act on one's belief. The first part is absolute. As explained in Gerona v. Secretary of Education:211 The realm of belief and creed is infinite and limitless bounded only by one's imagination and thought. So is the freedom of belief, including religious belief, limitless and without bounds. One may believe in most anything, however strange, bizarre and unreasonable the same may appear to others, even heretical when weighed in the scales of orthodoxy or doctrinal standards. But between the freedom of belief and the exercise of said belief, there is quite a stretch of road to travel.212 The second part however, is limited and subject to the awesome power of the State and can be enjoyed only with proper regard to the rights of others. It is "subject to regulation where the belief is translated into external acts that affect the public welfare." 213 Legislative Acts and the Free Exercise Clause Thus, in case of conflict between the free exercise clause and the State, the Court adheres to the doctrine of benevolent neutrality. This has been clearly decided by the Court in Estrada v. Escritor, (Escritor)214 where it was stated "that benevolent neutrality-accommodation, whether mandatory or permissive, is the spirit, intent and framework underlying the Philippine Constitution."215 In the same case, it was further explained that" The benevolent neutrality theory believes that with respect to these governmental actions, accommodation of religion may be allowed, not to promote the government's favored form of religion, but to allow individuals and groups to exercise their religion without hindrance. "The purpose of accommodation is to remove a burden on, or facilitate the exercise of, a person's or institution's religion."216 "What is sought under the theory of accommodation is not a declaration of unconstitutionality of a facially neutral law, but an exemption from its application or its 'burdensome effect,' whether by the legislature or the courts." 217 In ascertaining the limits of the exercise of religious freedom, the compelling state interest test is proper.218 Underlying the compelling state interest test is the notion that free exercise is a fundamental right and that laws burdening it should be subject to strict scrutiny.219 In Escritor, it was written: Philippine jurisprudence articulates several tests to determine these limits. Beginning with the first case on the Free Exercise Clause, American Bible Society, the Court mentioned the "clear and present danger" test but did not employ it. Nevertheless, this test continued to be cited in subsequent cases on religious liberty. The Gerona case then pronounced that the test of permissibility of religious freedom is whether it violates the established institutions of society and law. The Victoriano case mentioned the "immediate and grave danger" test as well as the doctrine that a law of general applicability may burden religious exercise provided the law is the least restrictive means to accomplish the goal of the law. The case also used, albeit inappropriately, the "compelling state interest" test. After Victoriano , German went back to the Gerona rule. Ebralinag then employed the "grave and immediate danger" test