Case Digest (G.R. No. 122068)
Facts:
- Juanito Manzano is the petitioner, while Hon. Redentor Valera, Judge of the Municipal Trial Court (MTC) of Bangued, Abra, and Vilma A. Bobila are the respondents.
- On June 2, 1994, a criminal complaint for libel was filed against Manzano, a Senior Police Officer 1.
- The complainant, Vilma Bobila, accused Manzano of making false and defamatory statements about her in the police blotter, suggesting she made threats against him.
- The MTC initially recognized that the Regional Trial Court (RTC) had jurisdiction and forwarded the case to the Office of the Provincial Prosecutor.
- The prosecutor later argued that the MTC should handle the case, leading to the MTC accepting it.
- Manzano filed a motion to dismiss based on lack of jurisdiction, which the Assistant Provincial Prosecutor supported.
- The respondent Judge denied the motion to dismiss and a subsequent motion for reconsideration.
- Manzano's final appeal was denied, prompting him to file a petition for certiorari and prohibition, questioning the MTC's jurisdiction.
Issue:
- (Unlock)
Ruling:
- The Supreme Court granted the petition, declaring the orders of the respondent Judge dated August 2 and August 30, 1995, null and void due to lack of jurisdiction.
- The Court permanently enjoined the MTC from further handling Criminal Case No. 5728 and ordere...(Unlock)
Ratio:
- The Supreme Court stated that Article 360 of the Revised Penal Code governs jurisdiction over libel cases, assigning it to the Courts of First Instance (now RTC).
- The Court noted that while Republic Act 7691 expanded the jurisdiction of first-level courts, it did not grant jurisdiction over libel cases to the MTC.
- The Court...continue reading
Case Digest (G.R. No. 122068)
Facts:
The case involves Juanito Manzano as the petitioner and Hon. Redentor Valera, Judge of the Municipal Trial Court (MTC) of Bangued, Abra, along with Vilma A. Bobila as the respondent. The events leading to this case began on June 2, 1994, when a criminal complaint for libel was filed against Manzano, who was then a Senior Police Officer 1. The complainant, Vilma Bobila, an employee of the Bureau of Internal Revenue, accused Manzano of maliciously entering false and defamatory statements about her in the police blotter at the Bangued Police Station. The statements allegedly portrayed Bobila as making grave threats against Manzano, including a gesture interpreted as a sign of intent to kill.
Initially, on October 24, 1994, the respondent Judge recognized that the Regional Trial Court (RTC) had jurisdiction over the case and forwarded the records to the Office of the Provincial Prosecutor. However, the prosecutor later argued that the MTC should take cognizance of the case, citing amendments in B.P. 129 and Republic Act 7691. Following this, the MTC accepted the case, prompting Manzano to file a motion to dismiss based on a lack of jurisdiction. The Assistant Provincial Prosecutor, instead of opposing the motion, supported Manzano's argument and requested that the case be elevated to the RTC. Despite this, the respondent Judge denied the motion to dismiss and subsequen...