G.R. No. 227534 - Yap vs. Ibay, Jr.

The petitioners—Jerry S. Yap, Gloria M. Galuno, Edwin R. Alcala, and Becky Rodriguez—are media practitioners indicted for libel.
They were charged based on an article titled "Salot na Tulak sa Distrito Uno ng Maynila (Attention: PDEA)" which appeared in Hataw Newspaper (and also involved X-Files Newspaper in part of the allegations).
The Information alleged that the article contained defamatory statements relating to a drug pusher allegedly connected to a barangay official, and it identified Police Senior Inspector Rosalino P. Ibay, Jr. as the offended party.

The Information stated that the libelous article was printed and first published in the City of Manila.
It raised a jurisdictional issue by not clearly indicating whether PSI Ibay was holding office in Manila at the time of publication, a requirement under Article 360 of the Revised Penal Code.
The petitioners contended that because the Information did not explicitly state that the officer was in Manila when the article appeared, the Regional Trial Court (RTC) should lack jurisdiction.

On October 13, 2015, the petitioners filed a Motion to Quash the Informations on the ground of lack of jurisdiction.
The RTC denied the motion, holding that the mention of PSI Ibay’s station at the Manila Police District and the allegation that the article was printed and published in Manila was sufficient to confer jurisdiction.
Despite subsequent motions and a Motion for Reconsideration that reiterated their jurisdictional arguments, the RTC maintained its position by setting arraignment and proceeding with the case.
The petitioners then turned to the Court of Appeals (CA), filing a Petition for Certiorari to assail the RTC’s and later the CA’s resolutions dismissing their appeals.
The CA dismissed the petition for certiorari on two main grounds:

The wrong remedy was availed of, as the denial of a motion to quash—an interlocutory order—generally does not warrant an appeal.
Procedural deficiencies were noted, including the failure to comply with the requirements of Rule 46 of the Rules of Court.

The crux of the controversy centers on whether the allegations in the Informations that the article was “printed and first published in the City of Manila” suffice, notwithstanding the absence of a clear statement that the offended officer was in Manila at the time of publication.
The petitioners argued that the RTC erred by inferring jurisdiction based on contextual phrases in the article, pointing out that the article even indicated that PSI Ibay was no longer assigned in Manila.
The respondent countered that the venue requirement under Article 360 was met by the sufficient allegation regarding the location of publication.

Whether the allegations that the libelous article was "printed and first published" in Manila are sufficient to confer jurisdiction on the RTC, despite not expressly stating that the offended public officer was holding office in Manila at the time of publication.

Whether the denial of the Motion to Quash (an interlocutory order) constitutes an appealable decision or is a matter that must be addressed through proper trial proceedings.
Whether the petitioners properly availed themselves of the correct remedy in challenging such an order.

Whether petitioners’ submission of the petition for certiorari before the Court of Appeals complied with the mandatory requirements set forth in Section 3, Rule 46 of the Rules of Court.
Whether the identified procedural infirmities render the petition for certiorari defective as a remedy against interlocutory orders.