Case Digest (G.R. No. 164785)
Facts:
In Eliseo F. Soriano v. Maria Consoliza P. Laguardia, et al. (G.R. Nos. 164785 & 165636, decided March 15, 2010), petitioner Eliseo F. Soriano, host and executive producer of the religious television program Ang Dating Daan, aired daily from 10:00 p.m. to midnight, was charged by ministers of the Iglesia ni Cristo with using vulgar and obscene language in his August 10, 2004 broadcast. The respondents, through the Movie and Television Review and Classification Board (MTRCB), initially imposed a 20–day preventive suspension of the program under Presidential Decree No. 1986 and later found Soriano guilty of violating the show’s “G” (General Patronage) rating by employing contextually inappropriate invectives—e.g., comparing his critic to a “puta” whose “itataas” and “ibaba” function in a sexually graphic manner. The MTRCB’s Hearing and Adjudication Committee suspended the program for three months. Soriano filed separate petitions for certiorari (G.R. No. 164785) and prohibition (GCase Digest (G.R. No. 164785)
Facts:
- Parties and Background
- Eliseo F. Soriano – petitioner, presiding minister and host–producer of the television program *Ang Dating Daan*, aired nationwide with a “G” (general patronage) rating.
- Respondents – Movie and Television Review and Classification Board (MTRCB) members and Iglesia ni Cristo ministers who filed complaints against Soriano.
- Broadcast Incident and Administrative Action
- August 10, 2004 broadcast – on *Ang Dating Daan*, Soriano reacted in strong language to a rival Iglesia ni Cristo program (*Ang Tamang Daan*) that had allegedly spliced and misrepresented his prior statements.
- MTRCB preventive suspension – imposed a 20-day suspension on the program under PD 1986, Sec. 3(d) for alleged violations of its “G” rating requirement.
- Formal penalty – after a hearing, the MTRCB imposed a three-month suspension on *Ang Dating Daan* for contextual use of vulgar and potentially obscene language on prime-time television.
- Judicial Proceedings
- Petitions filed – Soriano sought certiorari relief in G.R. No. 164785 and G.R. No. 165636 challenging preventive and penalty suspensions, later consolidated.
- Supreme Court decision (April 29, 2009) – affirmed MTRCB’s authority, modified the penalty so that the three-month suspension applied to the program (not personally to Soriano), and upheld the preventive suspension.
- Motion for reconsideration – filed by Soriano raising five grounds; resolved by a Supreme Court Resolution denying reconsideration.
Issues:
- Whether the three-month suspension constitutes an unconstitutional prior restraint on speech.
- Whether Soriano’s broadcast utterances fall within the exercise of religion and are thus immune from regulation.
- Whether the language used was legally offensive or obscene under the “G” rating standards.
- Whether the Court should have applied non-interference in intra-religious conflicts.
- Whether due process was violated by penalizing the program without proper representation of the registered producer.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)