IGLESIA NI CRISTO V.

COURT OF APPEALS
G.R. NO 11973, JULY 26, 1996

Facts:

Petitioner Iglesia ni Cristo has a televised program entitled “Ang Iglesia ni Cristo”
aired on Channel 2 every Saturday and Channel 13 every Sunday. The program deals
with the propagation of the petitioner’s beliefs, doctrines and practices. Sometime in
September, October and November of 1992, petitioner submitted tapes of its programs
to respondent Board of Review for Moving Pictures and Television. The Board classified
the series 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.”

Issue:
Whether or not that the MTCRB is vested with the power to censor religious
programs

Ruling:

No. Firstly, deeply ensconced in our fundamental law is its hostility against all
prior restraints on speech, including religious speech. Hence, any act that restrains
speech is hobbled by the presumption of invalidity and should greeted with furrowed
brows. Second, the “attacks” were mere criticisms of some of the deeply held dogmas
and tenets of other religions. Third, respondents cannot rely on the ground “attacks
against another religion” in x-rating the religious program of petitioner. Section 3 of PD
No. 1986 will reveal that it is not among the grounds to justify religion and order
prohibiting the broadcast of petitioner’s television program. The ground “attack against
another against another religion” was merely added by the Board in its Rules. This rule
is void for it runs smack against the hoary doctrine that administrative rules and
regulations cannot expand the letter and spirit of the law they seek to enforce. Fourth,
the respondents failed to apply the clear and present danger rule. In American Bible
Society v. City of Manila, the Supreme Court held: “The constitutionality guaranty of free
exercise and enjoyment of religious profession and worship carries with it the right to
disseminate religious information. Any restraind of such right can be justified like other
restraints on freedom of expression on the ground that there is a clear and present
danger of any substantive evil which the State has the right to prevent.”