AGLIPAY v.

RUIZ
G.R. No. 45459
March 13, 1937

TOPIC IN CONTEXT: Section 6: Separation of Church and State

Facts of the Case

The 33rd International Eucharistic Congress was held in Manila under the sponsorship
of the Catholic Church, and the government had authorized a special stamp issue to
commemorate the occasion. The petitioner, who is the leader of the Philippine
Independent Church, opposed the bill and said that it was unconstitutional because it
benefitted a particular religion; as a result, he attempted to prohibit the printing and
distribution of stamps honoring the occasion.

Issue at Bar
Whether or not the authorized stamp issue be declared invalid for violating the principle
of Separation of Church and State.

Ruling of the Court

NO. The Supreme Court discovered after reviewing the background information that
although the stamp's original design included a Catholic chalice, this was later
abandoned in favor of a map of the Philippines with the caption, "Seat XXXIII
International Eucharistic Congress, Feb. 3-7, 1937." Manila, as the congress's location,
was therefore emphasized rather than the Eucharistic Congress itself. The creation of
the disputed postage stamps wasn't inspired by any particular religion. The stamps were
not issued and sold for the benefit of the Roman Catholic Church; the primary goal was
"to advertise the Philippines and attract more tourists to this country." The proceeds
from the sale of the stamps weren't either donated to that church.

While it is evident that the issuance and sale of the disputed stamps can be said to be
inextricably associated with a religious event, the government's goal and purpose were
not the advertising that the Roman Catholic Church might receive as a result, if any. If
the intended aim is one that may lawfully be carried out by suitable laws, the
government should not be embarrassed by incidental effects that are more or less
religious in nature. The primary goal shouldn't be frustrated by being subordinate to
unexpected incidental outcomes.

Therefore, the stamp issue was held to be not invalid.