Patriotic Oath (Philippines)

Recitation of the Panatà is required by law at all public and private educational institutions meant for Filipinos or containing a majority of Filipino nationals. This guideline was set in Republic Act No. 1265, one of many national symbols laws, which was approved on 11 July 1955.[1] The act was implemented in schools through Department Order No. 8 of what is now the Department of Education, which was approved on 21 July 1955. The Panatà was revised in November 2001 by then Secretary of Education Raul Roco, using shorter lines in less formal Tagalog.

Although Department Order No. 8 states that the Panatà may be recited in English or any Philippine language, the Panatà is usually recited today in Filipino, of which two versions exist: the current text is a shorter rendering of the English original, while the older version is a more direct translation.

In 1993, sixty-eight students from the organization Jehovah's Witnesses (JW) were expelled from a school in Cebu for their failure to salute the flag, sing the Philippine National Anthem, and recite the patriotic oath. A teacher in the same school, also a JW adherent was fired from her job for the same offense. According to JW teachings, flag ceremonies, flag salutes, and patriotic oaths are viewed as acts of worship or religious devotion, the latter two of which they believe can only be rendered to God alone and not anyone nor anything. The JW's consider the flag an image and honoring the flag idolatry.

The case was brought to court wherein the Cebu Division Superintendent argued that the students and the teacher violated Republic Act No. 1265, the law that makes flag ceremony compulsory for all schools, citing the case of Gerona et al v. Secretary of Education.[4] Superintendent also argued of separation of church and state, stating the flag is devoid of religious significance and does not involve any religious ceremony, and that giving JW's right to exemption disrupt school discipline and demoralize the rest of the school population which by far constitutes the great majority.

The Court ruled in favor of the expelled JW students and the fired JW teacher, on the grounds that expulsion due to religious beliefs is invalid.[5] They also stated of freedom of religion in the 1987 Constitution of the Philippines:

Religious freedom is a fundamental right which is entitled to the highest priority and the amplest protection among human rights, for it involves the relationship of man to his Creator. [...] The right to religious profession and worship has a two-fold aspect, vis., freedom to believe and freedom to act on one’s belief. The first is absolute as long as the belief is confined within the realm of thought. The second is subject to regulation where the belief is translated into external acts that affect the public welfare. [...] The sole justification for a prior restraint or limitation on the exercise of religious freedom [...] is the existence of a grave and present danger of a character both grave and imminent, of a serious evil to public safety, public morals, public health or any other legitimate public interest, that the State has a right (and duty) to prevent.

Evidence also showed that even if they do not take part in the compulsory flag ceremony, they never engaged in “external acts” or behavior that would offend the people who believe in expressing their love of country through the observance of the flag ceremony. The expelled only quietly stood at attention during the flag ceremony to show their respect for the right of those who choose to participate in the solemn proceedings.

The students were later allowed to re-enroll in the school they were expelled from and the teacher was allowed to resume her duties.

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