GR 155282; (January, 2005) (Digest)
G.R. No. 155282; January 17, 2005
MOVIE AND TELEVISION REVIEW AND CLASSIFICATION BOARD (MTRCB), petitioner, vs. ABS-CBN BROADCASTING CORPORATION and LOREN LEGARDA, respondents.
FACTS
On October 15, 1991, ABS-CBN aired an episode of “The Inside Story” hosted by Loren Legarda titled “Prosti-tuition,” depicting female students working as prostitutes to pay tuition. The program named the Philippine Women’s University (PWU) and used its building facade as a backdrop, causing uproar and prompting complaints to the MTRCB. The MTRCB initiated a case against ABS-CBN and Legarda for violating Presidential Decree No. 1986 by airing the program without prior review and approval.
Respondents argued that “The Inside Story” is a public affairs program, news documentary, and socio-political editorial protected by constitutional freedom of the press, thus exempt from MTRCB’s prior restraint. The MTRCB Investigating Committee found them liable and imposed a fine, an order affirmed by the MTRCB Chairman. Respondents then filed a special civil action for certiorari with the Regional Trial Court (RTC), which ruled in their favor, declaring the cited provisions of P.D. No. 1986 and its rules inapplicable to “The Inside Story” and similar public affairs programs.
ISSUE
Whether the MTRCB has the power or authority to review “The Inside Story” prior to its television broadcast.
RULING
Yes, the MTRCB has the authority. The Supreme Court granted the petition, reversing the RTC Decision. The Court held that Section 3(b) of P.D. No. 1986 explicitly grants the MTRCB the power to review “all television programs,” with no exemption for public affairs programs, news documentaries, or socio-political editorials. The law’s plain language is clear and leaves no room for interpretation; thus, all television programs fall under MTRCB’s review jurisdiction.
The Court distinguished this case from Iglesia ni Cristo v. Court of Appeals, which involved a religious program. Here, “The Inside Story” is a secular public affairs program. The Court emphasized that while freedom of the press is paramount, it is not absolute and is subject to regulation. The MTRCB’s review power constitutes a valid form of prior restraint justified by the need to protect societal interests, such as the welfare of the youth and public order. The requirement of prior review is a content-based regulation permissible under the Constitution to prevent the broadcast of objectionable material. Therefore, respondents were obligated to submit the program for classification before airing.