3. People vs. Mandoriao, Jr.

C.A., 51 O.G. 4619

FACTS: The Iglesia ni Cristo held a religious rally at a public place in Baguio. About 200 people attended
the meeting, about 50 of whom were members of the Iglesia ni Cristo but the rest were outsiders and
curious listeners. While Salvio, a minister of Iglesia ni Cristo, was expounding on his topic to the effect that
Christ is not God, but only man, the crowd became unruly. Some people urged Mandoriao to go up the
stage and have a debate with Salvio. Mandoriao however, was not able to speak before the microphone
because the wire connecting it was abruptly disconnected.

ISSUE: Whether or not the meeting was a religious ceremony.

HELD: The meeting here was not a religious ceremony. A religious meeting is an “assemblage of people
meeting for the purpose of performing acts of adoration to the Supreme Being, or to perform religious
services in recognition of God as an object of worship…” The meeting here was not limited to the members
of the Iglesia ni Cristo. The supposed prayers and singing of hymns were merely incidental because the
principal object of the rally was to persuade new converts to their religion. Assuming that the rally was a
religious ceremony, the appellant cannot be said to have performed acts or uttered words offensive to
the feelings of the faithful. The act complained of must be directed against a dogma or ritual, or upon an
object of veneration. There was no object of veneration at the meeting.

Reyes Book II, page 80:

When the application of the Iglesia ni Cristo was to hold the meeting at a public place and the permit
expressly stated that the purpose was to hold a religious rally, what was held on that occasion was not a
religious ceremony, even if a minister was then preaching (“that Jesus Christ was not God but only a
man”). The rally was attended by persons who are not members of the sect.

Reyes Book II, page 81:

Remarks that those who believed that Christ is God are anti-Christ, that all the members of the Roman
Catholic Church are marked by the demon, and that the Pope is the Commander of Satan are notoriously
offensive to the feelings of the faithful.