Case Digest (G.R. No. 119673)
Facts:
Iglesia ni Cristo (INC) v. Court of Appeals, G.R. No. 119673, July 26, 1996, Supreme Court En Banc, Puno, J., writing for the Court. Petitioner Iglesia ni Cristo (INC) produced a religious television program titled "Ang Iglesia ni Cristo," broadcast on Channel 2 and Channel 13, which presented and propagated INC doctrines often by comparing them with other religions. In September–November 1992 INC submitted videotapes of Series Nos. 116, 119, 121 and 128 to the Board of Review for Motion Pictures and Television (the Board, later MTRCB) for classification; the Board classified several episodes as "X" (not for public viewing) on the ground that they allegedly attacked or offended other religions.INC pursued administrative and judicial remedies. Administratively, INC appealed the Board’s classification of Series No. 128 to the Office of the President; on December 18, 1992 the Executive Secretary reversed the Board and the Board thereafter allowed Series No. 128 to be telecast under parental guidance. Judicially, INC filed Civil Case No. Q-92-14280 in the Regional Trial Court (RTC), Quezon City, alleging the Board acted without jurisdiction or with grave abuse of discretion in requiring submission of tapes and in x-rating the programs; the RTC issued a writ of preliminary injunction, conducted hearings on evidentiary exhibits (including Board voting slips), and on December 15, 1993 rendered judgment ordering the Board to grant permits but directing INC to “refrain from offending and attacking other existing religions.”
INC moved for reconsideration seeking deletion of the restraint paragraph and a perpetual injunction against requiring submission of VTR tapes; on March 7, 1993 the RTC granted reconsideration, deleted the offending paragraph, and prohibited the Board from requiring submission of tapes. The Board appealed to the Court of Appeals. On March 24, 1995 the Court of Appeals (Tenth Division, Solano, J., ponente) reversed the RTC, holding (1) the Board had jurisdiction to review the programs under P.D. No. 1986, Sec. 3, and (2) the Board did not gravely abuse discretion in denying permits because the episodes constituted attacks on other religions and were indecent and contrary to law and good customs.
Petitioner filed this petition for review on certiorari under Rule 45 challenging the ...(Subscriber-Only)
Issues:
- Does the Movies and Television Review and Classification Board (MTRCB) have statutory power under P.D. No. 1986 to screen and review petitioner's religious television program for possible restriction or prohibition?
- If the Board has such power, did the Board (and the Court of Appeals in affirming it) gravely abuse that power by x-rating Series Nos. 115, 119 and 121 of "Ang Iglesia ni Cristo" for allegedly attacking other religions and being ind...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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