Case Digest (G.R. No. 246126) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
This case, decided by the Philippine Supreme Court En Banc on June 27, 2023 (G.R. No. 246126), involves a petition filed by petitioners Patricia Marie I. Ranada, Mara Alyssabel D. Cepeda, Raymon G. Dullana, Franklin Y. Cimatu, Mauricio E. Victa, Camille Kristina S. Elemia, Ralph Martin S. Rivas, Baltazar Espinosa Lagsa (collectively, the Rappler Journalists), and Rappler Inc. (Rappler), and various journalists, media practitioners, and media organizations as petitioners-in-intervention. They challenged the respondents, specifically the Office of the President, Office of the Executive Secretary, Presidential Communications Operations Office (PCOO), Media Accreditation Registration Office (MARO), and Presidential Security Group. The dispute arose following the Securities and Exchange Commission’s (SEC) revocation of Rappler's Certificate of Incorporation (COI) on January 11, 2018, for violating foreign equity restrictions in mass media. Consequently, Rappler and its affiliated jou Case Digest (G.R. No. 246126) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties Involved
- Petitioners: Patricia Marie I. Ranada, Mara Alyssabel D. Cepeda, Raymon G. Dullana, Franklin Y. Cimatu, Mauricio E. Victa, Camille Kristina S. Elemia, Ralph Martin S. Rivas, Baltazar Espinosa Lagsa, and Rappler, Inc. (collectively, Rappler Journalists and Rappler).
- Petitioners-in-Intervention: Included journalists, media practitioners, student journalists, members of the academe, and Pagbabago@Pilipinas Foundation, Inc.
- Respondents: Office of the President, Office of the Executive Secretary, Presidential Communications Operations Office (PCOO), Media Accreditation Registration Office (MARO), and Presidential Security Group.
- Background
- On January 11, 2018, the Securities and Exchange Commission (SEC) revoked Rappler's Certificate of Incorporation (COI) for violating constitutional and statutory foreign equity restrictions in mass media.
- Following the SEC revocation, Rappler and its journalists were effectively banned from covering any presidential events involving President Rodrigo Duterte, including public events.
- The petitioners viewed this as a "ban" enforced through verbal orders from President Duterte, based on three verbal declarations labeling Rappler a "fake news outlet" and invoking "executive action" to enforce the ban.
- Respondents characterized the situation as Rappler's loss of "special access" due to failure to meet accreditation requirements tied to SEC registration, IPC Press ID, and Malacañang Press Corps (MPC) membership.
- Accreditation requirements include:
- Recognition and endorsement as a bona fide media organization by the PCOO;
- Approval by MPC officials;
- One year in operation;
- Accreditation by the International Press Center (IPC);
- Registration with the SEC.
- Ranada's renewal application for IPC Press ID in 2018 was denied due to Rappler's revoked SEC registration.
- Procedural History
- Petition for Certiorari and Prohibition filed on April 10, 2019, seeking to prohibit respondents from enforcing the ban and declaring it void.
- Three petitions-in-intervention were filed by groups of journalists and media entities.
- Respondents filed a consolidated comment asserting the revocation of Rappler’s accreditation as legitimate.
- Petitioners responded with replies asserting constitutional violations.
Issues:
- Whether the ban or denial of accreditation preventing Rappler and its journalists from covering presidential events violates the constitutional freedom of the press.
- Whether the respondents’ enforcement of accreditation requirements constitutes prior restraint or subsequent punishment on free press.
- Whether the petitioners were denied procedural due process and equal protection.
- Whether the case remains justiciable despite supervening events (mootness).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)