Case Digest (G.R. No. 164785)
Facts:
Eliseo F. Soriano v. Ma. Consoliza P. Laguardia, G.R. Nos. 164785 and 165636, March 15, 2010, Supreme Court En Banc, Velasco Jr., J., writing for the Court.
Petitioner Eliseo F. Soriano is the host and acknowledged Executive Producer of the television program Ang Dating Daan (ADD), a nightly televised bible exposition that carried a "G" (general patronage) rating from the Movie and Television Review and Classification Board (MTRCB). Respondents include Ma. Consoliza P. Laguardia, Chairperson of the MTRCB, members of the MTRCB, and several ministers of the Iglesia ni Cristo (INC) who lodged complaints. The dispute arose after INC ministers aired a program that played allegedly spliced recordings purporting to show contradictions in Soriano's teachings; in response, on August 10, 2004, Soriano used vulgar language on air referring to an INC minister (Michael) in terms that the complainants characterized as obscene and offensive.
The MTRCB acted: it preventively suspended the airing of ADD for twenty days and, after hearings, found Soriano guilty and imposed a three‑month suspension on him from appearing on the program. Soriano filed two petitions with the Supreme Court: G.R. No. 164785 (challenging the preventive suspension) and G.R. No. 165636 (challenging the three‑month suspension); the cases were consolidated. In its April 29, 2009 decision, the Court modified the MTRCB's penalty by directing that the three‑month suspension apply to the television program Ang Dating Daan, rather than personally suspending petitioner Soriano.
Petitioner moved for reconsideration of that April 29, 2009 Decision, raising five main contentions: (1) the suspension constitutes an unconstitutional prior restraint and abridges freedom of religion and expression; (2) his utterances were an exercise of religion and thus immune from MTRCB regulation; (3) the Court erred in finding his language obscene/offensive; (4) the Court should follow a non‑interf...(Subscriber-Only)
Issues:
- Does the three‑month suspension imposed on the program constitute an unconstitutional prior restraint or an abridgement of petitioner's freedoms of speech and religion?
- Were petitioner's utterances on August 10, 2004 an exercise of religion entitled to special protection?
- Did the Court err in finding the language used to be offensive or obscene and thus incompatible with the program's "G" rating?
- Should the Court adopt a policy of non‑interference in conflicts between religious groups, thereby exempting religious broadcasts from MTRCB regulation?
- Was there a violation of due process in penalizing the program when, petitio...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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