G.R. No. L-27514 - Laquian vs. Baltazar

Marcelo D. Mendiola, the private respondent, initiated a civil action (Civil Case No. 2312) before the Court of First Instance of Pampanga on May 16, 1963, to recover damages for an alleged defamatory letter allegedly written by Fausto D. Laquian on May 21, 1962.
Subsequently, on May 19, 1964, Mendiola lodged a criminal complaint (Criminal Case No. 4216) with the Municipal Court of San Fernando, Pampanga, accusing Laquian of libel based on the same incident of written defamation.

On April 26, 1965, Laquian moved to dismiss the criminal complaint filed in the municipal court, arguing that the latter lacked jurisdiction under the exclusive provision of Article 360 of the Revised Penal Code as amended by Republic Act No. 1289.
Municipal Judge Jose L. Baltazar ruled against this motion by issuing an order on May 27, 1965.
A subsequent motion for reconsideration was also denied on August 4, 1965.

Following the denials in the municipal court, on August 27, 1965, Laquian commenced a special civil action for certiorari (Civil Case No. 2834) before the Court of First Instance of Pampanga.
The petition sought to annul the orders of May 27 and August 4, 1965, and to declare that the municipal court did not possess jurisdiction over the libel complaint.
In its May 18, 1966 order, the Court of First Instance dismissed the petition on the grounds that the municipal court had concurrent jurisdiction over libel cases, alongside the Court of First Instance, in view of provisions in Article 355 of the Revised Penal Code and Section 87(c) of Republic Act No. 296 as amended by Republic Act No. 3828.

The lower courts maintained that Congress, through subsequent legislation (notably RA No. 3828), had effectively accorded concurrent jurisdiction to both the municipal courts and the Court of First Instance in cases where the penalty did not exceed prision correccional or imprisonment for not more than six years, or a fine within prescribed limits.
Laquian contended that, under RA No. 1289 as amended, the filing of the civil action in the Court of First Instance of Pampanga had already vested exclusive jurisdiction over any corresponding criminal libel action – a point further reinforced by later legislative action (RA No. 4363).

Whether the municipal court of San Fernando, Pampanga, has jurisdiction over the criminal libel case considering that the civil case for damages was already filed in the Court of First Instance of Pampanga.

Whether Republic Act No. 3828, which confers concurrent jurisdiction on municipal courts for certain offenses, effectively amends or overrides the exclusive jurisdiction provision as laid down by Republic Act No. 1289 in Article 360 of the Revised Penal Code.
Whether Congress intended for concurrent jurisdiction in libel cases or whether the exclusive jurisdiction of the court of first instance shall prevail where both actions are based on the same defamatory act.

Whether the municipal judge erred in denying Laquian’s motion to dismiss the criminal complaint on jurisdictional grounds.
Whether the Court of First Instance was correct in dismissing Laquian’s petition for certiorari on the concurrent jurisdiction theory.