G.R. No. 123263 - People vs. Metropolitan Trial Court of Quezon City, Branch 32

On January 30, 1995, an information for libel was filed against Isah V. Red in the Regional Trial Court (RTC) of Quezon City, initiating Criminal Case No. 95-60134, which was raffled to Branch 82.
Red filed a motion to quash the information on the ground that the RTC lacked jurisdiction over the offense.
The RTC Judge granted the motion and, by an Order dated March 29, 1995, remanded the case to the Metropolitan Trial Court (MetroTC) of Quezon City “for proper action/disposition in the premises.”
The remand was based on Section 2 of R.A. No. 7691, which, effective April 15, 1994, vested exclusive original jurisdiction over all offenses punishable with imprisonment not exceeding six (6) years (irrespective of the fine and other penalties) in the Municipal Trial Courts; however, this provision was applied by the lower court to remit the case.

Once transferred, the case was docketed as Case No. 43-00548 and raffled to Branch 43 of the MetroTC.
The private prosecutor, acting “under the control and supervision of the Fiscal,” filed a “Manifestation and Motion to Remand” dated August 1, 1995, urging the case’s return to the RTC.
The motion invoked Article 360 of the Revised Penal Code, which explicitly designates the court of first instance (i.e., the Regional Trial Court) to handle libel cases, citing precedents such as Jalandoni v. Endaya and related jurisprudence.
The MetroTC denied the motion by Order dated August 14, 1995, relying on the notion that R.A. No. 7691, as a modern law, impliedly repeals the older Revised Penal Code provisions not only by operation but also by making the applicable penalty lighter.
The MetroTC later dismissed subsequent motions for reconsideration (Order dated September 7, 1995) and reiterated its position in another Order dated October 18, 1995, even as the trial continued with the prosecution calling its next witness.

The petitioner (People of the Philippines) sought to declare the Orders of August 14, September 7, and October 18, 1995, null and void on the ground that they were issued without jurisdiction.
It also prayed for an injunction enjoining the MetroTC from further proceedings in Criminal Case No. 43-00548.
Lastly, the petitioner requested that the case be remanded to the Executive Judge of the RTC of Quezon City for proper disposition.

The petitioner argued based on Article 360 of the Revised Penal Code and cited decisions (e.g., Jalandoni v. Endaya, People v. Topacio, Time, Inc. v. Reyes) reaffirming that libel cases fall exclusively within the RTC’s jurisdiction.
The petitioner contended that laws vesting jurisdiction exclusively in a particular court (i.e., special laws) are to prevail over the general jurisdiction provided by statutory laws such as R.A. No. 7691.
Supporting citations included Philippine Railway Co. v. CIR and Villegas v. Subido, among others, emphasizing that a general law should not be construed to repeal or amend a specific provision unless there is an unmistakable legislative intent.
The petitioner further referenced Administrative Order No. 104-96, issued on October 21, 1996, which categorically states that libel cases shall be tried solely by the Regional Trial Courts.

Whether the RTC or the MetroTC (or any other first level court) has exclusive original jurisdiction over criminal actions of libel.
Whether the operating provision of R.A. No. 7691, which expands jurisdiction over offenses punishable with imprisonment not exceeding six (6) years to inferior courts, applies to libel cases.

Whether Article 360 of the Revised Penal Code, which specifically designates the RTC as the proper forum for libel cases, should prevail over the general jurisdiction granted under R.A. No. 7691.
Whether the subsequent enactment of R.A. No. 7691 diminishes or overrides the special law principles and precedents establishing the RTC’s exclusive jurisdiction over libel.

Whether the orders issued by the MetroTC (dated August 14, September 7, and October 18, 1995) are valid given that they were made without proper jurisdiction.
Whether interlocutory orders such as these may become immutable or final, thereby impacting the venue and proceeding of libel cases.