Case Digest (G.R. No. 184800) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Wonina M. Bonifacio, et al. v. Regional Trial Court of Makati, Branch 149 and Jessie John P. Gimenez, petitioner trustees of Parents Enabling Parents Coalition, Inc. (PEPCI) faced thirteen libel charges under Articles 353 and 355 of the Revised Penal Code arising from allegedly defamatory statements posted on the PEPCI website between August and October 2005. On October 18, 2005, private respondent Gimenez, representing the Yuchengco Family and Malayan Insurance Co., Inc., filed a criminal complaint for libel before the Makati City Prosecutor’s Office. By Resolution of May 5, 2006, probable cause was found and informations were filed in the Regional Trial Court (RTC) of Makati, Branch 149. Petitioners first sought review before the Secretary of Justice, resulting in a June 20, 2007 resolution reversing probable cause. Meanwhile, on June 6, 2006, petitioners moved to quash the informations in Makati RTC for lack of jurisdiction and failure to state a punishable offense. On Oct Case Digest (G.R. No. 184800) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioners: Wonina M. Bonifacio, Jocelyn Upano, Vicente Ortuoste and Jovencio Pereche, Sr., officers and trustees of Parents Enabling Parents Coalition, Inc. (PEPCI).
- Private Respondent: Jessie John P. Gimenez, on behalf of the Yuchengco Family (Ambassador Alfonso Yuchengco and Helen Y. Dee) and Malayan Insurance Co., Inc., filed a criminal complaint for libel under Articles 353 and 355, RPC.
- Underlying Controversy
- PEPCI was formed by planholders of Pacific Plans, Inc. (subsidiary of Yuchengco Group) who alleged nonpayment of benefits after PPI’s rehabilitation filing.
- PEPCI maintained a public website (pepcoalition.com), a blogspot (pacificnoplan.blogspot.com), and a Yahoo group, where critical articles were posted between August 25 and October 2, 2005, imputing malice and ill tactics against the Yuchengco Family and Malayan.
- Procedural History
- May 5, 2006: Makati City Prosecutor found probable cause and filed thirteen separate Informations for libel in RTC Makati.
- June 20, 2007: Justice Secretary reversed the finding of probable cause, ruling that “internet libel” was not recognized under RPC.
- October 3, 2006: RTC Makati, Branch 149 granted petitioners’ Motion to Quash the Information for lack of venue allegations (no “printed and first published” allegation in Makati).
- March 8, 2007: On prosecution’s motion for reconsideration, RTC ordered amendment of the Information to cure venue defect.
- March 20, 2007: Amended Information filed alleging the article was “first published and accessed” in Makati City.
- April 22, 2008 and August 12, 2008: RTC denied petitioners’ Motion to Quash the Amended Information and its reconsideration, respectively.
- Petitioners filed a petition for Certiorari and Prohibition before the Supreme Court, alleging grave abuse of discretion.
Issues:
- Whether petitioners violated the rule on hierarchy of courts, rendering their petition dismissible.
- Whether the RTC committed grave abuse of discretion in admitting the Amended Information despite alleged jurisdictional defects.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)