Courts Affirm Dismissal of Case Against Exorcist Priest
The Court of Appeals (CA) has affirmed a Quezon City court’s dismissal of the case filed against Fr. Winston Cabading, an exorcist priest, who was accused of offending religious feelings in connection with comments about the 1948 Marian apparitions in Lipa City, Batangas. In a 28-page ruling promulgated on September 28, the CA’s 12th Division denied petitions for certiorari filed by retired Sandiganbayan Justice Harriet Demetriou, finding no merit in the arguments presented.
Lower Court Ruling Grounded in Distinction Between Ceremony and Broadcast
At the core of the CA decision is the interpretation of what constitutes a religious ceremony. The appellate court agreed with the Quezon City Regional Trial Court (RTC) Branch 224, which earlier ruled that a Facebook program in which Cabading’s statements were aired does not fall under a “religious ceremony.” The CA described the program as a show, broadcast, telecast, videogcast, performance, or dialogue that does not resemble a formal or solemn act prescribed by the ritual or protocol of a religious procedure.
Implications for Religious Rituals and Digital Media
The CA’s ruling emphasizes that a livestream or online discussion, accessible to a broad audience regardless of religious belief, does not automatically become a religious ceremony. The court noted that the Facebook livestream allowed access to anyone on the Internet, extending beyond the confines of a specific religious group. Consequently, the exchange of viewpoints, preachment, prayer, and commentary during the discussion was not deemed a formal religious rite.
Concerns About Judicial Legislation
Demetriou had argued that the lower court engaged in “judicial legislation” by defining what constitutes a religious ceremony for purposes of the case. The CA rejected this characterization, warning that broad interpretations could set a dangerous precedent. If courts broadly labeled ordinary discussions about religion as ceremonies, it could chill public discourse on religious topics and lead to a proliferation of claimed offenses based on procedural labels rather than substantive harms.
Legal Basis and Statutory Considerations
The CA also addressed the charge that Cabading violated a Pastoral Instruction and an Injunction Order issued by the Dominican Province of the Catholic Bishops’ Conference of the Philippines. The court stated that such acts are not punishable under the Revised Penal Code or under specific laws. This finding aligns with a broader view that church directives or internal communications do not automatically translate into criminal offenses in the secular legal framework when they occur in the context of public discourse.
Background of the Case
Demetriou filed the case accusing Cabading of being a “rabid critic” of Mary and questioned the Basilica’s 1951 Lipa Diocesan verdict that apparently negated the authenticity of the 1948 apparition of Our Lady, Mary, Mediatrix of All Grace. The complaint centered on the priest’s statements during a digital Catholic program that challenged the 1948 apparition’s authenticity. In 2024, the Quezon City court granted Cabading’s motion to quash and dismissed the raps against him for lack of a sufficient legal basis to proceed.
What this means for Fr. Cabading and the Community
For Cabading, the CA ruling provides a legal vindication: his public comments on a subject tied to religious belief and church history did not cross the line into criminal offense as defined by Philippine law. For observers, the decision helps delineate the boundary between protected religious discussion and punishable acts, especially in a landscape where social media can broadcast sermons, debates, and doctrinal disputes to a global audience.
Looking Ahead
The decision by the CA sets a precedent for similar cases where religious commentary, aired digitally, is debated in terms of legality. While the court underscored the importance of safeguarding religious freedom and open dialogue, it also reaffirmed that not every negative or controversial statement about religious matters constitutes a crime. The Philippine judiciary thus continues to balance the rights to express religious beliefs with the responsibilities that accompany public discourse.
