G.R. No. L-37642 - People vs. Casuga y Munar

Accused Feliza Casuga y Munar was originally charged with grave slander on July 9, 1964 by the Municipal Court of San Fernando, La Union for uttering defamatory words by calling the offended party, Erlinda Munar, an unmarried woman and a distant relative of a person, the paramour of somebody.
The municipal court rejected her alibi defense and rendered a decision on September 8, 1964 ordering her to pay a fine of P20.00 with subsidiary imprisonment in case of insolvency, in addition to payment of costs.
The accused then filed an appeal directly to the La Union Court of First Instance, posting the required P100.00 appeal bond as fixed by the municipal court.

The La Union Court of First Instance re-arraigned the accused on December 23, 1964 after accepting her appeal from the municipal court’s judgment.
A full trial de novo was conducted with extensive hearings on multiple dates: October 11, 1965; December 9, 1965; December 29, 1965; August 11, 1966; October 4, 1966; and January 5, 1967. Evidence was closed upon the last hearing date.
On January 30, 1967, the trial court rendered its decision, rejecting the alibi defense and considering the defamatory remarks only moderately injurious, thereby convicting her of slight slander. The penalty imposed was a fine of P50.00 (with subsidiary imprisonment if insolvent) and the payment of costs. Additionally, the accused was ordered to indemnify the offended party in the amount of P500.00 by way of civil liability.

The accused filed a motion for reconsideration on February 8, 1967, seeking acquittal and a reduction of the imposed civil liability to P100.00. This motion was denied by the trial court.
In her subsequent notice of appeal directly to the Supreme Court, the accused based her argument solely on a question of law.

She contended that there was no legal basis for the judgment because the proceedings were null and void due to the participation of a private prosecutor who, despite initially reserving the right to file a separate civil case, withdrew that reservation.
Furthermore, she raised an additional jurisdictional issue, arguing that the crime of grave slander fell within the concurrent jurisdiction of municipal courts in provincial capitals or city courts and courts of first instance; thus, she claimed that her appeal should have been addressed directly to the Court of Appeals or the Supreme Court rather than to the La Union Court of First Instance.

Although the trial court ordered the record elevated to the Supreme Court, an oversight led to the records being forwarded initially to the Court of Appeals, where the parties filed their briefs.
The Solicitor-General (later a member of the Supreme Court) noted this oversight and requested that the appeal, which raised purely questions of law, be certified to the Supreme Court.
The appellate court eventually resolved this issue on September 19, 1973, and the case was transmitted to the Supreme Court on October 10, 1973.

Whether the participation of a private prosecutor—who had initially reserved the right to file a separate civil case but later withdrew that reservation—rendered the trial proceedings null and void due to his lack of legal personality to represent the prosecution.
Whether the belated objection raised by the accused-appellant on this matter (introduced through a motion for reconsideration) was legally tenable.

Whether the court of first instance, whose jurisdiction was expressly invoked by the accused-appellant in her direct appeal from the municipal court’s decision, lacked jurisdiction in rendering the judgment, given that the crime of grave slander falls under the area of concurrent jurisdiction.
Whether the accused-appellant’s subsequent challenge to the jurisdiction of the very court she had voluntarily submitted to is permissible under the doctrine of estoppel.