Case Digest (G.R. No. 164785)
Facts:
On August 10, 2004, at around 10:00 p.m., Eliseo F. Soriano, host of the television program Ang Dating Daan aired on UNTV 37, delivered a series of harsh expletives directed at Michael M. Sandoval, calling him among other things a “legitimate son of the devil,” a “liar,” “gago,” and “worse than a whore,” with graphic sexual references. Two days later, Jessie L. Galapon and seven other members of the Iglesia ni Cristo filed separate, nearly identical affidavit-complaints with the Movie and Television Review and Classification Board (MTRCB), alleging petitioner’s broadcast violated Presidential Decree No. 1986 (“PD 1986”) and its Implementing Rules and Regulations (“IRR”). On August 16, 2004, after a preliminary conference at which petitioner appeared, the MTRCB issued a 20-day preventive suspension order against Ang Dating Daan under PD 1986, Sec. 3(d) and Sec. 3, Chapter XIII of the IRR. Petitioner sought reconsideration and recusal of certain Board members, then withdrew his moCase Digest (G.R. No. 164785)
Facts:
- Background
- Eliseo F. Soriano hosted the religious TV program *Ang Dating Daan* on UNTV 37, rated “G” for general audiences.
- On August 10, 2004, during an episode aired at around 10:00 p.m., Soriano uttered profane and insulting remarks toward a rival minister, including the phrases “lehitimong anak ng demonyo,” “gago ka talaga,” and repeated references to “putang babae.”
- MTRCB Proceedings
- Two days later, Jessie L. Galapon and others (all Iglesia ni Cristo members) lodged separate but similar complaints with the Movie and Television Review and Classification Board (MTRCB).
- On August 16, 2004, after a preliminary conference, the MTRCB issued a preventive suspension of *Ang Dating Daan* for 20 days and set a preliminary investigation in accordance with P.D. 1986, its IRR, and the MTRCB Rules of Procedure.
- Soriano sought—but then withdrew—a motion for reconsideration and filed two Rule 65 petitions in the Supreme Court (G.R. Nos. 164785 and 165636) to nullify the suspension and, later, the MTRCB’s three-month suspension decision issued on September 27, 2004.
Issues:
- G.R. No. 164785 (Preventive Suspension Order)
- Whether P.D. 1986 and its IRR validly authorize preventive suspension orders.
- Whether Soriano was deprived of due process and equal protection.
- Whether the order violated freedom of religion, speech, and expression.
- G.R. No. 165636 (Three-Month Program Suspension)
- Whether Section 3(c) of P.D. 1986 is unconstitutional as an undue infringement on freedom of religion, speech, and expression.
- Whether the implementing rules, procedures, and MTRCB decision denying due process and equal protection.
- Whether P.D. 1986 unduly delegated legislative power by failing to specify penalties.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)