G.R. No. 173081 - Marcelo, Jr. vs. Villordon

Petitioners: 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 – all associated with ABS-CBN Broadcasting Corporation.
Respondents: People of the Philippines and several officers of GMA Network, Inc., including Felipe L. Gozon (CEO), Gilberto R. Duavit, Jr. (Executive VP), Marissa L. Flores (News Dept. VP), Jessica A. Soho (News Director), Grace dela PeAa-Reyes (Head of News Operations), and John Oliver T. Manalastas (Program Manager).
The controversy arose from two libel complaints filed by GMA Network officers against the ABS-CBN personnel over statements aired on ABS-CBN programs accusing GMA-7 of pirating exclusive video footage.

On July 22-23, 2004, Angelo dela Cruz, a Filipino hostage released by Iraqi captors, arrived in the Philippines. ABS-CBN undertook exclusive live coverage of his arrival and press conference at NAIA.
ABS-CBN’s exclusive footage was shared with Reuters Television Service through an agreement. GMA-7, a subscriber of Reuters and CNN, received video feeds possibly containing ABS-CBN’s footage.
GMA-7 aired approximately over one and a half minutes of the Angelo footage obtained through Reuters’ live feed, allegedly without awareness that the footage originated from ABS-CBN. Upon recognition, GMA-7 ceased airing the footage.
On July 22-23, 2004, ABS-CBN news programs “Insider” and “Magandang Umaga Bayan” aired reports, with statements by Erwin Tulfo and Lynda Jumilla accusing GMA-7 of stealing and pirating ABS-CBN's exclusive video footage. Examples of statements include:

Erwin Tulfo: Called the coverage “exclusive” and accused GMA-7 of pirating the footage, insinuating a crime.
Lynda Jumilla: Reiterated that ABS-CBN’s exclusive videos were being aired by GMA-7 without permission and considered filing a lawsuit.

These statements were the basis for the libel complaints filed by GMA-7 officers on July 27, 2004.

Nearly ten years later, on January 28, 2013, the Quezon City Prosecutor filed two criminal Informations charging the petitioners with libel per Articles 353 and 354 of the Revised Penal Code.
On February 14, 2013, the RTC found probable cause and ordered the issuance of warrants of arrest against the petitioners.
Petitioners posted bail on February 18 and 19, 2013, and filed a Very Urgent Motion for Reconsideration and Motion to Quash the Informations.
RTC denied those motions in Orders dated April 16 and June 11, 2013, affirming the sufficiency of the Informations and the presence of probable cause.
Petitioners filed a Petition for Certiorari with the Court of Appeals (CA), which was dismissed on August 17, 2017, affirming the RTC’s denial of the motions.
Petitioners then filed the present Petition for Review on Certiorari before the Supreme Court, assailing the CA ruling.

Whether the Court of Appeals erred in ruling that a petition for certiorari under Rule 65 is an improper remedy to question the RTC’s denial of the motion to quash.

Whether the Court of Appeals erred in upholding the sufficiency in form and substance of the Informations charging petitioners with libel.

Whether the Court of Appeals erred in not finding grave abuse of discretion on the part of the RTC in denying the motions to quash and reconsider.

Whether the Court of Appeals erred in upholding the validity of the Informations despite private respondents’ (GMA-7 officers) admission to the unauthorized use of the ABS-CBN footage.