Freedom of religion 1 ) Stay away from anger It hurtsOnly You !

2) If you are right then there is no need to get angry, and if you are wrong then you dont have any right to get angry. 3) Patience with family is love, Patience with others is respect. Patience with self is confidence and Patience with GOD is faith. 4) Never think hard about the PAST, It brings tears Dont think more about the FUTURE, It brings fears Live this moment with a smile, It brings cheers 5) Every test in our life makes us bitter or better, Every problem comes to make us or break us, The choice is ours whether we become victims or victorious.. Definition of TIME!? Slow when you wait! Fast when you are late! Deadly when you are sad! Short when you are happy! Endless when you are in pain! Long when you feel bored! Every time, time is determined by your feelings and your psychological conditions & not by clocks. So Have A Nice Time Always. Worlds best 8 Superb Sentences Shakespeare. "Never Play With The Feelings Of Others Because You May Win The Game But The Risk Is That You Will Surely Lose The Person For A Life Time". Napoleon. "The world suffers a lot. Not because of the violence of bad people, But because of the silence of good people!" Einstein. "I am thankful to all those who said NO to me It's because of them I did it myself." Abraham Lincoln. "If friendship is your weakest point then You are the strongest person in the world." Shakespeare. "Laughing Faces Do Not Mean That There Is Absence Of Sorrow! But It Means That They Have The Ability To Deal With It". William Arthur. "Opportunities Are Like Sunrises, If You Wait Too Long You Can Miss Them". Hitler. "When You Are In The Light, Everything Follows You, But When You Enter Into The Dark, Even Your Own

Shadow Doesn't Follow You." Shakespeare. "Coin Always Makes Sound But The Currency Notes Are Always Silent. So When Your Value Increases Keep Quiet.

ESTRADA VS ESCRITOR A.M. No. P-02-1651, August 4, 2003 FACTS: Complainant Alejandro Estrada wrote to Judge Jose F. Caoibes, Jr., requesting for an investigation of rumors that respondent Soledad Escritor, court interpreter, is living with a man not her husband. They allegedly have a child of eighteen to twenty years old. Estrada is not personally related either to Escritor or her partner. Nevertheless, he filed the charge against Escritor as he believes that she is committing an immoral act that tarnishes the image of the court, thus she should not be allowed to remain employed therein as it might appear that the court condones her act. Respondent Escritor testified that when she entered the judiciary in 1999, she was already a widow, her husband having died in 1998. She admitted that she has been living with Luciano Quilapio, Jr. without the benefit of marriage for twenty years and that they have a son. But as a member of the religious sect known as the Jehovah's Witnesses and the Watch Tower and Bible Tract Society, their conjugal arrangement is in conformity with their religious beliefs. In fact, after ten years of living together, she executed on July 28, 1991 a "Declaration of Pledging Faithfulness," insofar as the congregation is concerned, there is nothing immoral about the conjugal arrangement between Escritor and Quilapio and they remain members in good standing in the congregation. ISSUE: Whether or not respondent should be found guilty of the administrative charge of "gross and immoral conduct." HELD: Benevolent neutrality recognizes that government must pursue its secular goals and interests but at the same time strives to uphold religious liberty to the greatest extent possible within flexible constitutional limits. Thus, although the morality contemplated by laws is secular, benevolent neutrality could allow for accommodation of morality based on religion, provided it does not offend compelling state interests. It still remains to be seen if respondent is entitled to such doctrine as the state has not been afforded the chance has demonstrate the compelling state interest of prohibiting the act of respondent, thus the case is remanded to the RTC. Benevolent neutrality is inconsistent with the Free Exercise Clause as far as it prohibits such exercise given a compelling state interest. It is the respondents stance that the respondents conjugal arrangement is not immoral and punishable as it comes within the scope of free exercise protection. Should the Court prohibit and punish her conduct where it is protected by the Free Exercise Clause, the Courts action would be an unconstitutional encroachment of her right to religious freedom. The Court cannot therefore simply take a passing look at respondents claim of religious freedom, but must instead apply the compelling state interest test. The government must be heard on the issue as it has not been given an opportunity to discharge its burden of demonstrating the states compelling interest which can override respondents religious belief and practice. RECENT JURISPRUDENCE POLITICAL LAW

RE: REQUEST OF MUSLIM EMPLOYEES IN THE DIFFERENT COURTS IN ILIGAN CITY A.M. No. 02-2-10-SC, 14 December 2005, En Banc, (Callejo, Sr. J)

"No law shall be made respecting an establishment of religion, or prohibiting the free exercise thereof.

The exercise and enjoyment of religious profession and worship, without discrimination or preference, shall forever be allowed. No religious test shall be required for the exercise of civil and political rights The Court recognizes that the observance of Ramadan and the Friday Muslim Prayer Day is integral to the Islamic faith.

In their Letter dated November 19, 2001 addressed to Executive Judge Valerio Salazar, RTC Iligan City, several Muslim employees requested that they be allowed to enjoy the following privileges: (1) to hold office hours from 7:30 a.m. to 3:30 p.m. without lunch break or coffee breaks during the month of Ramadan; (2) to be excused from work from 10:00 a.m. to 2:00 p.m. every Friday (Muslim Prayer Day) during the entire calendar year. The Muslim employees invoked P.D. No. 291 as amended by P.D. No. 322, which was issued to reinforce national unity by recognizing Muslim holidays and making them part of our national holidays.

Section 3 of the same law, as amended, provides that during the fasting season on the month of Ramadan, all Muslim employees in the national government, government-owned or controlled corporations, provinces, cities, municipalities and other instrumentalities shall observe office hours from 7:30 a.m. to 3:30 p.m. without lunch break or coffee breaks, and that there shall be no diminution of salary or wages, provided, that the employee who is not fasting is not entitled to the benefit of this provision. It also provides that "regulations for the implementation of this section shall be issued together with the implementing directives on Muslim holidays."

Pursuant thereto, the Civil Service Commission (CSC) promulgated Resolution No. 811277 stating that during Ramadan, the fasting month (30 days) of the Muslims, the Civil Service official time of 8:00 to 12:00 and 1:00 to 5:00 is hereby modified to 7:30 A.M. to 3:30 P.M. without noon break and the difference of 2 hours is not counted as undertime. The resolution also declared that during Friday Muslims are excused from work from 10 oclock in the morning to 2 oclock in the afternoon. In another resolution, CSC clarified that the term Friday in the above resolution is not limited to the Fridays during the month of Ramadan, but refers to all Fridays of the calendar year.

ISSUES: 1. Whether or not the said Muslim Employees have the right to hold office hours from 7:30 a.m. to 3:30 p.m. without break during the month of Ramadan pursuant to Section 3 (a) of Presidential Decree No. 291, as amended by Presidential Decree No. 322; and

2. Whether or not they have the right to be excused from work from 10:00 a.m. to 2:00 p.m. every Friday, the Muslim Prayer Day, during the entire calendar year.

HELD:

The request to allow the Muslim employees in the Judiciary to hold office hours from 7:30 a.m. to 3:30 p.m. without break during the month of Ramadan GRANTED. The request that the Muslim employees in the Judiciary be excused from work from 10:00 a.m. to 2:00 p.m. every Friday, the Muslim Prayer Day, during the entire calendar year DENIED for lack of legal basis. RECENT JURISPRUDENCE POLITICAL LAW

The recommendation of the Court Administrator with respect to the matter of allowing the Muslim employees in the Judiciary to hold flexible office hours from 7:30 a.m. to 3:30 p.m. without break during the month of Ramadan is well taken. The same has statutory basis in Section 3 (a) of P.D. No. 291, as amended by P.D. No. 322.

The Court, however, is constrained to deny for lack of statutory basis the request of the Muslim employees to be excused from work from 10:00 a.m. to 2:00 p.m. every Friday to allow them to attend the Muslim Prayer Day. CSC exceeded its authority insofar as it declared that Muslim employees are excused from work from 10:00 a.m. to 2:00 p.m. every Friday subject to certain conditions. CSC Resolution was purportedly issued pursuant to Sections 2 and 5 of P.D. No. 291, as amended by P.D. No 322, but neither of the two decrees mention Friday, the Muslim Prayer Day as one of the recognized holidays.

The Court is not unmindful that the subject requests are grounded on Section 5, Article III of the Constitution: "No law shall be made respecting an establishment of religion, or prohibiting the free exercise thereof. The exercise and enjoyment of religious profession and worship, without discrimination or preference, shall forever be allowed. No religious test shall be required for the exercise of civil and political rights."

The Court recognizes that the observance of Ramadan and the Friday Muslim Prayer Day is integral to the Islamic faith. However, while the observance of Ramadan and allowing the Muslim employees in the Judiciary to hold flexible office hours from 7:30 a.m. to 3:30 p.m. without any break during the month of Ramadan finds statutory support; there is no such basis to excuse them from work from 10 a.m. to 2: p.m. every Friday, the Muslim Prayer Day, during the entire calendar year.

In fine, the remedy of the Muslim employees, with respect to their request to be excused from work from 10:00 a.m. to 2:00 p.m. every Friday during the entire calendar year, is legislative, which is to ask Congress to enact a legislation expressly exempting them from compliance with the prescribed government working hours. Liberty of Abode and freedom movement

Gudani vs. Senga

G.R. No. 170165, Aug. 15, 2006

The ability of the President to prevent military officers from testifying before Congress does not turn on executive privilege, but on the Chief Executives power as commander -in-chief to control the actions and speech of members of the armed forces. The Presidents prerogatives as commander-in-chief are not hampered by the samelimitations as in executive privilege.

FACTS: On Sept. 22, 2005, Sen. Biazon invited several senior officers of the AFP, including Gen. Gudani, to appear at a public hearing before the Senate Committee on National Defense and Security concerning the

conduct of the 2004 elections wherein allegations of massive cheating and the Hello Garci tapes emerged. AFP Chief of Staff Gen. Senga issued aMemorandum, prohibiting Gen. Gudani, Col. Balutan and company from appearing before the Senate Committee without Presidential approval. Nevertheless, Gen. Gudani and Col. Balutan testified before said Committee, prompting Gen. Senga to order them subjected to General Court Martial proceedings for willfully violating an order of a superior officer. In the meantime, President Arroyo issued EO 464, which was subsequently declared unconstitutional. ISSUE: Whether or not the President can prevent military officers from testifying at a legislative inquiry

RULING: We hold that the President has constitutional authority to do so, by virtue of her power as commander-inchief, and that as a consequence a military officer who defies such injunction is liable under military justice. At the same time, we also hold that any chamber of Congress which seeks the appearance before it of a military officer against the consent of the President has adequate remedies under law to compel such attendance. Any military official whom Congress summons to testify before it may be compelled to do so by the President. If the President is not so inclined, the President may be commanded by judicial order to compel the attendance of the military officer. Final judicial orders have the force of the law of the land which the President has the duty to faithfully execute. Ability of President to prevent military officers from testifying before Congress is based on Commanderin-chief powers As earlier noted, we ruled in Senate that the President may not issue a blanket requirement of prior consent on executive officials summoned by the legislature to attend a congressional hearing. In doing so, the Court recognized the considerable limitations on executive privilege, and affirmed that the privilege must be formally invoked on specified grounds. However, the ability of the President to prevent military officers from testifying before Congress does not turn on executive privilege, but on the Chief Executives power as commander-in-chief to control the actions and speech of members of the armed forces. The Presidents prerogatives as commander-in-chief are not hampered by the samelimitations as in executive privilege. RATIONALE: Our ruling that the President could, as a general rule, require military officers to seek presidential approval before appearing before Congress is based foremost on the notion that a contrary rule unduly diminishes the prerogatives of the President as commander-in-chief. Congress holds significant control over the armed forces in matters such as budget appropriations and the approval of higher-rank promotions, yet it is on the President that the Constitutionvests the title as commander-inchief and all the prerogatives and functions appertaining to the position. Again, the exigencies of military discipline and the chain of command mandate that the Presidents ability to control the individual members of the armed forces be accorded the utmost respect. Where a military officer is torn between obeying the President and obeying the Senate, the Court will without hesitation affirm that the officer has

to choose the President. After all, the Constitution prescribes that it is the President, and not the Senate, who is the commander-in-chief of the armed forces. Remedy is judicial relief

At the same time, the refusal of the President to allow members of the military to appear before Congress is still subject to judicial relief. The Constitution itself recognizes as one of the legislatures functions is the conduct of inquiries in aid of legislation. Inasmuch as it is ill-advised for Congress to interfere with the Presidents power as commander -in-chief, it is similarly detrimental for the President to unduly interfere with Congresss right to conduct legislative inquiries. The impasse did not come to pass in this petition, since petitioners testified anyway despite the presidential prohibition. Yet the Court is aware that with its pronouncement today that the President has the right to require prior consent from members of the armed forces, the clash may soon loom or actualize. We believe and hold that our constitutional and legal order sanctions a modality by which members of the military may be compelled to attend legislative inquiries even if the President desires otherwise, a modality which does not offend the Chief Executives prerogatives as commander-in-chief. The remedy lies with the courts. The fact that the executive branch is an equal, coordinate branch of government to the legislative creates a wrinkle to any basic rule that persons summoned to testify before Congress must do so. There is considerable interplay between the legislative and executive branches, informed by due deference and respect as to their various constitutional functions. Reciprocal courtesy idealizes this relationship; hence, it is only as a last resort that one branch seeks to compel the other to a particular mode of behavior. The judiciary, the third coordinate branch of government, does not enjoy a similar dynamic with either the legislative or executive branches. Whatever weakness inheres on judicial power due to its inability to originate national policies and legislation, such is balanced by the fact that it is the branch empowered by the Constitution to compel obeisance to its rulings by the other branches of government.

Leave Division of OCA vs HeusdensA.M. No. P-11-2927, December 13, 2011Facts: Respondent left for abroad without waiting for the result of her application. It turned out that no travel authority wasissued in her favor because she was not cleared of all her accountabilities as evidenced by the SC Certificate ofClearance. The OCA found respondent to have violated the OCA Circular for failing to secure the approval of her application for travel authority. Issue: What are the inherent and statutory limitations on the constitutional right to travel? Ruling: The exercise of ones right to travel is not absolute. There are constitutional, statutory and inherent limitations regulating the right to travel. Section 6 provides that neither shall the right to travel be impaired except in the interes t ofnational security, public safety o r public health, as may be provided by law. Inherent limitations on the right to travel are those that naturally emanate from the source. An example of such inherent limitation is the power of the trial courts toprohibit persons charged with a crime to leave the country. Some of these statutory limitations are the following:1. The Human Security Act of 2010 or Republic Act (R.A.) No. 9372.2. The Philippine Passport Act of 1996 or R.A. No. 8239.3. The Anti Trafficking in Persons Act of 2003 or R.A. No. 92 08.4.

The Migrant Workers and Overseas Filipinos Act of 1995 or R. A. No. 8042, as amended by R.A. No. 10022.5. The Act on Violence against Women and Children or R.A. No. 9262.6. Inter-Country Adoption Act of 1995 or R.A. No. 8043