioner alleged direct injury from PhilPost’s actions under Presidential Proclamation No. 815.
• Mootness did not bar review under exceptions: alleged grave constitutional violation, public interest, need for guiding principles, and capability of repetition yet evading review.
Legal Standing
• Petitioner sufficiently alleged illegal use of public funds: only 50,000 of 1,200,000 stamps were paid for by INC; remaining 1,150,000 allegedly funded by PhilPost’s government resources.
• Recognized as a taxpayer’s suit to prevent illegal disbursement under Mamba v. Lara.
Non-Establishment Clause Analysis
• The State must maintain benevolent neutrality without hostility or indifference to religion.
• Historical jurisprudence (Aglipay v. Ruiz) permits incidental religious references if the primary purpose is secular.
• Philippine jurisprudence balances separation with recognition of religion’s cultural role.
Application of Article VI, Section 29(2)
• Prohibition targets appropriation of public money primarily for religious benefit.
• The cost of the 50,000 stamps was fully borne by INC under the MOA; incidental use of PhilPost facilities de minimis.
• Remaining stamps were sold commercially; proceeds did not inure to INC.
• PhilPost’s actions did not involve exclusive or continuous support to INC at the expense of other religions.
Design and Purpose of the Stamp
• Design acknowledged INC as
Case Syllabus (G.R. No. 223395)
Antecedents
- On May 10, 2014, PhilPost issued a centennial commemorative stamp for Iglesia ni Cristo (INC) featuring Felix Y. Manalo’s portrait, his designation, the INC Central Temple, and the INC centennial logo.
- Renato V. Peralta filed a complaint for injunction on June 16, 2014 before the RTC of Manila, challenging the printing, issuance, and distribution of the INC stamps as an unconstitutional use of public funds.
- Peralta alleged violations of Article VI, Section 29(2) (prohibiting public funds for sectarian use) and the non-establishment clause of Article III, Section 5 (prohibiting laws respecting an establishment of religion).
- PhilPost contended no public funds were used, citing a May 7, 2014 MOA whereby INC would shoulder all printing costs; any sectarian benefit was merely incidental to a broader philatelic program.
Complaint and Lower Court Proceedings
- The RTC denied Peralta’s TRO application (June 23, 2014), then denied a preliminary injunction and dismissed the action (July 25, 2014).
- The RTC held the suit was not a taxpayer’s suit and found no violation of Section 29(2), Article VI.
- Peralta appealed to the Court of Appeals (CA).
Court of Appeals Proceedings
- On July 24, 2015, the CA in CA-G.R. CV No. 103151 denied Peralta’s appeal, ruling that:
- The suit was a taxpayer’s suit; but
- The issuance of the commemorative stamp did not violate the constitutional separation of church and State or use of public funds for religious purposes.
- A motion for reconsideration was denied in a March 8, 2016 Resolution.
Petition for Review on Certiorari
- Peralta elevated the case to the Supreme Court under Rule 45, contesting the CA’s decisions for failing to recognize the stamp design as primarily religious and thus unconstitutional.
Issues
- Whether printing, issuance, and distribution of the INC centennial stamps violated Article VI, Section 29(2) by employing public money or property for relig