G.R. No. 165732 - Safeguard Security Agency, Inc. vs. Tangco

Ascencion P. Olarte was charged with libel for allegedly writing and circulating letters containing defamatory, contemptuous, and derogatory statements against Visitacion M. Meris.
The libelous letters were dated from February to May 1954, with the first letter reportedly received on February 27, 1954 and subsequent ones on March 1, March 13, April 26, and May 9, 1954.
Miss Meris, the offended party, eventually lodged a libel complaint.

On January 7, 1956, Meris lodged a charge with the provincial fiscal of Pangasinan, which led to the assignment of the case to an assistant provincial fiscal.
Based on the fiscal’s advice, on February 22, 1956, a formal complaint for libel was filed with the Justice of the Peace Court of Pozorrubio, Pangasinan.
Defendant Olarte waived her right to a preliminary investigation in the Justice of the Peace Court, and the case was forwarded to the Court of First Instance of Pangasinan.
The corresponding information was subsequently filed on July 3, 1956.
Defendant moved to quash the information on the ground that the offense had prescribed under Article 90 of the Revised Penal Code, arguing that the prescriptive period continued running until the filing of the information in the Court of First Instance.
The lower court granted the motion to quash for prescription, dismissing the case with costs de oficio.
On appeal by Meris, the filing brief (initially prepared by private prosecutors and later adopted by the Solicitor General) supported the position that the filing of the complaint in the Justice of the Peace Court interrupted the running of the prescriptive period.

Article 90 of the Revised Penal Code provides that the crime of libel shall prescribe in two years, and Article 91 states that such period commences from when the offense is discovered and is interrupted by the filing of a complaint or information.
There was a critical issue regarding the venue and jurisdiction for filing libel cases, particularly after the amendment of Article 360 by Republic Act No. 1289, which emphasized that both civil and criminal actions for libel "shall" be filed with the Court of First Instance.
The dispute centered on whether the filing of a complaint with a Justice of the Peace Court qualifies as an interruption of the prescriptive period, given that under the amendment, the proper commencement of a criminal libel case is tied to filing in the Court of First Instance.

Whether the filing of the complaint for libel with the Justice of the Peace Court constitutes the commencement of judicial proceedings that interrupt the running of the statute of limitations under Article 91 of the Revised Penal Code.
Whether the amendment of Article 360 by Republic Act No. 1289, which designates the Court of First Instance as the proper venue for criminal as well as civil actions for libel, precludes a Justice of the Peace from effecting an interruption of the prescriptive period.