Case Digest (G.R. No. 223451)
Facts:
In Antonio F. Trillanes IV v. Hon. Evangeline C. Castillo-Marigomen and Antonio L. Tiu (G.R. No. 223451, March 14, 2018), petitioner Senator Trillanes sponsored Senate Resolution No. 826 to probe alleged overpricing in Makati infrastructure projects. During a Senate Blue Ribbon Sub-Committee hearing, private respondent Tiu claimed “absolute ownership” of the Hacienda Binay estate via Sunchamp Real Estate Corporation, prompting Trillanes to characterize him in media interviews as a “front,” “nominee,” or “dummy” of former Vice President Binay. Tiu filed a complaint for defamation in RTC Quezon City (Branch 101), alleging that Trillanes’s remarks, made outside official Senate debates, tarnished his reputation and triggered steep share-price declines in his publicly listed companies, AgriNurture, Inc. and Greenergy Holdings, Inc. Trillanes answered, raising special and affirmative defenses of truth, fair commentary, parliamentary immunity under Article VI, Section 11 of the 1987 CoCase Digest (G.R. No. 223451)
Facts:
- Legislative inquiry and public statements
- Petitioner Senator Trillanes filed Proposed Senate Resolution No. 826 directing the Senate Blue Ribbon Sub-Committee to investigate alleged overpricing (P1.601 B) of Makati City Hall II Parking Building, the Makati City Hall Building, and related anomalies by former and local officials.
- At the SBRS hearings (October 8, 22 and 30, 2014), former Vice Mayor Mercado testified on VP Binay’s 350-hectare Hacienda Binay in Rosario, Batangas, and alleged that overpricing on Makati projects funded development expenses. Based on an unnotarized one-page Agreement between Sunchamp Real Estate Corporation (private respondent’s company) and Gregorio, Jr., petitioner publicly opined in media interviews that private respondent Tiu was a “front,” “nominee,” or “dummy” of VP Binay.
- Civil action and procedural history
- On October 22, 2014, private respondent Antonio L. Tiu filed a Complaint for Damages (Civil Case No. R-QZN-14-10666-CV) alleging that petitioner’s statements from October 8–14, 2014 defamed him, caused a steep drop in the share prices of AgriNurture, Inc. and Greenergy Holdings, Inc., and sought ₱4 M moral damages, ₱500 K exemplary damages, and ₱500 K attorney’s fees.
- In his Answer with Motion to Dismiss, petitioner raised special and affirmative defenses: truth/fact, public-figure/fair comment doctrine, parliamentary immunity under Art. VI, Sec. 11, freedom of speech, and moved for a preliminary hearing on these defenses under Section 6, Rule 16.
- RTC, Branch 101, Quezon City, denied the motion to dismiss and the motion for reconsideration in Orders dated May 19 and December 16, 2015, ruling that parliamentary immunity and jurisdiction issues required full trial and that a preliminary hearing was barred by the pending motion to dismiss.
- Petitioner filed a petition for certiorari under Rule 65 before the Supreme Court, assailing the May 19 and December 16 Orders for grave abuse of discretion.
Issues:
- Whether the petition for certiorari should have been filed first with the lower courts in accordance with the doctrine of hierarchy of courts.
- Whether petitioner’s media interview statements are shielded by parliamentary immunity (Speech or Debate Clause, Art. VI, Sec. 11, 1987 Constitution).
- Whether jurisdiction lies with the courts or with the Senate regarding petitioner’s statements and the defamation complaint.
- Whether a preliminary hearing on special and affirmative defenses was proper under Rule 16, Section 6.
- Whether the Complaint for Damages sufficiently states a cause of action for defamation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)