NOTABLE CASES THAT REACHED THE SUPREME COURT

One of the most notable cases involving the MTRCB that reached the
Supreme Court is the case of Iglesia Ni Cristo vs. Court of Appeals. After
submitting several episodes to the MTRCB, the board disallowed the
broadcast of several episodes – 115, 119, 121, and 128 – on the ground that
they “offend and constitute an attack against other religions which is
expressly prohibited by law.” INC appealed the Board’s ruling on Episode 128
to the Office Of The President which then reversed the Board’s ruling and
allowed the said episode to air. INC, invoking its right to religious freedom,
filed a civil case before the Regional Trial Court (RTC) against the Board,
alleging that the Board acted without jurisdiction or with grave abuse of
discretion when it required INC to submit the episodes prior to telecast, and
disallowing the broadcast of Episode 128. The MTRCB argued that it acted
well within its power, as given by Presidential Decree No. 1986. However, the
trial court ruled in favor of the INC, which lead the dissatisfied Board to file an
appeal to the Court of Appeals. The
appellate court then reversed the ruling of the RTC, stating that the Board acted

well within its powers when it required the INC to submit the episodes, and

disallowed the broadcast on Episode 128. and The Court held that the MTRCB

has the power to review the program of INC as the law clearly states that the Board

has the power to screen, review and examine all television programs. The Court

stated that the MTRCB cannot rely on the ground attack against another religion in

giving the X rating. The ground attack against other religion was merely added by

the Board in its rules since it wasn’t in the grounds to justify an order prohibiting an

airing of the program; lastly, that the MTRCB failed to apply the clear and present

danger rule the Court cited the ruling in Victoriano vs. Elizalde Rope Workers union

expressing that

“It is only where it is unavoidably necessary to prevent an immediate and

grave danger to the security and welfare of the community that

infringement of religious freedom may be justified, and only to the

smallest extent necessary to avoid the danger.”

ABS-CBN then appealed to the Regional Trial Court of Quezon City. The petitioner. MTRCB ruled against ABS-CBN and fined them and ordered that all tapes should be submitted to them before airing the episode. The episode caused uproar in the PWU community that lead to the filing of complaint to the MTRCB claiming that the episode besmirched the name of PWU and resulted in the harassment of some its female students. the airing of which is protected by the constitutional provision on freedom of expression and of the press. the RTC ruled in favor of ABS-CBN and annulled the decision and resolution of the MTRCB. ABS-CBN argued that “The Inside Story is a public affairs program. Chapter III and Section 7. 1986 and Section 3. MTRCB.” and that the MTRCB had no power to impose any form of prior restraint to the respondents. ABS- CBN. ABS-CBN aired Prosti-tuition.It was expressed that it is inappropriate to use the clear and danger test for it is the content of the speech and not the time. and making permanent the injunction against MTRCB. place. Chapter IV of the MTRCB’s Rules and Regulations. The Inside Story. It is one of the episodes of the program. news documentary and socio-political editorial. The Philippine Women’s University (PWU) was named by some of the students involved and the façade of their campus was conspicuously served as the background. initiated a formal complaint against ABS-CBN alleging that they did not submit a copy of the episode of The Inside Story and because of the non-submission of a copy for review. they are violating Section 7 of Presidential Decree No. which depicted female students moonlighting as prostitutes for them to pay for their tuition fees. The second case that reached the Supreme Court is MTRCB vs. and manner of the speech which is the issue here. . declared that the implementing rules does not cover The Inside Story and other similar programs.

The Court then differentiated the freedom of the press and freedom of religion saying that the latter has accorded preferred status in the Constitution but the Courts did not exempt them from the review powers of the MTRCB. as distinguished from news analyses. The Inside Story was clearly not a newsreel but more of a public affairs program. Newsreels as defined in the Implementing Rules of Presidential Decree 1986 as “straight news reporting. Since The Inside Story is a television program.MTRCB filed a motion for reconsideration but was denied hence the filing of petition for review on certiorari attacking the decision of the RTC. The Court resurrected the ruling in Iglesia Ni Cristo vs. commentaries and opinions. reiterating that it is clear that the Board has the power to screen. . Talk shows on a given issue are not considered newsreels.” With the meaning of newsreels clarified. Court of Appeals. review and examine all television programs. it is within the jurisdiction of the MTRCB to review it.