CONCEPCION, CLARISA YSABEL R.

VELARDE v. SOCIAL JUSTICE SOCIETY

G.R. No. 159357 (April 28, 2004)
Ponente: J. Panganiban

FACTS:
In 2003, Social Justice Society (SJS), a political party, filed a petition for Declaratory Relief to the
Regional Trial Court (RTC), seeking the interpretation of a few constitutional provisions,
specifically on the separation of Church and State (Sec. 6, Art. II, 1987 Constitution), and wanted
relief on the constitutionality of the acts of the religious leaders endorsing a candidate for an
elective office during the election period. Among the religious leaders were Mike Velarde,
Cardinal Sin, Eddie Villanueva, Eli Soriano and Eraño Manalo, who claimed that there was
justiciable controversy nor a cause of action in the case filed against them; thus, seeking the
dismissal of the petition. The RTC denied the motion for the dismissal and decided on the case
on the basis of deeming the endorsement of specific candidates in an election to any public office
as a clear violation of the separation clause in the Sec. 6, Art. II of the 1987 Constitution. It then
proceeded with a lengthy opinion of the issue raise. Furthermore, the RTC failed to include a
dispositive portion in its Decision—which just ended with “SO ORDERED.”

ISSUES:
A. Procedural Issues
1. Whether or not the Petition for Declaratory Relief raised a justiciable controversy.
2. Whether or not the Petition for Declaratory Relief stated a cause of action.
3. Whether or not SJS prove to have any legal standing to file the petition for Declaratory
Relief

B. Substantive Issues
1. Whether or not the RTC Decision followed the rules required by the Constitution, and
other statutes.
2. Whether or not religious leaders are prohibited by law to endorse specific candidates
for an elective public office.

HELD:
A. 1.) No. There was no justiciable controversy because the issue raised was merely
hypothetical and conjectural. Hence, it is not appropriate for a judicial determination.
Furthermore, there was no precise mention of the direct statement of the facts on which
the party’s petition relies for its claim. The whole claim of SJS was on the basis of a
speculation.
2.) No. There was no cause of action on the part of SJS because there were no rights
violated. SJS failed to prove that he religious leaders did something to violate the rights
of former. The Court found that there was no trigger for the cause of action of SJS as it
failed to suggest that they had a legal right to protect.
 3.) No. There was no legal standing on the part of SJS, with regards to material, personal
or substantial interest. The party failed to discuss how to challenged act affect their legal
interest and how it would injure or benefit them.

B. 1.) No. Section 24, Article VIII of the 1987 Constitution mandates each court Decision to
express clearly and distinctly the facts and the law on which it is based. Similarly, Rule 120
of the Rules of Court on Criminal Procedure; Section 1, Rule 36 of the Rules on Civil
Procedure states that:

“A judgment or final order determining the merits if the case shall

be rendered. The decision shall be in writing, personally and
directly prepared by the judge, stating clearly and distinctly the
facts and law on which it is based, signed by the issuing
magistrate, and filled with the clerk of court.”

The assailed Decision contained no statement of facts or the court’s findings as to the
probable facts. What it only contained was a lengthy opinion on the nature and extent of
the separation of Church and State. The RTC also failed to express a final conclusion
insofar as to specifying the relief granted or denied. It simply ended with “SO ORDERED.”

With the irregularities as to the form of the RTC Decision, it is impossible to note that the
trial court conformed with the mandated rules.

2.) There is no answer for this because the very Decision of the RTC was vague and grossly
inadequate that it was deemed void for it did not contain a dispositive portion, nor a ratio
decidendi for that matter. Moreover, there has been no finding of a justiciable
controversy, cause of action or locus standi on the part of SJS.