May it please the Court, my name is Wayne de Vera, and I represent the appellant United Free Artist of the

Philippines Inc. ( UFAPI ). We brought a petition for injunction with prayer for the issuance of a temporary restraining order against the Cultural Center of the Philippines (CCP) for yielding to the clamour of the Catholic Church and pressure from the Office of the President of the Republic to close down my clients exhibit or artworks. This case raises an issue on whether or not the closure of my clients exhibit violates his Constitutional right provided in Article III Section 4 which states that ; No law shall be passed abridging the freedom of speech, of expression, or the press, or the right of the people peaceably to assemble and petition the government for redress of grievances. The test of limitations on freedom of expression continues to be the CLEAR AND PRESENT DANGER RULE that words are used in such a circumstance and are of such a nature as to create a clear and present danger that they will bring about the substantial evils that a lawmaker has a right to prevent. The icons, images, and symbols although shown in a manner very much different from that in which they have been regularly depicted and portrayed does not create a clear and present danger requiring the prior restraint of the State. The government is neutral, and while protecting all, it prefers none, and it disparages none. Furthermore, the CCP should not yield to the clamour of the Catholic Church because of the existence of a valid contract entered into by my client and the CCP that both parties should observe diligently. And as stated on Article 1314 of the NCC: Any third person who induces another to violate his contract shall be liable for damages to the other contracting party. Clearly my client has no intention whatsoever to disrespect the Catholic Church in any way thru their art works, if they had intention of doing so they would not burden themselves in contracting with the CCP to facilitate their exhibit, they should just have posted their artworks in the internet which will give them more exposure and chances to show their disrespect to the Catholic Church globally. But no they brought their art works at the CCP to formally exhibit them, and be appreciated by those people who have great interest and value for the ART. Although it seems that those icons, images, and symbols were shown in a manner very much different from that in which they have been regularly depicted, it is just a mere product of an artist abstract and boundless imagination. If one of my peers would sit beside me and draw a picture of a naked woman in my notebook, I might tell him Bastos mo naman pre but if your peer happens to be an artist, and he does the same thing, you might ask him to indicate his initials and even have that drawing laminated or framed.