Title
Iglesia ni Cristo vs. Court of Appeals
Case
G.R. No. 119673
Decision Date
Jul 26, 1996
INC's religious TV program was classified "X" by MTRCB for allegedly attacking other religions. SC ruled in favor of INC, upholding religious freedom and expression, stating censorship requires clear and present danger.

Case Digest (G.R. No. 119673)
Expanded Legal Reasoning Model

Facts:

  • Parties and Program
    • Petitioner Iglesia ni Cristo is a duly organized religious organization that produces a weekly television program entitled “Ang Iglesia ni Cristo,” aired on Channel 2 (Saturdays) and Channel 13 (Sundays).
    • Respondent Board of Review for Motion Pictures and Television (later MTRCB) classified Series Nos. 116, 119, 121 and 128 as “X” (not for public viewing) on the ground that they “offend and constitute an attack against other religions.”
  • Procedural History
    • Administrative Appeal: On November 28, 1992, petitioner appealed the X-rating of Series No. 128 to the Office of the President; Executive Secretary reversed the Board’s decision on December 18, 1992, allowing public telecast of Series 128.
    • Civil Case in RTC: On December 14, 1992, petitioner filed Civil Case No. Q-92-14280 (RTC, Quezon City), challenging the Board’s jurisdiction and X-rating of Series Nos. 115, 119, 121 and 128; RTC issued a writ of preliminary injunction on January 4, 1993.
    • RTC Judgment: On December 15, 1993, RTC ordered the Board to grant permits for all series but directed petitioner to “refrain from offending and attacking other existing religions.”
    • RTC Reconsideration: On March 7, 1994, RTC granted petitioner’s motion to delete the “offending” proviso and permanently enjoined the Board from requiring submission of future VTR tapes.
    • Court of Appeals Decision: On March 24, 1995, the CA reversed RTC, holding that (a) the Board has jurisdiction to review television programs, and (b) it did not abuse its discretion in X-rating Series Nos. 115, 119, 121 and declaring them indecent and contrary to good customs.
    • Petition to the Supreme Court: Petitioner filed a Rule 45 petition for certiorari seeking reversal of the CA’s upholding of the X-ratings.

Issues:

  • Whether the Court of Appeals erred in ruling that “Ang Iglesia ni Cristo” is not constitutionally protected as religious exercise and free speech.
  • Whether the MTRCB has jurisdiction and power to review and censor religious television programs.
  • Whether the MTRCB gravely abused its discretion in X-rating Series Nos. 115, 119 and 121 for allegedly “attacking” other religions and being indecent, contrary to law and good customs.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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