G.R. No. 155282 - Movie and Television Review and Classification Board vs. ABS-CBN.

On October 15, 1991 at 10:45 PM, ABS-CBN aired an episode of its public affairs program The Inside Story entitled “Prosti-tuition.”
The episode depicted female students moonlighting as prostitutes to pay tuition, interviewed student-prostitutes, pimps, customers, and some faculty, and identified Philippine Women’s University (PWU) by name and by showing its Taft Avenue facade.

Dr. Leticia P. de Guzman (Chancellor and Trustee of PWU) and the PWU Parents and Teachers Association filed letter-complaints with the Movie and Television Review and Classification Board (MTRCB), alleging the episode besmirched PWU’s reputation and harassed its students.
MTRCB’s Legal Counsel initiated a formal complaint before its Investigating Committee, charging respondents with failure to submit the program for prior review and unauthorized exhibition in violation of Section 7 of P.D. No. 1986 and Sections 3 and 7 of the MTRCB Rules and Regulations.
The MTRCB Investigating Committee (Feb. 5, 1993) fined ABS-CBN and Loren Legarda ₱20,000 for non-submission and ordered all future public affairs programs to be submitted for prior review. The MTRCB Chairman affirmed the penalty (Mar. 12, 1993) and denied reconsideration (Apr. 14, 1993).

Respondents filed a special civil action for certiorari before RTC Branch 77, Quezon City, seeking:

Declaration of unconstitutionality of Sections 3(b), 3(c), 3(d), 4, 7, and 11 of P.D. No. 1986 and Sections 3, 7, and 28(a) of the MTRCB Rules and Regulations;
In the alternative, exclusion of The Inside Story from those provisions;
Annulment of the MTRCB decisions of March 12 and April 14, 1993.

Annulled and set aside the MTRCB decisions of March 12 and April 14, 1993;
Declared the cited P.D. and MTRCB Rules inapplicable to The Inside Story and similar public affairs programs;
Issued a permanent injunction against MTRCB enforcement.

MTRCB filed a petition for review on certiorari under Rule 45, assailing the RTC’s decision and order.
MTRCB argued that:

P.D. No. 1986 Section 3(b) grants it power to review all television programs, including public affairs and news documentaries;
Television programs are more accessible than print and subject to regulation without constituting prior restraint;
Section 3(b) does not violate freedom of expression or of the press.

Respondents contended The Inside Story is protected by freedom of expression and of the press and thus exempt from MTRCB review.

Whether the MTRCB has the power or authority under P.D. No. 1986 and its Implementing Rules to review and approve The Inside Story prior to its television broadcast.
Whether Sections 3(b), 3(c), 3(d), 4, 7, and 11 of P.D. No. 1986 and Sections 3, 7, and 28(a) of the MTRCB Rules and Regulations are unconstitutional or inapplicable to a public affairs program like The Inside Story.