Primary Holding

The Supreme Court held that the flag ceremony is not a religious act and that the Department of Education's requirement for students to participate does not violate the constitutional guarantee of religious freedom.

Background

Petitioners, members of Jehovah's Witnesses, refused to let their children participate in the flag ceremony at public schools, citing religious beliefs. The children were expelled, leading to a legal challenge against the Department of Education's order mandating the flag ceremony.

Facts

• 1. Petitioners are Jehovah's Witnesses who believe saluting the flag violates their religious beliefs.
• 2. Their children were expelled from public schools for refusing to participate in the flag ceremony.
• 3. Petitioners sought exemption from the flag ceremony, which was denied by the Secretary of Education.
• 4. They filed a lawsuit challenging the constitutionality of Department Order No. 8.

Arguments of the Petitioners

• 1. The flag ceremony violates their religious beliefs, as they consider the flag an "image" forbidden by their religion.
• 2. They argued that the requirement to salute the flag, sing the national anthem, and recite the patriotic pledge infringes on their constitutional right to religious freedom.
• 3. They requested an exemption from participating in the flag ceremony.

Arguments of the Respondents

• 1. The flag ceremony is a non-religious act aimed at fostering patriotism and national unity.
• 2. The requirement is a reasonable regulation necessary for maintaining school discipline and civic responsibility.
• 3. The Department of Education has the authority to enforce such regulations under Republic Act No. 1265.

Issues

• 1. Whether the flag ceremony violates the constitutional right to religious freedom.
• 2. Whether the Department of Education's order mandating the flag ceremony is constitutional.

Ruling

• 1. The Supreme Court ruled that the flag ceremony is not a religious act and does not violate the constitutional guarantee of religious freedom.
• 2. The flag is a symbol of national sovereignty and unity, and saluting it is an act of patriotism, not religious veneration.
• 3. The Court emphasized that the freedom of religious belief does not exempt individuals from complying with reasonable and non-discriminatory laws.
• 4. The Court upheld the Department of Education's authority to enforce the flag ceremony as a means of promoting civic responsibility and national unity.

Doctrines

• 1. Freedom of Religion: The Constitution guarantees freedom of religious belief, but this does not exempt individuals from complying with reasonable laws.
• 2. State Authority in Education: The state has the authority to regulate educational institutions and enforce rules that promote civic responsibility and national unity.

Key Excerpts

• 1. "The flag is not an image but a symbol of the Republic of the Philippines, an emblem of national sovereignty, of national unity and cohesion and of freedom and liberty which it and the Constitution guarantee and protect."
• 2. "The freedom of religious belief guaranteed by the Constitution does not and cannot mean exemption from or non-compliance with reasonable and non-discriminatory laws, rules and regulations promulgated by competent authority."

Precedents Cited

• 1. Reynolds vs. U.S. (98 U.S. 145): Upheld the validity of laws prohibiting polygamy, even against religious beliefs.
• 2. Hamilton vs. University of California (293 U.S. 243): Upheld the requirement of military training in state universities, even for conscientious objectors.
• 3. Minersville School District vs. Gobitis (310 U.S. 586): Initially upheld the requirement for students to salute the flag, but was later overturned.
• 4. West Virginia State Board of Education vs. Barnette (319 U.S. 624): Overturned Gobitis, ruling that compulsory flag salutes violate religious freedom.

Statutory and Constitutional Provisions

• 1. Article XIV, Section 5 of the Constitution: Charges the state with the supervision and regulation of all educational institutions.
• 2. Republic Act No. 1265: Makes flag ceremonies compulsory in all educational institutions.