Case Digest (G.R. No. 123881) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Viva Productions, Inc. v. Court of Appeals and Hubert J.P. Webb (G.R. No. 123881, March 13, 1997), petitioner Viva Productions, Inc. contracted with Ma. Jessica M. Alfaro to produce “The Jessica Alfaro Story” while the rape with homicide case stemming from the Vizconde Massacre was under investigation. On June 19, 1995, the NBI filed charges (I.S. No. 95-402) against Hubert J.P. Webb and eight others based on Alfaro’s sworn statement. After the Department of Justice filed an information on August 10, 1995 (Criminal Case No. 95-404, RTC Parañaque, Br. 274), Webb warned Viva and Alfaro by letters dated August 25, 1995 that the scheduled premiere (September 11, 1995) and public exhibition (from September 13, 1995) of the movie would violate the sub judice rule and his constitutional rights as an accused. Undeterred, Viva pursued promotion and marketing. On September 6, 1995, Webb filed a petition for contempt in the Parañaque court and, after hearing on September 8, that court i Case Digest (G.R. No. 123881) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- The underlying criminal case (Vizconde Massacre)
- On June 19, 1995, nine suspects, including Hubert J.P. Webb, were charged with rape with homicide based on the sworn statement of Ma. Jessica M. Alfaro (I.S. No. 95-402, DOJ).
- The case generated intense media coverage, spotlighting Alfaro as the star witness.
- The movie project and preliminary investigation
- Alfaro entered into a contract with Viva Productions, Inc. to film her life story, “The Jessica Alfaro Story,” while DOJ investigations were ongoing.
- On August 10, 1995, after preliminary investigation, an Information for rape with homicide was filed in RTC Parañaque, Branch 274 (Crim. Case No. 95-404).
- Warnings and promotional activities
- On August 25, 1995, Webb sent letters to Viva and Alfaro warning that the scheduled premiere (September 11) and public showing (September 13) would violate the sub judice rule and infringe his rights.
- Despite warnings, Viva promoted the film via print, broadcast, and billboards, scheduling public exhibition in about 60 theaters.
- RTC orders and appeals
- September 6, 1995 – Webb filed a petition for contempt in RTC Parañaque, Branch 274, alleging contumacious promotion of the film.
- September 8, 1995 – After hearing and viewing the movie, the Parañaque court issued a Cease and Desist Order enjoining the film’s exhibition.
- September 8, 1995 – Webb filed a separate civil case for injunction with damages in RTC Makati, Branch 58, which issued an ex parte TRO and later a writ of preliminary injunction barring promotion and exhibition nationwide until trial in Parañaque concluded.
- Viva sought certiorari before the Court of Appeals without moving for reconsideration in the RTCs; CA consolidated the petitions (SP-38407 & SP-38408) and upheld both lower court orders.
Issues:
- Whether the Parañaque RTC violated Viva’s freedom of expression without a showing of clear and present danger when it issued a prior restraint on the film’s exhibition.
- Whether the Makati RTC had jurisdiction over the injunction case identical to the contempt proceeding pending in Parañaque, which had already acquired jurisdiction.
- Whether Webb engaged in prohibited forum shopping by filing two cases with identical facts, issues, and reliefs in coequal courts.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)