Case Summary (G.R. No. 123881)
Factual Background
The NBI charged Webb and others with rape with homicide based on Jessica Alfaro’s sworn statement. Viva Productions contracted Alfaro for a biographical film scheduled to premiere on September 11, 1995, and publicly exhibit from September 13. Webb asserted that promoting or exhibiting the film would violate the sub judice rule and infringe his rights as an accused.
Trial Court Orders
RTC Parañaque, upon Webb’s contempt petition and after viewing the film, issued a Cease and Desist Order (September 8, 1995) barring the premiere, public exhibition, and marketing of the movie. Concurrently, Webb obtained an ex parte temporary restraining order from RTC Makati enjoining the film’s promotion and exhibition nationwide.
Court of Appeals Decision
Viva Productions sought relief via certiorari in the Court of Appeals without first moving for reconsideration in the trial courts. The CA consolidated the petitions and, on December 13, 1995, dismissed them, sustaining the RTC orders.
Legal Issues Presented
- Whether RTC Parañaque unreasonably curtailed Freedom of Expression absent a clear and present danger.
- Whether RTC Makati validly exercised jurisdiction over an injunction action identical to the contempt proceedings in RTC Parañaque.
- Whether Webb committed forum shopping by filing duplicative actions in two coordinate courts.
Forum Shopping Analysis
The Supreme Court found that Webb’s civil injunction case in Makati and his contempt petition in Parañaque sought the same preliminary relief—preventing the film’s exhibition under the sub judice rule—thus constituting willful forum shopping in violation of Administrative Circulars No. 28-91 and 04-94. Although the contempt proceeding (criminal contempt) and the injunction with damages (civil) are formally distinct, the identical objective and relief rendered the Makati action a subterfuge. RTC Makati abused its discretion by not deferring to RTC Parañaque, consolidating the cases, or suspending proceedings to avoid conflicting orders.
Sub Judice Rule and Jurisdiction
Once RTC Parañaque acquired jurisdiction over the contempt petition and the sub judice issue, it precluded concurrent jurisdiction by other courts on that same question. Permitting both courts to adjudicate the identical issue risked conflicting injunctions and disorderly administration of justice.
Free Expression Consideration
Having resolved the case on forum shopping grounds, the Court did not reach whether the prior restraint met the “cle
Case Syllabus (G.R. No. 123881)
Facts
- On June 19, 1995, the NBI charged Hubert J.P. Webb and eight others with Rape with Homicide in connection with the Vizconde Massacre, based on the sworn statement of Maria Jessica M. Alfaro, docketed as I.S. No. 95-402 before the Department of Justice.
- The case generated an intense media frenzy, with front-page news for at least two months focusing on Alfaro as the NBI’s star witness.
- While the DOJ investigation was ongoing, Alfaro entered into a movie contract with Viva Productions, Inc. to film her life story as “The Jessica Alfaro Story.”
- After preliminary investigation, an Information for Rape with Homicide was filed on August 10, 1995, as Criminal Case No. 95-404 before the Regional Trial Court (RTC) of Parañaque, Branch 274.
- On August 25, 1995, Webb sent letters to Viva and Alfaro warning that the movie’s promotion and scheduled showing would violate the sub judice rule and infringe upon his constitutional rights as an accused.
- Despite these warnings, Viva aggressively promoted the film through print, broadcast media, and billboards, with a premiere set for September 11, 1995 at the New Frontier Theater and regular exhibition from September 13, 1995 in some sixty theaters.
Procedural History
- September 6, 1995: Webb filed a Petition for Contempt in Criminal Case No. 95-404 (Parañaque RTC), alleging contumacious acts under Section 3, Rule 71 of the Revised Rules of Court.
- September 8, 1995: After a full-day hearing and viewing of the movie, Parañaque RTC issued a Cease and Desist Order restraining the film’s premiere and public exhibition, and prohibiting promotion and marketing.
- September 8, 1995: Webb instituted Civil Case No. 95-1365 (Injunction with Damages) before Makati RTC, Branch 58, obtaining an ex parte Temporary Restraining Order enjoining Viva from further promotion, advertising, marketing, or exhibition of the movie.
- Viva did not seek reconsideration in either RTC, but filed petitions for certiorari with the Court of Appeals (CA) in CA-G.R. Nos. SP-38407 and SP-38408, praying for a temporary restraining order and writ of preliminary injunction.
- December 13, 1995: The CA dismissed both petitions, sustaining the orders of the Parañaqu