G.R. No. 196094 - People vs. Macasaet

Three consolidated petitions for review on certiorari under Rule 45 of the Rules of Court were filed.
The consolidated cases involve multiple petitions corresponding to different G.R. Nos. – 196094, 196720, and 197324 – relating to libel complaints arising from interrelated newspaper articles published in Malaya and Abante.
The libel complaints originally stemmed from nine counts of libel allegedly committed through articles written by Amado “Jake” Macasaet, with statements deemed derogatory to public figures, namely Casimiro “Ito” M. Ynares, Jr. and Narciso “Jun” Y. Santiago, Jr.

Accused/Appellants include Amado “Jake” Macasaet (publisher, chairman, and writer), Enrique P. Romualdez (executive editor), and Joy P. Delos Reyes (editor), noting that Delos Reyes is deceased.
Complainants/Respondents vary by petition, with Ynares and Santiago initiating separate libel complaints against the accused.
The articles in question include “Santiago’s gambling habits” (April 21, 1999 issue of Malaya) and “NCA-UCAP Feud: Walang trabaho, personalan lang” (March 1, 1999 issue of Malaya).
While the Abante libel complaint was dismissed, two separate Informations for libel (targeting certain counts) were subsequently filed pertaining to the Malaya articles.

The complaints underwent preliminary investigation and various motions including motions to dismiss on the ground of improper venue and violation of the right to speedy disposition.
At the Regional Trial Court (RTC) level:

In Criminal Case No. 08-263273 (RTC Manila, Branch 37), motions to dismiss were filed and denied based on allegations that the Information sufficiently linked the accused to the publication at Malaya’s address at Port Area, Manila.
In Criminal Case No. 08-263272 (RTC Manila, Branch 36), similar motions were raised regarding the alleged libelous article on March 1, 1999.

Both the RTC branches ruled against the accused’s motions to dismiss despite the issues raised regarding the venue and alleged delay in the resolution of the case.

In G.R. No. 196094, the CA decision (October 2010) nullified the RTC orders dated November 3, 2009 and January 29, 2010, dismissing the libel Information on the ground of defective venue.
In G.R. No. 196720, the CA affirmed the RTC’s Orders in denying the motion to dismiss, ruling that the venue was proper and that the accused had waived any violation of their right to speedy trial by not objecting earlier.
In G.R. No. 197324, the CA likewise affirmed the RTC’s ruling in a similar manner regarding the filing of the case and the timing of the accused’s objections.
Subsequent motions for reconsideration were filed at the CA level but were denied in all three petitions.

Delays in the proceedings were highlighted, including an inordinate lapse of over eight years by the Provincial Prosecutor before finally dismissing complaints for want of jurisdiction due to improper venue.
The accused argued that such delays violated their constitutional right to a speedy disposition of their cases.
The issue of whether the “address” provided in the Information is equivalent to the place where the defamatory article was “printed and first published” became central to the venue issue.
Evidence, including records from the DOJ Consolidated Resolution and statements from Malaya, was pivotal in establishing that Port Area, Manila was indeed where the article was written and published.

Whether the Information charged against Macasaet and Romualdez was sufficient in form and substance to establish the crime of libel.
Whether the Information properly alleged the venue – specifying the place of publication – especially given that it only stated “address at Port Area, Manila” without explicitly using the term “printed and first published.”

Whether the delay in the filing, consideration, and disposition of both criminal cases (i.e., the libel complaints) violated the accused’s constitutional right to a speedy trial and speedy disposition.
Whether the accused’s failure to timely object to the delay operates as a waiver of their right, or whether the delay can be deemed “vexatious, capricious and oppressive” as alleged.