G.R. No. 164785 – 605 Phil. 43 – Political Law – Constitutional Law – General Principles – Elements of a State – Government – Parens Patriae
Eliseo Soriano is a preacher who has a television show (Ang Dating Daan) being aired on UNTV 37. During one episode in August 2004, he hurled invectives against the Iglesia Ni Cristo and its ministers. He called them “sons of devils” and other profanity. He even cursed them on TV. Ma. Consoliza Laguardia was then the Movie and Television Review and Classification Board (MTRCB) chairperson. As a result, the MTRCB issued a 20-day suspension against Ang Dating Daan.
ISSUE: Whether or not the suspension is proper.
HELD: Yes under the doctrine of parens patriae. The State acts as guardian of the public, especially children, using its parens patriae role to regulate morally and socially harmful broadcast content. The State has the authority to protect youth from offensive language on general‑view programs. The parens patriae doctrine empowers the State to regulate speech that could harm children’s moral and intellectual development—even if speech elements originate from religious contexts. In fact, in this case, Soriano’s speech is not protected speech as it was obscene, with no real religious content and were mere insults that did not morph into religious discourse.
