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IGLESIA NI CRISTO v. CA

## FACTS:

The petitioner in this case is Iglesia ni Cristo, a religious organization with a television program called "Ang Iglesia ni Cristo." The Board of Review for Motion Pictures and Television (BRMPT) classified the petitioner's TV program series as "X" or not for public viewing, stating that they offend and attack other religions. The petitioner filed a civil case against the BRMPT, alleging jurisdictional issues and grave abuse of discretion. The trial court held a hearing on the petitioner's prayer for a writ of preliminary injunction, where both parties presented their arguments and evidence.

The trial court granted a writ of preliminary injunction on petitioner's bond, prohibiting the BRMPT from denying the petitioner a permit to exhibit their TV show. The trial court later rendered a judgment ordering the BRMPT to grant the necessary permit but directing the petitioner to refrain from offending and attacking other religions in their program. The petitioner filed a motion for reconsideration, seeking to delete the provision prohibiting them from offending and attacking other religions. The trial court granted the motion and prohibited the BRMPT from requiring the submission of program tapes.

The BRMPT appealed to the Court of Appeals, which reversed the trial court's decision and upheld the BRMPT's power to review the program and deny the permit. The petitioner then filed a petition for review on certiorari with the Supreme Court, raising various issues including the power of the BRMPT to censor religious programs and whether the program is indecent and contrary to law and good customs.

The case primarily revolves around the interpretation of Presidential Decree No. 1986 and the power of the BRMPT to regulate television programs. The petitioner argues that its religious program falls outside the scope of television programs and that its prohibition would violate the freedom of religion guaranteed by the Constitution. The court, however, rejects this argument and emphasizes the state's authority to regulate acts or omissions that affect the public, even if they arise from religious beliefs.

ISSUES

The main issues in this case are:

  1. Whether the respondent Board of Review for Motion Pictures and Television (MTRCB) has the power to review the TV program "Ang Iglesia ni Cristo."

  2. Assuming that the MTRCB has the power to review, did it commit grave abuse of discretion when it prohibited the airing of petitioner's religious program for constituting an attack against other religions and being indecent, contrary to law and good customs?

RULING

  1. The Supreme Court affirmed the jurisdiction of the MTRCB to review all television programs, including the petitioner's religious program "Ang Iglesia ni Cristo." The law, as stated in P.D. No. 1986, grants the MTRCB the power to screen, review, and examine all television programs.

  2. The Supreme Court, however, reversed the decision of the Court of Appeals insofar as it sustained the MTRCB's decision to x-rate the petitioner’s TV program series (Nos. 115, 119, and 121). This ruling was founded on the conclusion that the action taken by the Board against the program constituted an improper application of prior restraint on religious speech. The court recognized the exercise of religious freedom, noting that even harsh critiques among religious beliefs must be tolerated to uphold free speech, provided such expressions do not breach the standard of clear and present danger which threatens public interest—a threshold the MTRCB did not meet in this case.

PRINCIPLES

  1. Freedom of Religion and Speech: Religious speech, like other forms of expression, is safeguarded by the constitutional guarantee of freedom of speech.

  2. Administrative Powers and Religious Exercise: Administrative bodies, such as the MTRCB, possess jurisdiction to regulate content broadcast on television but must exercise this in consideration of constitutional freedoms including religious exercise and free speech.

  3. Clear and Present Danger Test: Regulations restricting religious expression through broadcasting must only be upheld if such expression presents a clear and present danger of a substantive evil recognized by law.

  4. Prior Restraint and Judicial Review: Prior restraints on freedom of speech and religion are generally disfavored and are subject to judicial review to ensure they do not encroach upon constitutional protections unduly.

  5. Neutrality in Religious Disputes by the State: In regulating religious content, the state must maintain neutrality and cannot favor any religion nor shield one from criticism by another.

This case reaffirms the robust protection afforded to expressions of religious belief in the Philippines, highlighting the delicate balance between regulation by government bodies and constitutional freedoms.