Ranada v. Office of the President
REITERATIONFacts
The Antecedents: The underlying dispute arose from the Securities and Exchange Commission's (SEC) revocation of Rappler Inc.'s Certificate of Incorporation in January 2018, citing violations of foreign equity restrictions in mass media. Following this revocation, Rappler and its journalists were allegedly banned from covering events involving the then-President, Rodrigo Duterte. Petitioners contended this ban was a direct result of President Duterte's personal animus towards Rappler and its reporting, constituting a violation of press freedom. Procedural History: Rappler and its journalists filed a Petition for Certiorari and Prohibition with the Supreme Court, seeking to nullify the alleged ban. Subsequently, several groups of journalists and media practitioners, along with a foundation, filed Petitions-in-Intervention. The respondents, including various offices within the Office of the President, filed their consolidated comment. The Court then required the petitioners and petitioners-in-intervention to file their respective replies. The Petition: The Petition, filed under Rule 45, sought writs to prohibit the respondents from implementing the ban on Rappler and its journalists from covering presidential events. Petitioners argued that the ban abridged the freedom of the press, constituted a form of subsequent punishment, and failed the test of strict scrutiny. They also raised arguments of denial of procedural due process and equal protection. The respondents, conversely, maintained that the prohibition was merely a consequence of Rappler's failure to comply with accreditation rules following the SEC's revocation of its incorporation, and not a violation of press freedom.
Issue(s)
Whether the case has been rendered moot by the expiration of President Duterte's term and the subsequent access granted to Rappler journalists under the new administration. Whether the Supreme Court can resolve the substantive constitutional issues despite the presence of disputed factual allegations regarding the scope and basis of the ban.
Ruling
The Petition for Certiorari and Prohibition as well as the Petitions-in-Intervention are DISMISSED on the ground of mootness.
Ratio Decidendi
On Issue 1: The Court ruled that the case is moot because President Duterte's term ended on June 30, 2022, in accordance with Article VII, Section 4 of the Constitution. Since the petitioners' primary assertion was that the ban resulted from the executive department implementing the verbal directives of President Duterte, his departure from office removed the source of the alleged injury. A case is moot when it ceases to present a justiciable controversy, making any declaration of no practical use or value. Furthermore, evidence showed that Rappler journalists have been granted access to presidential events under the administration of President Ferdinand Marcos, Jr. While exceptions to mootness exist, the Court found that the passage of time and the change in administration rendered the issues stale, as no actual relief could be afforded to the petitioners. On Issue 2: The Court emphasized that it is not a trier of facts and cannot resolve cases where the resolution depends on determining factual issues. There were significant factual disputes, including whether Rappler remained a member of the Malacañang Press Corps (MPC) and the actual physical extent of the ban, such as whether it applied to public places. The petitioners and respondents had sharply contrasting views on the basis of the ban—whether it was a pretext for harassment or a legitimate enforcement of accreditation rules. Resolving these 'interlocking and overlapping issues' would require the evaluation of evidence, which is not the function of the Supreme Court in an original jurisdiction case. Consequently, the Court declined to rule on the substantive constitutional questions to maintain judicial restraint and adhere to the doctrine of hierarchy of courts.
Main Doctrine
A case is considered moot and academic when it ceases to present a justiciable controversy by virtue of supervening events, so that an adjudication of the case or a declaration on the issue would be of no practical value or use. While the Court may take cognizance of moot cases under specific exceptions—such as grave constitutional violations or matters of paramount public interest—it will decline to do so if the case involves interlocking factual issues. The Supreme Court is not a trier of facts; it is not equipped to receive and evaluate evidence in the first instance, and the doctrine of hierarchy of courts operates as a filtering mechanism to ensure the Court focuses on fundamental legal tasks.