Title
National Press Club vs. Commission on Elections
Case
G.R. No. 102653
Decision Date
Mar 5, 1992
Media entities challenged COMELEC's regulation prohibiting sale/donation of print/airtime for campaigns, claiming it violated free speech, press, and information rights. SC upheld the law, ruling it ensures fair elections by preventing wealthy candidates from dominating media, balancing constitutional rights with legitimate public interest.

Case Digest (A.M. No. 1720, 1911, 2300-CFI)
Expanded Legal Reasoning Model

Facts:

  • Background of the Petitions
    • Three consolidated petitions filed by:
      • National Press Club (G.R. No. 102653)
      • Philippine Press Institute and officers (G.R. No. 102925)
      • Broadcasters’ associations, media owners, individual candidates and voters (G.R. No. 102983)
    • Petitioners challenged the constitutionality of Section 11(b) of Republic Act No. 6646 (Electoral Reforms Law of 1987).
  • Statutory Provisions Involved
    • RA 6646 Section 11(b):
– Prohibits newspapers, radio/TV stations or any mass-media user from selling or giving free print space or airtime for campaign or political purposes, except to the Commission on Elections (COMELEC) under Secs. 90 and 92 of B.P. Blg. 881. – Requires any media columnist/commentator who is also a candidate to take leave during the campaign.
  • Batas Pambansa Blg. 881 (Omnibus Election Code)
– Sec. 90 (Comelec Space): COMELEC must procure and equally allocate free newspaper space among all candidates. – Sec. 92 (Comelec Time): COMELEC must procure and equally allocate free radio/TV time among all candidates.
  • Constitutional Context
    • Article IX-C, Section 4 (1987 Constitution):
– Empowers COMELEC during the election period to supervise/regulate media franchises to ensure “equal opportunity, time, and space” and the right to reply in candidate forums.
  • Article II, Section 26 (1987 Constitution):
– States that “the State shall guarantee equal access to opportunities for public service.”

Issues:

  • Primary Issue
    • Does Section 11(b) of RA 6646 unconstitutionally abridge freedom of speech, freedom of the press and freedom of expression by banning mass-media campaign advertisements except through COMELEC?
  • Secondary Issues
    • Does the prohibition amount to impermissible censorship of media content?
    • Is COMELEC’s exercise of power under Article IX-C(4) constitutionally valid as applied to Section 11(b)?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
Unlock Full Case Digest

Analyze Cases Smarter, Faster
Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources. AI digests are study aids only—use responsibly.

About Privacy Terms