Case Digest (G.R. No. 154473)
Facts:
People of the Philippines and Photokina Marketing Corporation v. Alfredo L. Benipayo, G.R. Nos. 154473 and 155573, April 24, 2009, the Supreme Court En Banc, Nachura, J., writing for the Court.In G.R. No. 154473, Alfredo L. Benipayo, then Chairman of the Commission on Elections (COMELEC), delivered a speech on January 31, 2002 at the University of the Philippines–Diliman which was later published in the Manila Bulletin (Feb. 4–5, 2002). Photokina Marketing Corporation (Photokina) believed the speech imputed corrupt dealings to it and filed an Affidavit‑Complaint for libel with the Office of the City Prosecutor of Quezon City (OCP‑QC). Benipayo challenged the prosecutor’s jurisdiction on the ground that, as an impeachable officer, he was immune from ordinary criminal prosecution during incumbency and that, if prosecutable, the Sandiganbayan and the Office of the Ombudsman had exclusive competence. Despite the jurisdictional protest, the City Prosecutor filed an Information for libel with the Regional Trial Court (RTC), Quezon City, Branch 102 (Crim. Case No. Q‑02‑109407). Photokina moved to inhibit Judge Salazar and to consolidate with the other libel case; the court later dismissed the case for lack of jurisdiction on June 18, 2002, holding that the alleged libel was committed in relation to Benipayo’s office and thus cognizable by the Sandiganbayan.
In G.R. No. 155573, the facts mirror a separate episode: on March 13, 2002 Benipayo, as COMELEC Chair, made on‑air statements on ANC’s Point Blank that Photokina allegedly funded a PR campaign and spent large sums in relation to the Photokina deal. Photokina filed a libel complaint; the City Prosecutor filed an Information with RTC, Quezon City, Branch 101 (Crim. Case No. Q‑02‑109406). Benipayo again moved to dismiss for lack of jurisdiction. The RTC, Branch 101, dismissed the information on June 25, 2002 and denied reconsideration on September 18, 2002.
Petitioners in both cases filed separate petitions for review on certiorari under Rules 122 and 45, arguing (inter alia) that the trial courts erred in (a) failing to resolve the motion to inhibit before the motion to dismiss, (b) finding the libel was committed in relation to office, (c) ruling they lacked jurisdiction and dismissing rather than endorsing to the Sandiganbayan. The Clerk of Court consolidated the petitions. The primary contested legal question before the Supreme Court became whether the RTC has ...(Pro-only)
Issues:
- Under existing law, does the Regional Trial Court have exclusive original jurisdiction over criminal and civil actions for written defamation to the exclusion of other courts, including the Sandiganbayan?
- If the RTC has exclusive jurisdiction over written defamation, was the trial court correct in dismissing the libel cases on the ground that the offenses were committed in relation to respondent's office?
- Did the trial court err procedurally in failing to resolve the motion to inhibit before resolving the motion to dismiss, and/or in dismissing r...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)