Before this Court is a Rule 45 Petition, seeking to review the 6 May 2005 Regional Trial (RTC) Decision in Special Civil Action No. RTC 2005-0032. In the Decision, the RTC dismissed petitioners’ Rule 65 Petition, which assailed the directive of Judge Marvel C. Clavecilla requiring Roberto Dipad to submit the latter’s Income Tax Returns (ITRs) for the years 2001 to 2003.

American independent cinema has always been a notoriously difficult concept to define. This is primarily because the label ‘independent’ has been widely used since the early years of American cinema by filmmakers, film critics, industry practitioners, trade publications, academics and cinema fans, to the extent that any attempt towards a definition is almost certainly destined to raise objections.