South Africa is struggling with the debate over legalizing voluntary euthanasia and physician-assisted suicide. The Salvation Army opposes euthanasia and assisted suicide. In 1997, the Philippine Senate considered passing a bill legalizing passive euthanasia. It is opposed to euthanasia and assisted suicide. Physician-assisted suicide is legal under the same conditions as voluntary euthanasia. The United Methodist Church is opposed to euthanasia and assisted suicide. Active euthanasia or assisted suicide are not legal in Spain. Active euthanasia or assisted suicide are not legal in Chile. Among other policies, they also support laws against prostitution, marijuana, euthanasia, and gestational surrogacy. Suicide is discouraged except in cases of euthanasia, where it would end extreme suffering. A euthanaticum is used for euthanasia and physician-assisted suicide. He also opposes laws regulating pornography, euthanasia, or stem cell research. The Quinlan case paved the way for legal protection of voluntary passive euthanasia. They objected to inviting an advocate of euthanasia to speak. This contrast is brought out in issues such as voluntary euthanasia.