The case of Gonzalez v. Roman Catholic Archbishop of Manila in 1929 revolved around the issue of whether or not a bequest to masses, which are religious services in the Roman Catholic Church, could be considered as charitable trusts under U.S law. The petitioner, Eulogio R. Gonzalez was an executor and trustee for his brother's estate who had left $1,000 for masses to pray for his soul after death. However, when he sought approval from the probate court to pay this sum to the respondent (the Archbishop), it was denied on grounds that such a trust lacked certainty and definiteness required by law because there were no specific beneficiaries named. Gonzalez appealed this decision all the way up to Supreme Court arguing that these types of trusts have been recognized historically both within common law jurisdictions and canon law itself; moreover they serve public welfare by promoting religion which is one aspect of charity according its broadest sense. In response, Justice George Sutherland delivered opinion affirming lower courts' rulings stating "a gift indefinite as this cannot support a valid trust." He further explained while church may benefit indirectly through increased attendance or donations resulting from mass being said - direct benefits accrue only priest saying mass himself thus failing meet legal requirements necessary establish charitable trust.

The dissenting opinion in the case of Gonzalez v. Roman Catholic Archbishop of Manila argued that the court should not have intervened in a religious matter, as it was beyond its jurisdiction. The justice contended that the decision to appoint or reject an applicant for priesthood is purely ecclesiastical and should be left solely to church authorities without interference from secular courts. He further stated that by involving itself in such matters, the court had violated principles of separation between church and state enshrined within First Amendment rights. Additionally, he disagreed with majority's interpretation of Philippine law regarding seminary admissions, arguing instead that they were misapplied and misunderstood.