G.R. No. 202284 - Seming vs. Alamag

Petitioner: Froilan L. Hong, who served as Director for Administration of Lord’s Flock Catholic Charismatic Community.
Respondents: Thirty-four members of the same community, including Iluminado Aragon, Ma. Elena Aragon, Susan Ramos, Henry Tan, Marilou Villamor, Teresita Tan, among others, who later became complainants.
Lord’s Flock was established on April 4, 1986 by the Spouses Rodriguez, Froilan L. Hong, and several Catholic priests.
The community maintained a defined hierarchical structure through various councils (Directors, Elders, Advisors, Coordinators, and Workers).

In 1998, internal conflict arose when Fr. Larry Faraon and the Spouses Rodriguez had a falling out, with allegations concerning morality and misuse of funds.
As a response to these disagreements, certain members (later the respondents) were accused of spreading rumors and falsehoods against the established leadership and against the teachings embodied in the community’s guidebook, the Shema.
Petitioner, as a founding director, along with the spouses Rodriguez, appealed to members to desist from these activities, but their warnings went unheeded.

On January 21, 2002, a Notice was posted on the community’s bulletin board, signed by petitioner, declaring that 34 members were confirmed as having spread “lies, evil nonsense and falsehood” against the leadership and thus were expelled.
Out of these 34 expelled members, 28 filed joint complaint-affidavits for libel against petitioner in February 2002 before the Office of the City Prosecutor of Quezon City.
Petitioner responded on April 24, 2002 by filing a motion to consolidate the cases and subsequently a Counter-Affidavit.

On August 1, 2008, Prosecutor Rodrigo del Rosario issued a Resolution finding probable cause against petitioner for libel, leading to the filing of an Information with the RTC.
Petitioner submitted an Urgent Motion for Reconsideration, asserting that his actions were in accordance with the teachings of the community and denying malice.
In a Supplement dated March 27, 2009, petitioner argued violations of his constitutional rights—to present evidence fully and to have his case disposed of promptly—given the six-year lapse before the resolution finding probable cause.

RTC-Branch 215, in its Order dated March 22, 2010, denied the Motion to Withdraw the Information, noting that the notice contained defamatory imputations that specifically ascribed vice or defect upon clearly identified respondents.
A Motion for Reconsideration was subsequently filed by petitioner, which was denied in an Order dated December 20, 2010 by RTC-Branch 105 after the case was transferred due to inhibition issues.
The Court of Appeals (CA) issued a Decision on June 27, 2013 affirming the orders of the RTCs, finding that they had independently assessed the available evidence and determined that probable cause for libel existed.
The CA also noted that petitioner’s allegations regarding the violation of his constitutional right to a speedy trial were unsubstantiated, as the delay was not proven to be capricious, malicious, or oppressive.
An additional Resolution dated October 30, 2013 by the CA denied petitioner’s subsequent Motion for Reconsideration, prompting him to file the present Petition for Review on Certiorari challenging both the denial of the motion to withdraw information and the alleged delay.

Whether the trial courts, by denying the motion to withdraw the Information and upholding the findings of probable cause, committed grave abuse of discretion.
Whether the lengthy delay in the resolution finding probable cause (six years from the filing of the complaints) violated petitioner’s constitutional right to a speedy trial and to speedy disposition of a case.
Whether the actions of the trial courts in conducting an independent evaluation of the evidence were sufficient in light of the defense’s contention that the case was prejudged and that their constitutional rights were violated.