Case Digest (G.R. No. 237620)
Facts:
Erwin Tulfo, Lilibeth Frondoso, Lynda Jumilla, Maria Progena, Estonillo Reyes, Anna Liza Eugenio, Fernando Garcia, Eugenio Lopez III, Luis F. Alejandro, Jose Ramon Olives, Jesus “Jake” Maderazo, Luisita Cruz‑Valdes, Jose “Jing” Magsaysay, Jr., and Alfonso “Pal” A. Marquez III v. People of the Philippines, Felipe L. Gozon, Gilberto R. Duavit, Jr., Marissa L. Flores, Jessica A. Soho, Grace Dela Pena‑Reyes, and John Oliver T. Manalastas, G.R. No. 237620, April 28, 2021, Supreme Court Third Division, Inting, J., writing for the Court.Petitioners were ABS‑CBN personalities and executives; private respondents were officers of GMA Network (and the People of the Philippines prosecuted the case). The dispute arose from live broadcast statements in July 2004 during coverage of Angelo dela Cruz’s return to the Philippines, wherein petitioners’ anchors and reporters publicly accused GMA‑7 of “stealing” or “pirating” ABS‑CBN’s exclusive video footage. GMA‑7 had aired footage it received via Reuters/CNN feeds; upon seeing ABS‑CBN reporters in that feed, GMA‑7 stopped airing it. The private respondents filed a libel complaint on July 27, 2004.
After a long lapse, two criminal informations for libel (dated January 28, 2013) were filed by the Quezon City Prosecutor and presented to Branch 88, RTC Quezon City. On February 14, 2013 the RTC found probable cause and ordered warrants of arrest; petitioners posted bail on February 18–19, 2013. Petitioners moved for reconsideration and filed an Ad Cautelam Motion to Quash (filed March 8, 2013), arguing lack of identifiability, malice, and insufficiency. The RTC denied both the motion for reconsideration and the motion to quash in an Order dated April 16, 2013, and later denied a Manifestation and Motion to Disqualify with Motion for Reconsideration on June 11, 2013; arraignment had been set for May 7, 2013.
Claiming grave abuse of discretion by the RTC, petitioners filed a Rule 65 petition for certiorari in the Court of Appeals. The CA (in CA‑G.R. SP No. 131601) dismissed the Rule 65 petition on August 17, 2017, affirming that (a) certiorari was not the proper remedy, (b) the informations were sufficient under Section...(Pro-only)
Issues:
- Is a petition for certiorari under Rule 65 the proper remedy to assail the RTC’s denial of the motion to quash the informations?
- Did the RTC commit grave abuse of discretion in denying petitioners’ motions such that certiorari is warranted?
- Are the informations sufficient in form and substance to charge the crime of libel?
- Does private respondents’ admission of unauthorized use of the footage vitiate the informations’ validity (...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)