First of two parts

THE normal daily routine of Metro Manila was disrupted and forced to follow the rhythm of the Iglesia Ni Cristo (INC) rally starting the morning of June 30, when thousands of INC members massed near the EDSA People Power Monument to protest the impending plunder and indirect bribery case against Sen. Rodante Marcoleta, one of the sect’s most prominent political figures. The Office of the Ombudsman has accused Marcoleta of failing to disclose P75 million in campaign contributions he received in early 2025, while he was still a sitting congressman, before he formally became a senatorial candidate. The crowd, estimated by the Quezon City Police District at more than 15,000 on the rally’s second day, blocked EDSA’s northbound lane using blue buses marked with New Era University and NET25. The police and the Metropolitan Manila Development Authority were both helpless in enforcing public order and traffic laws — to the detriment of thousands of commuters and motorists.

The rally’s permit for a third day in Quezon City was revoked, so organizers relocated to Liwasang Bonifacio in Manila, a freedom park that does not require a rally permit. Manila Mayor Isko Moreno suspended classes across all levels in the city just to accommodate the crowd — wasting a day in the academic calendars of learning institutions. Through INC spokesman Bro. Edwil Zabala, the group framed the action as a stand against what it called “selective justice” in the government’s handling of Marcoleta’s case. Ombudsman Jesus Crispin Remulla was unmoved, stating plainly that the filing of charges would proceed regardless of the demonstrations, and that no exception exists for anyone in his office’s docket. Malacañang, through Undersecretary Claire Castro, reminded the public that acquittal happens in court, not in the streets, even as it acknowledged the INC’s grievance about accountability more broadly.

This is not the INC’s first turn at mass mobilization to defend one of its own from State investigation. It is difficult to miss the parallels to its 2015 protests against then-justice secretary Leila de Lima, mounted after a former minister accused INC leaders of illegal detention. In both instances, the church (INC) invoked the same constitutional language and the same grievance — that the State was crossing a line it has no business crossing. Is that line being correctly located?

Constitutional provisions

The 1987 Constitution addresses the relationship between religion and government in more than one place, and as a lawyer, I owe it to the readers to be precise about which provision is actually applicable.

The often-quoted line is Article II, Section 6: “The separation of Church and State shall be inviolable.” This is a declaration of state principle, not, by itself, an enforceable right. It sits alongside Article III, Section 5 of the Bill of Rights, which bears the heavier constitutional weight: “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. No religious test shall be required for the exercise of civil or political rights.”

Other provisions reinforce the same architecture. Article VI, Section 29(2) bars the appropriation of public money or property for the use, benefit or support of any religion, minister or religious teacher, except when assigned to the armed forces, penal institutions, orphanages or leprosaria. Article IX-C, Section 2(5) disqualifies religious denominations and sects from registering as political parties. Article XIV, Section 3(3) allows optional religious instruction in public schools only at the written option of parents or guardians, at no cost to the government.

Read together, these provisions do not erect what the US tradition sometimes calls a “wall of separation.” The Philippine framework is narrower and more functional — government may not establish, fund or favor a religion and religion may not commandeer the machinery of the State. What the Constitution does not do is exempt religious institutions or their members, from generally applicable criminal and administrative law.

Separation of church and state doctrine

Separation of church and state, as a constitutional doctrine, operates in two directions at once. It prevents the government from legislating religious orthodoxy, funding religious activity, or using religious tests to award or deny civil rights. And it prevents religious institutions from wielding an accusation of “persecution” as a shield against otherwise valid legal proceedings, simply because the accused happens to be a person of faith or a member of a religious organization.

Philippine jurisprudence has settled on a specific interpretive lens for this balance called “benevolent neutrality (or accommodation).” In the landmark case of Estrada v. Escritor (AM P-02-1651, Aug. 4, 2003), and the 2006 resolution on motion for reconsideration), the Supreme Court, through Justice Reynato Puno, examined the tax exemption, optional-religious-instruction and preamble provisions carried across the 1935, 1973 and 1987 Constitutions, and concluded that Filipinos never intended to build a rigid wall between church and state. The court held that benevolent neutrality, not strict separation, is the spirit and framework underlying the Constitution’s religion clauses. Under this approach, government pursues its secular objectives while accommodating religious liberty to the fullest extent the Constitution allows, but accommodation is not automatic. It requires that the claimant show a sincere religious belief, that the state show a compelling interest before it may burden that belief, and that any restriction be the least restrictive means available.

To be concluded on July 11, 2026

News information were sourced from Rappler, Philstar.com, Philippine Daily Inquirer, GMA News Online and The Manila Times (June 30 to July 2, 2026). Legal discussions derived from the 1987 Philippine Constitution and cited Supreme Court decisions.

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