G.R. No. 161422 - Natividad vs. Movie and Television Review and Classification Board

Federico “Toto” Natividad, a movie producer and director with Venus Films, produced the movie "Butakal (Sugapa Sa Laman)" which is allegedly based on the true and notorious case of the Chiong sisters of Cebu.
The film depicts, albeit controversially, the kidnapping, rape, and killing of Jacqueline Chiong and the disappearance of her sister Marijoy Chiong, crimes committed on July 16, 1997.
The factual backdrop involves the conviction of eight accused in connection with the crimes, with seven receiving two counts of reclusion perpetua, and the case’s evolution through automatic appeal and subsequent resolutions in criminal courts.

On August 25, 1999, while criminal proceedings against the accused were pending, Natividad sought a permit from the Movie and Television Review and Classification Board (MTRCB) to exhibit the movie.
The MTRCB granted the movie an R-Strictly for Adults rating and issued the permit on August 27, 1999.
The movie was slated for public exhibition starting September 8, 1999 in various theaters in Metro Manila and Cebu City and was advertised in major daily newspapers.

Private respondents—the spouses Dionisio and Thelma Chiong, along with Marichu Jimenea (a relative)—objected to the film’s public exhibition, claiming it misrepresented the brutality of the real-life events and operated on a purely commercial motive.
They contended that the film’s depiction was libelous and that its showings during the pendency of the criminal case rendered the matter sub judice.
In response, the MTRCB arranged for a special screening in the presence of the Chiongs, and after the screening, the board maintained its approval of the film pending a restraining order from the proper court.
The Chiongs subsequently filed a petition for a temporary restraining order (TRO) with the Regional Trial Court (RTC) in Civil Case No. Q-99-38647, seeking to cancel the permit and halt the film’s exhibition on the grounds of legal and moral impropriety.
The RTC granted the TRO, first issuing a 72-hour injunction and then extending it to a full duration of 20 days. Later developments included the filing of supplementary motions and pleadings by both Natividad and the Chiongs, with issues of forum shopping emerging as the matter evolved.

Amid these proceedings, on September 27, 1999, the MTRCB, influenced by a directive from the Office of the President (OP) and a subsequent meeting between Thelma Chiong’s relatives and the President, recalled the permit to exhibit the film and ordered a second review by a designated Committee.
Natividad promptly filed motions with both the RTC and the MTRCB, challenging the recall as an act of forum shopping and asserting that the decision of the first review was final.
The RTC eventually dismissed Civil Case No. Q-99-38647 on the ground of forum shopping, while simultaneously the Chiongs filed a separate administrative complaint (MTRCB Administrative Case No. 25-99) seeking prohibition of the film’s exhibition.
In response, Natividad contended that the MTRCB had no jurisdiction over the controversy, that the complainants had engaged in forum shopping, and that the recall order violated his right to due process.

The MTRCB confiscated the VHS master copy of the film, citing that it was material evidence in the administrative complaint brought by the Chiongs.
Natividad later requested the return of the master copy, contending that the seizure exceeded the allowances provided under the relevant provisions of Presidential Decree No. 1986 and the MTRCB’s own rules.
On May 12, 2000, Natividad filed a special civil action for certiorari and mandamus before the Court of Appeals (CA), challenging the MTRCB’s actions, particularly the prolonged seizure of the master copy and the recall order.

The CA denied Natividad’s petition, ruling that the orders issued by the MTRCB were interlocutory and non-justiciable through a petition for certiorari.
The CA held that the proper remedy for Natividad was to respond to the administrative complaint, raise any issues at trial, and pursue an appeal if necessary.
The CA further emphasized that the MTRCB had acted within its jurisdiction under PD 1986 and according to its Implementing Rules and Regulations, particularly given the pendency of criminal cases that bore materially on the administrative proceedings.

Whether the Court of Appeals erred in holding that the movie "Butakal (Sugapa Sa Laman)" is a true-to-life depiction of the Chiong sisters’ case, notwithstanding the absence of an MTRCB hearing on the matter.

Natividad argued that no hearing was conducted by the MTRCB in Administrative Case No. 25-99, thus the factual determination was premature.

Whether the MTRCB acted without jurisdiction or with grave abuse of discretion by refusing to lift or dissolve the recall order on the film’s permit.

Natividad contended that after the MTRCB denied the Chiongs’ complaint—or at least failed to dismiss it in a timely manner—the recall order should have been lifted, arguing that its continued existence was an overreach.
The petitioner asserted that such actions amounted to a lack or exercise of jurisdiction and infringed his rights.

Whether the MTRCB committed grave abuse of discretion by confiscating the VHS master copy of the film for evidentiary purposes in violation of the period prescribed by law.

Natividad maintained that, besides not being given due process, the prolonged seizure of the film (beyond the 20-day preventive period allowed) was a breach of procedure and an infringement on his proprietary rights.