Case Digest (G.R. No. 205836) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines and Photokina Marketing Corporation v. Alfredo L. Benipayo, two informations for libel were filed against respondent Alfredo L. Benipayo, then Chairman of the Commission on Elections, before the Regional Trial Court (RTC) of Quezon City Branches 102 and 101. In Criminal Case No. Q-02-109407, Photokina Marketing Corporation, believing itself defamed by a speech delivered by Benipayo on January 31, 2002 at the University of the Philippines Diliman and published in the February 4 and 5, 2002 issues of the Manila Bulletin, filed an Affidavit-Complaint for libel. In Criminal Case No. Q-02-109406, the same corporation charged Benipayo with libel over statements made on March 13, 2002 during the ANC-23 television talk show “Point Blank.” In both cases, Benipayo questioned the jurisdiction of the RTC on the ground that as an impeachable officer he could not be prosecuted during his incumbency, or, alternatively, that if prosecution were possible it belonged Case Digest (G.R. No. 205836) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- G.R. No. 154473
- On January 31, 2002, Alfredo L. Benipayo, then COMELEC Chair, delivered a speech at the University of the Philippines–Diliman, later published in the Manila Bulletin (Feb. 4–5, 2002). He accused Photokina Marketing Corporation of attempting to “hoodwink” the government into a disadvantageous ₱6.5 billion contract.
- Photokina filed an Affidavit-Complaint for libel with the Quezon City Prosecutor, who filed an Information (Crim. Case No. Q-02-109407) before RTC Branch 102. Benipayo challenged jurisdiction, claiming status as an impeachable officer and that only the Sandiganbayan could try libel committed in relation to office.
- RTC Branch 102 dismissed the case (June 18, 2002) for lack of jurisdiction, finding that the alleged libel was committed in his official capacity and thus fell under Sandiganbayan jurisdiction. A motion for reconsideration was denied (June 23, 2002).
- G.R. No. 155573
- On March 13, 2002, on the ANC-23 show “Point Blank,” Benipayo alleged that Photokina funds amounting to US$2.4 million (≈₱120 million) were used in a PR campaign against him.
- Photokina filed an Affidavit-Complaint for libel; the Prosecutor filed an Information (Crim. Case No. Q-02-109406) before RTC Branch 101. Benipayo raised similar jurisdictional objections.
- RTC Branch 101 dismissed the case (June 25, 2002) and denied reconsideration (September 18, 2002), holding that libel committed in relation to office fell under Sandiganbayan’s exclusive jurisdiction.
Issues:
- Does the RTC have exclusive original jurisdiction over libel (written defamation) cases to the exclusion of all other courts?
- If jurisdiction is shared with the Sandiganbayan, does the relation of the libelous act to public office affect the proper forum?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)