Case Digest (G.R. No. 148579) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In GMA Network, Inc. v. Movie and Television Review and Classification Board, GMA Network, Inc. (petitioner) operates EMC Channel 27, a UHF television station in the Philippines. On January 7, 2000, the MTRCB (respondent), chaired by Armida P.E. Siguion-Reyna, issued an order suspending EMC Channel 27 for seven days for airing “Muro Ami: The Making” without first securing a permit as required under Section 7 of Presidential Decree No. 1986. The suspension was grounded on Memorandum Circular No. 98-17 (December 15, 1998), which prescribed penalties for exhibiting programs without valid MTRCB permits. Petitioner sought reconsideration and protested the order, informing the Board that EMC Channel 27 complied by going off air on January 11, 2000; these submissions were “noted” and effectively denied. Petitioner then filed a certiorari petition with the Court of Appeals, which, in its June 18, 2001 decision, affirmed the MTRCB’s order in toto. Aggrieved, GMA Network elevated the matt Case Digest (G.R. No. 148579) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the Parties and Subject Matter
- Petitioner GMA Network, Inc. operates UHF television station EMC Channel 27.
- Respondent Movie and Television Review and Classification Board (MTRCB) regulates television programs under PD 1986.
- Suspension Order and Procedural History
- On January 7, 2000, MTRCB issued an order suspending EMC Channel 27 for seven days for airing “Muro Ami: The Making” without a permit, pursuant to Section 7 of PD 1986 and Memorandum Circular No. 98-17.
- Petitioner moved for reconsideration and filed a letter-protest, both of which were effectively denied; it complied with the suspension from January 11, 2000.
- Petitioner filed a certiorari petition with the Court of Appeals (CA), which on June 18, 2001 dismissed the petition and affirmed the suspension order in toto.
- Petitioner elevated the case to this Court via a petition for review under Rule 45.
Issues:
- Authority of MTRCB to Review “Muro Ami: The Making” Prior to Broadcast
- Whether MTRCB’s statutory mandate under PD 1986 includes prior review of the subject program.
- Enforceability of Memorandum Circular No. 98-17
- Whether Memorandum Circular No. 98-17, as the basis for the suspension order, was validly promulgated and binding on petitioner.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)