2. People vs. Reyes, et al.

C.A.-G.R. No. 13633-R, July 27, 1955

FACTS: The Iglesia ni Cristo held a meeting at a public plaza after securing a permit to do so from the
mayor. The meeting started with some singing, after which the minister (Sanidad) of the sect read from
the Bible and then delivered a sermon, in the course of which he attacked the Catholic and Aglipayan
churches, as well as the women of San Esteban, Ilocos Sur. The Chief of Police ordered his policemen to
stop the minister. When the minister refused, the Chief of Police fired two shots in the air which dispersed
the crowd and stopped the meeting.
ISSUE: Whether or not the Chief of Police is liable under Article 132 (Interruption of religious worship) of
the Revised Penal Code.
HELD: The act of the Chief of Police is not a violation of Article 132 (Interruption of religious worship), but
of Article 131 (Prohibition, interruption, and dissolution of peaceful meetings).

Reyes Book II, page 78:
The Chief of Police who ordered the speaker in a public meeting of the Iglesia ni Cristo, then attacking the
Catholic and Aglipayan churches, to stop and fired two shots in the air which dispersed the crowd and
stopped the meeting, is liable under Article 131.

Article 131, RPC:
Prohibition, interruption, and dissolution of peaceful meetings. The penalty of prision correccional
in its minimum period shall be imposed upon any public officer or employee who, without legal ground,
shall prohibit or interrupt the holding of a peaceful meeting, or shall dissolve the same.
The same penalty shall be imposed upon any public officer or employee who shall hinder any person
from joining any lawful association or from attending any of its meetings.
The same penalty shall be imposed upon any public officer or employee who shall prohibit or hinder any
person from addressing, either alone or together with others, any petition to the authorities for the
correction of abuses or redress of grievances.
Article 132, RPC:
Interruption of religious worship. The penalty of prision correccional in its minimum period shall be
imposed upon any public officer or employee who shall prevent or disturb the ceremonies or
manifestations of any religion.
If the crime shall have been committed with violence or threats, the penalty shall be prision correccional in
its medium and maximum periods.