Here, the Iglesia Ni Cristo (INC or Church of Christ) can really claim victory.
The 2nd Division of the Court of Appeals (CA) has affirmed the legality of using public funds to print more than a million postage stamps to mark the 100th founding anniversary of the INC in 2014.
In a 10-page decision penned by Associate Justice Remedios Salazar-Fernando, the CA dismissed a petition filed by a certain Renato Peralta that sought to reverse an order issued by the Manila Regional Trial Court denying an injunction to stop the Philippine Postal Corp. (PhilPost) from paying for the printing of the commemorative stamps and to stop its distribution.
Associate Justices Priscilla Baltazar-Padilla and Socorro Inting concurred with the ruling.
Insisting that as a taxpayer he has the right to complain when there is a claim that public funds are illegally disbursed, Peralta turned to the CA where he argued that the printing and issuance of the INC centennial stamps violated Section 29 (2) Article VI of the 1987 Constitution, which bars the use of public funds to support a religious sect.
He argued that the postage stamps constitute a form of free advertisement for the church at the expense of taxpayers’ money.
The CA, however, said that what the 1987 Constitution prohibits was the giving of aid to a religious institution, not the mere entering into a transaction or an agreement where the State could benefit for itself.
It added that the stamps were not meant to help the INC because it was the government that benefited from it since proceeds from the sale of the stamps will go to the government, not to the religious group.
“Defendant-appellee PhilPost merely exercised its proprietary function and entered into a business transaction intended to generate income for the State, rather than bestow any grant or aid to the INC,” the CA ruled.
“It is not as if the government donated these stamps to the INC … Ultimately, it is the State which benefited from the issuance of these stamps, which could be bought by anyone,” it added.
The CA said not every government activity involving use of public funds and which has some “religious shade” violates the constitutional provisions regarding the separation of Church and State.
It cited the Lemon Test, the American doctrine on the separation of the Church and State, where public money can be made available to religious persons or institutions if the use will be for a secular purpose; neither primarily advance nor inhibit religion; and will not involve excessive government entanglement with religion.
“In this case… the stamps printed for a secular purpose… did not primarily advance religion. Likewise, the issuance of these stamps did not result in excessive entanglement by the government such as to require state monitoring, as these stamps were simply printed then sold to the public by defendant-appellee PhilPost,” the CA said.
It added that the purpose for printing the commemorative stamps “to enhance awareness of the INC’s contribution in national development” was a “legitimate secular purpose.”
The CA said there was nothing wrong in putting the late INC founder Felix Manalo’s portrait on the stamp.
“There is no question that the late Felix Y. Manalo is a prominent figure in Philippine History who deserves to be commemorated like any other Filipino here, statesman or national artist which is what defendant-appelle PhilPost has been doing in the design of its commemorative stamps,” it added.
The CA said the Philippine government recognizes Manalo’s significance in Philippine culture and history.
“No amount of bigotry or spite against INC can erode the historial and cultural significance to the nation of Felix Y. Manalo and the institution he founded,” it added.