Reli German v. Gen. Santiago Barangan

Summary

Fifty petitioners sought to enter St. Jude Chapel on J.P. Laurel Street to pray and hear mass but were prevented by presidential security officials who cited security concerns since the chapel was within the Malacañang security perimeter. Petitioners filed for mandamus and injunction claiming violation of their constitutional rights to freedom of religious worship and locomotion. The Supreme Court En Banc dismissed the petition, with the majority finding that the security restriction was reasonable for national security purposes and questioning petitioners' good faith given their conduct (wearing yellow shirts, raising clenched fists, chanting anti-government slogans). The Court held that while freedom to believe is absolute, freedom to act in exercise of religion can be limited when it conflicts with established institutions and law. Multiple justices dissented, arguing that religious freedom as a preferred right can only be restricted under the clear and present danger standard, which was not established. The case highlights the tension between constitutional rights and national security concerns during the martial law period.