Case Digest (G.R. No. 123881)
Facts:
Viva Productions, Inc. v. Court of Appeals and Hubert J.P. Webb, G.R. No. 123881, March 13, 1997, Supreme Court Third Division, Melo, J., writing for the Court.Petitioner Viva Productions, Inc. produced a film entitled "The Jessica Alfaro Story" based on the life of Ma. Jessica M. Alfaro; Hubert J.P. Webb (private respondent) was one of the accused in the criminal case arising from the "Vizconde Massacre." After Alfaro executed a sworn statement and an Information for Rape with Homicide was filed (Criminal Case No. 95-404 before the Paranaque RTC, Branch 274), Viva entered into a contract with Alfaro to film her story while the criminal case was under investigation.
Private respondent Webb sent warning letters (August 25, 1995) to Viva and Alfaro asserting that the planned film exhibition would violate the sub judice rule and his constitutional rights as an accused, but Viva continued promotion and scheduled a premiere for September 11, 1995, with general release set for September 13, 1995.
On September 6, 1995 Webb filed a Petition for Contempt in Criminal Case No. 95-404 (Paranaque RTC, Branch 274), alleging that the film's promotion and intended exhibition were contumacious under Section 3, Rule 71, Revised Rules of Court. After hearings and a viewing of the film on September 8, 1995, the Paranaque RTC issued a Cease and Desist Order restraining the premiere and public exhibition.
Also on September 8, 1995 Webb filed a separate civil action for Injunction with Damages (Civil Case No. 95-1365) in the Makati RTC, Branch 58, which issued an ex parte Temporary Restraining Order and later a writ of preliminary injunction enjoining Viva from marketing and exhibiting the film nationwide pending final disposition of the Paranaque criminal trial.
Petitioner elevated the matter to the Court of Appeals by petition for certiorari (consolidated as C.A. G.R. Nos. SP-38407 and SP-38408), seeking a TRO and provisional reliefs; on December 13, 1995 the Court of Appeals dismissed the consolidated petitions, affirming both the Paranaque and Makati RTC orders. After denial of its motion for r...(Pro-only)
Issues:
- Did private respondent and/or his counsel engage in forum shopping by filing substantially identical actions in two courts of concurrent jurisdiction?
- Could the Makati Regional Trial Court validly exercise jurisdiction to enjoin the exhibition of the film notwithstanding the pending contempt proceedings and restraining order of the Paranaque RTC?
- Did the Paranaque RTC lawfully restrain petitioner’s freedom of expression without...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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