Case Digest (G.R. No. 210088) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Ellen T. Tordesillas et al. v. Puno et al. (G.R. No. 210088, October 1, 2018), journalists and media organizations led by petitioners Ellen Tordesillas, Charmaine Deogracias, Ashzel Hachero and James Konstantin Galvez, among others, sought damages and injunctive relief against then DILG Secretary Ronaldo Puno, DOJ Secretary Raul Gonzales, DND Secretary Gilbert Teodoro, PNP Chief Avelino Razon Jr., AFP Chief Hermogenes Esperon and other high‐ranking officials (collectively, respondents). On November 29, 2007, Senator Antonio Trillanes IV and members of the Magdalo group, facing contempt proceedings in the Makati RTC, walked out of the courtroom, seized the Manila Peninsula Hotel to call for President Arroyo’s ouster, and held a press conference. Reporters entered the hotel to cover the standoff. Police attempted to serve a contempt warrant on Trillanes’s group, ordered all occupants—including press—to vacate by 3:00 p.m., and, when this deadline elapsed, forcibly dispersed the Case Digest (G.R. No. 210088) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Manila Peninsula Standoff
- On November 29, 2007, Senator Antonio Trillanes IV, Brig. Gen. Danilo Lim, and other Magdalo officers walked out of the Makati RTC during their Oakwood Mutiny trial, proceeded to the Manila Peninsula Hotel, seized the lobby, and held a press conference calling for President Arroyo’s ouster.
- Numerous journalists, including several petitioners, followed to cover the event, relocating with the group from the lobby to a function room.
- Arrest of Journalists and Government Advisories
- Police led by NCRPO Chief Geary Barias attempted to serve a direct-contempt arrest warrant on Trillanes’ group; upon refusal to receive it, officers pushed it under the door and set a 3 p.m. deadline to vacate. Some journalists disobeyed, and after tear gas and warning shots, police broke in, arrested both mutineers and journalists, then released the latter the same night.
- High-ranking officials issued public warnings and an advisory:
- DILG Sec. Ronaldo Puno threatened obstruction and disobedience charges against journalists ignoring police orders.
- AFP Chief Hermogenes Esperon and DND Sec. Gilbert Teodoro supported investigating journalists for hindering operations.
- DOJ Sec. Raul Gonzales issued a written advisory to media CEOs cautioning that reporters who disobey lawful orders during emergencies may incur criminal liability.
- Procedural History
- Petitioners filed a Complaint for Damages and Injunction with a TRO application (January 28, 2008). The Makati RTC denied the TRO (Feb. 8, 2008), then dismissed the complaint for lack of cause of action (June 20, 2008).
- The Court of Appeals, in a May 31, 2013 Decision, affirmed the RTC’s dismissal and denial of injunctive relief, and in a Nov. 11, 2013 Resolution denied reconsideration. Petitioners filed a Rule 45 petition for review with the Supreme Court.
Issues:
- Cause of Action and First Amendment Claims
- Did the CA err in finding no actionable violation of press freedom when respondents’ advisory and statements allegedly constituted content-based prior restraint and chilling effect?
- Was the warrantless arrest of journalists plain censorship?
- Expert Witness Testimony
- Should the RTC and CA have admitted Dean Raul C. Pangalangan’s expert testimony on constitutional issues?
- Injunctive Relief
- Was the denial of the TRO and/or preliminary injunction proper under the requisite standards?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)