Case Digest (G.R. No. 93023) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Berteni CataluAa Causing v. People of the Philippines (G.R. No. 258524, October 11, 2023), petitioner Berteni CataluAa Causing was charged with two counts of Cyber Libel under Section 4(c)(4) of Republic Act No. 10175 (Cybercrime Prevention Act of 2012) in relation to Articles 353 and 355 of the Revised Penal Code (RPC). Respondent Congressman Ferdinand L. Hernandez filed a Complaint-Affidavit on December 16, 2020, alleging that on February 4 and April 29, 2019, Causing uploaded Facebook posts accusing Hernandez of stealing ₱225 million meant for Marawi siege victims. After the City Prosecutor of Quezon City found probable cause, two separate Informations were filed in the Regional Trial Court (RTC), Quezon City, on May 10, 2021, docketed as Criminal Cases R-QZN-21-04099 and R-QZN-21-04100. Causing moved to quash on prescription grounds, arguing that Cyber Libel is not a new crime and prescribes in one year under the RPC. Branch 93 of the RTC denied the Motion to Quash on Oct Case Digest (G.R. No. 93023) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and antecedents
- Petitioner Berteni CataluAa Causing (Causing) charged by Ferdinand L. Hernandez (Hernandez), Representative of South Cotabato-2nd District, with two counts of Cyber Libel under Section 4(c)(4) of RA 10175 in relation to Articles 353 and 355 of the Revised Penal Code (RPC) for Facebook posts dated February 4, 2019 and April 29, 2019.
- Hernandez alleged Causing maliciously imputed that he stole ₱225 million intended for Marawi siege victims via posting and sharing a Radyo Inquirer report on his public Facebook profiles.
- Procedural history
- After counter-affidavits and reply-affidavit, the OCP–Quezon City found probable cause and filed two Informations dated May 10, 2021 in RTC, Quezon City, Branch 93 (Crim. Cases R-QZN-21-04099 and R-QZN-21-04100).
- On June 28, 2021, Causing moved to quash the Informations as prescribed, arguing Cyber Libel is libel under the RPC prescribing in one year (Art. 90(4), RPC) and RA 10175 did not create a new crime.
- RTC denied the Motion to Quash on October 5, 2021, ruling prescription at 12 years under Act 3326 via Section 6, RA 10175, and prision mayor penalty; denied reconsideration on November 15, 2021.
- Causing filed a Rule 65 Petition for Certiorari challenging both RTC orders.
Issues:
- Is a Rule 65 Petition proper from the denial of a motion to quash and did Causing properly bypass lower courts?
- Which law governs prescription of Cyber Libel: Articles 90 & 91 of the RPC or Section 1 of Act 3326?
- Have the two counts of Cyber Libel prescribed under the correct prescriptive period and its reckoning?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)