G.R. No. 92541 - Aquino-Sarmiento vs. Morato

Petitioner Ma. Carmen G. Aquino-Sarmiento, a member of the Movie and Television Review and Classification Board (MTRCB), requested in February 1989 access to the Board’s individual voting slips used to decide on banning, cutting, or classifying films and TV productions.
The MTRCB records officer conditioned access on prior clearance from Chairman Manuel L. Morato, who ultimately denied the request, characterizing the voting slips as private “conscience votes.”

On February 27, 1989, Morato convened an executive meeting in which 17 Board members voted to classify individual voting records as confidential, thus barring public access without the Chairman’s consent.
On July 27, 1989, the Board issued Resolution No. 10-89 declaring the reviewing committee’s decisions and individual voting slips confidential, private, and personal.

On June 22, 1989, Morato ordered unilateral deletions of the film “Mahirap ang Magmahal,” despite its prior “R-18 without cuts” classification by the Board.
Petitioner contested that under Presidential Decree (PD) 1986, the Chairman lacks power to reverse a subcommittee or full Board decision; the Justice Secretary later opined that Morato had no such authority, but Morato ignored that opinion.

Whether Resolution No. 10-89 violates Article III, Section 7 of the 1987 Constitution by denying public access to official records.
Whether PD 1986 and implementing rules authorize the MTRCB Chairman to unilaterally downgrade or reverse decisions of the reviewing sub-committees or the full Board.
Whether the refusal of Morato and the MTRCB to abide by the Justice Secretary’s Opinion No. 1, Series of 1990, constitutes grave abuse of discretion or capricious, arbitrary action.