Iglesia Ni Cristo vs.

Court of Appeals
G.R. No. 119673. July 26, 1996

Nature: Petition for review

Ponente: Puno
Petitioner: IGLESIA NI CRISTO
Respondents: THE HONORABLE COURT OF APPEALS, BOARD OF REVIEW FOR
MOVING PICTURES AND TELEVISION and HONORABLE HENRIETTA S. MENDEZ

Facts:

Petitioner Iglesia ni Cristo (INC), a duly organized religious organization, has a television
program entitled Ang Iglesia ni Cristo aired every Saturday and Sunday. The program presents
and propagates petitioners religious beliefs, doctrines and practices oftentimes in comparative
studies with other religions.
Sometime in September 1992, petitioner submitted to the respondent Board of Review
for Moving Pictures and Television (Board) VTR tapes of several of its TV program series. The
Board classified the series as X or not for public viewing on the ground that they offend and
constitute an attack against other religions which is expressly prohibited by law.
On December 14, 1992, petitioner filed a case against the respondent Board, at the
Regional Trial Court of Quezon City (RTC-QC), alleging that the Board acted without
jurisdiction or with grave abuse of discretion in requiring petitioner to submit the VTR tapes of
some of its TV programs and in X-rating them. Petitioner contended that religious programs, like
Ang Iglesia ni Cristo, should not be under the jurisdiction of the Board because otherwise, it
will contravene the Constitutional provision of the free exercise of religion. The RTC-QC
rendered judgment in favor of the petitioner.
The respondent Board appealed to the Court of Appeals (CA) where it reversed the
decision of the trial court. The CA ruled that the Board has jurisdiction and power to review the
TV program Ang Iglesia ni Cristo. Hence, the petition for review at the Supreme Court.

Issue: Whether a religious TV program is protected by the Constitution under its freedom of
religion provision which qualifies all of its broadcasts exempted from any review.

Disposition: No. Petition denied.

Ruling:
Section 5 of Article III of the Constitution guarantees that no law shall be made
respecting an establishment of religion, or prohibiting the free exercise thereof. The free exercise
and enjoyment of religious profession and worship, without discrimination or preference, shall
forever be allowed.
The freedom that the Constitution above mentioned is freedom from conformity to
religious dogma, not freedom from conformity to law because of religious dogma. The exercise
of religious freedom can be regulated by the State when it will bring about the clear and present
danger of some substantive evil which the State is duty bound to protect i.e., serious detriment to
the more overriding interest of public moral and welfare.
Since the TV program Ang Iglesia ni Cristo can be viewed by the public at large, it
would create war between followers of INC and the other religious sects, whom their criticisms
are directed. This war is not impossible to ensue considering the countrys warring religious
beliefs and the fanaticism with which some of us cling and claw.
Thus, the TV program Ang Iglesia ni Cristo should be reviewed.