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These are all original case digests or case briefs done while the author was studying law school in the Philippines.

Hopefully these digested cases will help you get a good grasp of the salient facts and rulings of the Supreme Court in order to have a better understanding of Philippine Jurisprudence.

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Saturday, June 13, 2015

American Bible Society v City of Manila (1957)


American Bible Society v City of Manila GR No. L-9637, April 30, 1957

FACTS:
In the course of its ministry, the Philippine agency of American Bible Society (a foreign, non-stock, non-profit, religious,

missionary corporation) has been distributing and selling bibles and/or gospel portions thereof throughout the Philippines. The acting City Treasurer of Manila informed plaintiff that it was conducting the business of general merchandise since November 1945, without providing itself with the necessary Mayor’s permit and municipal license, in violation of Ordinance No. 3000, as amended, and Ordinances Nos. 2529, 3028 and 3364. The society paid such under protest and filed suit questioning the legality of the ordinances under which the fees are being collected.

ISSUES:
  1. Whether or not the ordinances of the City of Manila are constitutional and valid
  2. Whether the provisions of said ordinances are applicable or not to the case at bar
RULING:
1. Yes, they are constitutional. The ordinances do not deprive defendant of his constitutional right of the free exercise and 
enjoyment of religious profession and worship, even though it prohibits him from introducing and carrying out a scheme or purpose which he sees fit to claim as part of his religious system. It seems clear, therefore, that Ordinance No. 3000 cannot be considered unconstitutional, even if applied to plaintiff society.

2. The ordinance is inapplicable to said business, trade or occupation of the plaintiff. Even if religious groups and the press are not altogether free from the burdens of the government, the act of distributing and selling bibles is purely religious and does not fall under Section 27e of the Tax Code (CA 466). The fact that the price of bibles, etc. are a little higher than actual cost of the same does not necessarily mean it is already engaged in business for profit. Thus, the Ordinances are not applicable to the Society. 

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