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Political Law; Constitutional Law; Separation of Church and State

RE: LETTER OF TONY Q. VALENCIANO, HOLDING OF RELIGIOUS RITUALS


AT THE HALL OF JUSTICE BUILDING IN QUEZON CITY
AM No. 10-4-19-SC March 7, 2017; EN BANC; MENDOZA, J. - PONENTE

BRIEF SUMMARY OF THE CASE:

In 2009, Valenciano sent a series of letters addressed to then Chief


Justice Puno alleging that the exercise of religious worship at the Hall of
Justice (Justice Hall) in Quezon City violates the constitutional principle of
separation of church and state. The first Letter contains that the basement of
the Justice Hall had been converted into a Roman Catholic Chapel. Masses
were held in said basement, and that the court employees became hostile
toward each other as they vied for the right to read the epistle. The second
letter comprises of a prayer by Valenciano that rules be promulgated by the
Court to put a stop to the holding of Catholic masses or any other religious
rituals.
RTC Executive Judge Sagun, Jr. addressed the complaints of Valenciano
informing the Court that his office had already implemented measures for it –
including that masses were shortened to a little over thirty (30) minutes; that it
was only during special holy days of obligation when the celebration of mass
went beyond one (1) o'clock in the afternoon; and that the court employees
prepared for the mass before the day officially started, so that the performance
of their official duties in court was not hampered.
MeTC Executive Judge Lutero, in her Letter-Comment, opined that it is
not the conduct of masses in public places which the Constitution prohibited,
but the passage of laws or the use of public funds for the purpose of
establishing a religion or prohibiting the free exercise thereof.
In its decision, the Supreme Court denied that the holding of religious
rituals of any of the world's religions in the QC Hall of Justice or any halls of
justice all over the country be prohibited. The prohibition embodied in the
Constitution contemplates a scenario where the appropriation is primarily
intended for the furtherance of a particular church, wherein in this case is
absent.
Political Law; Constitutional Law; Separation of Church and State

DISSENTING OPINION by JUSTICE LEONEN:

On Separation of Church and State

By holding daily Catholic masses or any religious ritual within court


premises, courts unnecessarily shed their impartiality. It weakens the
commitment to protect all religious beliefs.

Courts are not simply venues for the resolution of conflict. Halls of
Justice should symbolize the adherence to the majesty and impartiality of the
rule of law. Unnecessary sponsorship of religious rituals undermines the
primacy of secular law and its impartiality. It consists of physical
manifestations of a specific kind of belief which can best be done in private
churches and chapels, not in a government building.

Allowing masses to be held within Halls of Justice have no other purpose


except to allow a sect, or religious denomination to express its beliefs. The
primary purpose of the policy that is favored by the majority of this Court is
not secular in nature, but religious. This is contrary to the existing canons of
our Constitutional law.

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