Case Digest (G.R. No. 212670) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Movie and Television Review and Classification Board (MTRCB) v. ABC Development Corp. (TV5), G.R. No. 212670, decided July 6, 2022, the MTRCB sought to uphold its May 30, 2012 administrative decision in MTRCB ADM. CASE No. 008-2012 suspending the show “T3 Kapatid Sagot Kita” (T3) for three months, imposing a ₱100,000 fine, and placing it on probation after suspension, on the ground that hosts Raffy, Erwin, and Ben Tulfo uttered threatening and indecent remarks on May 7, 2012 concerning the alleged mauling of their brother Ramon Tulfo by Raymart Santiago and Claudine Barretto. MTRCB Special Agents reported these “Subject Utterances” as possibly violative of Section 3(c) of Presidential Decree No. 1986 (PD 1986). TV5 conducted its own investigation, suspended the hosts for three episodes, and accepted their apologies. The MTRCB Hearing and Adjudication Committee nevertheless issued a twenty-day preventive suspension order, conducted formal hearings, and rendered its decision on Case Digest (G.R. No. 212670) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Case Background
- Movie and Television Review and Classification Board (MTRCB)
- Issued a Decision dated May 30, 2012 in ADM. Case No. 008-2012.
- Penalized “T3 Kapatid Sagot Kita” (T3) for airing objectionable scenes on May 7, 2012:
- Three-month suspension.
- ABC Development Corp. (TV5)
- Aired T3, hosted by Raffy, Erwin, and Ben Tulfo.
- Tulfo brothers made threatening, profane utterances regarding the mauling of their brother Ramon Tulfo.
- Procedural History
- Administrative Proceedings
- MTRCB Special Agents filed an incident report on May 7, 2012.
- Chief Legal Counsel found probable cause under Section 3(c), PD 1986; formal adjudication followed.
- Hearing and Adjudication Committee issued 20-day preventive suspension (May 10, 2012) and the May 30, 2012 Decision.
- Self-Regulation by TV5
- TV5 directed hosts to explain; they apologized.
- TV5 imposed a three-episode suspension instead of contract termination.
- Judicial Proceedings
- TV5 filed Petition for Certiorari (Rule 65) before the CA; TRO granted; no injunction issued by SC.
- TV5 filed Petition for Review (Rule 43) before the CA; CA granted TRO and preliminary injunction, then on March 7, 2013 set aside MTRCB Decision.
- CA denied MTRCB Motion for Reconsideration (May 15, 2014).
- MTRCB elevated case to the Supreme Court via Rule 45.
Issues:
- Whether the MTRCB’s determination that the Tulfo brothers’ utterances violated Section 3(c) of PD 1986 was within its authority to censor “immoral, indecent, contrary to law and/or good customs, or with dangerous tendency to encourage…violence.”
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)