Title
Ranada vs. Office of the President
Case
G.R. No. 246126
Decision Date
Jun 27, 2023
Petitioners challenged the ban preventing Rappler journalists from covering presidential events, alleging it violated press freedom; the Court dismissed the case as moot following the end of Duterte's term.
freedom of the press
accreditation
presidential events
A

Case Summary (G.R. No. 246126)

Petitioners

The principal relief sought was a petition for certiorari and prohibition with prayers for injunctive relief, filed April 10, 2019, by Rappler and its journalists to prohibit respondents from implementing a purported ban that would prevent Rappler and its journalists from covering any and all newsworthy events involving the President, and to declare the ban void.

Respondents

Respondents, represented by the Office of the Solicitor General, defended the denial of “special access” to presidential events as an administrative consequence of Rappler’s revoked corporate registration and the resulting failure to meet accreditation requirements administered by PCOO offices (IPC and MARO) and by the Malacañang Press Corps (MPC).

Key Dates

Relevant chronological points include: SEC Decision revoking Rappler’s Certificate of Incorporation on January 11, 2018; petition filed April 10, 2019; supplemental filings and replies through 2020; and the Supreme Court decision dismissing the petitions as moot on June 27, 2023. The Court noted that President Duterte’s term ended on June 30, 2022, which is a dispositive supervening event.

Applicable Law

The Court evaluated issues under the 1987 Constitution (Article III, Section 4 — freedom of speech, expression, and of the press) and referenced applicable statutory and regulatory material cited by the parties, including RA No. 4363 and PD No. 576 (regarding press self-regulation), the SEC Decision revoking Rappler’s COI, IPC and MARO accreditation rules, and the MPC by-laws. The 1987 Constitution was applied as the governing constitutional charter.

Procedural History

After the petition and three petitions-in-intervention were filed, the Court required respondents to comment (July 30, 2019). Respondents filed a consolidated comment (September 24, 2019); petitioners and intervenors filed replies; and the Court issued further procedural resolutions, including dispensing with one intervenor’s late reply. The parties’ factual and legal contentions were fully briefed before the Court reached the question of justiciability.

Antecedents: SEC Decision and Accreditation Processes

The SEC revoked Rappler’s Certificate of Incorporation on January 11, 2018 for alleged violations of foreign equity restrictions in mass media. The PCOO’s International Press Center (IPC) issues IPC Press IDs and administers accreditation for special access to Malacañang and presidential events; MARO processes accreditation for presidential events and endorses organizations to the MPC; the MPC by-laws list criteria for membership, including SEC registration and PCOO recognition. Petitioners’ IPC and MARO accreditations expired December 31, 2017 and renewal efforts for 2018 were denied in light of the SEC decision.

Petitioners’ Factual and Legal Contentions

Petitioners alleged a de facto ban beginning February 20, 2018, that barred Rappler and its journalists from covering presidential events, including those held in public places. They attributed the ban to verbal declarations by President Duterte labeling Rappler “fake news” and invoking “executive action” to bar Rappler pending SEC legitimacy. Petitioners characterized the exclusion as retaliatory subsequent punishment based on the content of their reporting, a violation of press freedom under Article III, Section 4, and as lacking procedural due process and equal protection. They contended the accreditation regime, insofar as it requires government licenses or approvals, was an impermissible government intrusion on a self-regulating press.

Respondents’ Factual and Legal Contentions

Respondents framed the situation as an administrative enforcement of accreditation requirements. They contended that special access to the President requires valid IPC Press IDs, MARO accreditation, and MPC membership, and that the January 11, 2018 SEC revocation meant Rappler no longer met the MPC by-laws’ SEC-registration requirement. Respondents argued that the denial of physical access did not equate to a constitutional abridgment of press freedom, that accreditation does not amount to prior restraint, that the restriction was content-neutral and administrative, and that no subsequent punishment or constitutional violation had been shown.

Issues Presented to the Court

The principal justiciability and substantive issues included whether alleged exclusion from presidential events constituted an unconstitutional abridgment of press freedom (including whether accreditation requirements were a prior restraint or unlawful subsequent punishment), whether petitioners were denied due process and equal protection, and whether the Court could resolve the dispute in its original jurisdiction given the factual questions posed.

Court’s Threshold Analysis — Mootness

The Court held that supervening events mooted the petitions. The cessation of President Duterte’s term on June 30, 2022, and subsequent indications that Rappler journalists were included among MPC members under the succeeding administration deprived the Court of practical remedial power. The Court articulated the settled doctrine that federal judicial review requires an actual, live case or controversy; where supervening events render relief ineffectual, the case is moot and not proper for adjudication. The Court acknowledged exceptions to mootness doctrine but concluded they did not justify continuing the present action.

Court’s Procedural Limitation — Factual Determinations

The Court emphasized that its original jurisdiction is primarily for questions of law, not for resolving disputed factual issues, and explained the doctrine that the Supreme Court is not a trier of facts. The Court identified multiple material factual disputes—whether Rappler remained an MPC member after the SEC decision; the precise scope and incidence of the alleged ban (special access only versus physical exclusion from events open to the public); and whether the actions stemmed directly from presidential directives versus administrative accreditation enforcement. Because these contested issues required evidentiary findings, the Court declined to resolve the substantive constitutional claims in this original-action posture.

Court’s Disposition

On the basis of mootne

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