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Case Digest - Legal Writing
Case Digest - Legal Writing
Assignment 1
PONENTE: Puno, J
FACTS:
The religious group Iglesia ni Cristo has filed a case against the MTRCB for tagging
the episodes of its TV program Series Nos. 116, 119, 121 and 128 sometime in the
months of September, October and November 1992 and tagging them as "X" or not
for public viewing on the ground that they "offend and constitute an attack against
other religions which is expressly prohibited by law."
The respondent had answered the petition stating that it was clearly a violation of the
Article 2, section 6 of the constitution or the freedom of religion and exercise thereof.
The RTC ruled in favour of the petitioner group and ordered the board to issue the
necessary permit for the broadcast of the petitioner’s program. However, this was
answered by the Board through a appeal passed to the CA.
The CA ruled that: (1) the respondent Board has jurisdiction and power to review the
TV program “Ang Iglesia ni Cristo,” and (2) the respondent Board did not act with
grave abuse of discretion when it denied permit for the exhibition on TV of the three
series of “Ang Iglesia ni Cristo” on the ground that the materials constitute an attack
against another religion. It ruled in favour of the respondent Board.
Because of the decision, the petitioner was dissatisfied and appealed to the Supreme
Court.
Issues:
Does the respondent board have the power to review the petitioner’s programs?
If the board gravely abused its discretion when it prohibited the airing of the
program?
Ruling:
[The Court voted 13-1 to REVERSE the CA insofar as the CA sustained the action of
the respondent Board’s X-rating petitioner’s TV Program Series Nos. 115, 119, and
121. It also voted 10-4 to AFFIRM the CA insofar as the CA it sustained the
jurisdiction of the respondent MTRCB to review petitioner’s TV program entitled
“Ang Iglesia ni Cristo.”]
Ratio Decidendi / Reasoning:
The application of the free exercise of religion clause can be understood that
although there is free exercise of therefor, the State has still the capacity to regulate
when it will bring about clear and present danger in which the State has the
obligation to protect its people against.
However, there was a failure of the respondent to prove the dangers against the state.
It ruled that respondent board cannot squelch the speech of petitioner Iglesia ni
Cristo simply because it attacks other religions, even if said religion happens to be
the most numerous church in our country. In a State where there ought to be no
difference between the appearance and the reality of freedom of religion, the
remedy against bad theology is better theology