Facts:

The case involves Conrado R. Banal III as the petitioner against Judge Delia H. Panganiban, in her capacity as Presiding Judge of the Regional Trial Court (RTC) of Makati City, and other respondents namely Ma. Teresa G. Winternitz, Cristina G. Feibel, Raquel L. Gonzalez, and the People of the Philippines. The events took place in Makati City, with the core issues arising from the libelous articles Banal published in the "Breaktime" column of the Philippine Daily Inquirer on August 1 and August 12, 2000. The respondents, who were officers of Welbilt Construction Corporation and Wack Wack Condominium Corporation, filed six criminal informations for libel against Banal. The allegations were predicated on the assertion that Banal's articles maliciously exposed the respondents to public hatred by insinuating their involvement in illegal activities. Upon arraignment, Banal pleaded not guilty and subsequently filed a Motion to Quash, which was granted by the RTC on April

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Facts:

Background of the Libel Complaint

• A complaint was filed by Maria Teresa G. Winternitz, Cristina G. Feibel, and Raquel L. Gonzalez, officers of Welbilt Construction Corporation and Wack Wack Condominium Corporation, against Conrado R. Banal III.
• The complaint arose from petitioner’s libelous articles titled "House of the Rising Sun" and "Heist Cold Beer!" published in the “Breaktime” column of the Philippine Daily Inquirer on August 1 and August 12, 2000 respectively.

Filing of Criminal Informations

• Following the complaint, six informations for libel were filed in the RTC of Makati City, Branch 64 (Criminal Cases Nos. 01-693 to 01-698) against petitioner and Sylvia G. Cancio.
• The informations uniformly alleged that the libelous article was published in English in Makati City, with no differentiation in the naming of parties or specific details regarding the article, except for the name of the parties and the particular work involved.

Arraignment and Filing of the Motion to Quash

• Upon arraignment, petitioner entered a plea of not guilty.
• On February 11, 2002, he filed a Motion to Quash the informations on the ground that the trial court lacked jurisdiction, arguing that the allegations failed to state the actual residence of the offended party or the precise place where the article was printed and first published.

Trial Court Proceedings and Subsequent Developments

• In an Order dated April 9, 2002, the RTC granted the motion to quash and dismissed the cases for lack of jurisdiction, basing its ruling on the failure of the informations to specify that the libelous article was printed and first published in Makati City or that the offended party resided there.
• On May 1, 2002, respondents filed an Omnibus Motion for Reconsideration requesting the amendment of the informations to include the missing venue details.
• The trial court ruled that the amendment was merely formal since it did not affect the accused’s ability to challenge jurisdiction nor alter his defense.
• Petitioner then filed a petition for certiorari and prohibition under Rule 45 of the Rules of Court before the Court of Appeals, alleging grave abuse of discretion in recalling the April 9, 2002 Order and permitting the amendment.
• The Court of Appeals, in its decision dated October 15, 2004 and the subsequent March 17, 2005 Resolution, dismissed the petition, affirming the correctness of the trial court’s ruling and the allowance of the amendment.

Issue:

Jurisdiction of the RTC of Makati City

• Whether the criminal informations for libel failed to allege the requisite venue details (i.e., actual residence of the offended party or the printing and first publication site of the libelous article) as required under Article 360 of the Revised Penal Code.
• Whether the insufficiency in these allegations warranted a dismissal on the ground of lack of jurisdiction.

Nature of the Amendment to the Informations

• Whether the amendment made by the prosecution to include the location details is a matter of form or substance.
• Whether such an amendment, done after arraignment, is permissible given that it apparently addresses a fatal defect in the original allegations.

Alleged Grave Abuse of Discretion

• Whether recalling the prior court order which quashed the informations and allowing them to be amended constituted a grave abuse of discretion on the part of the trial court.
• Whether the trial court acted within its authority in allowing the addition of form-related details that clarify, rather than alter, the substantive allegations of the offence.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)