Case Summary (G.R. No. 145022)
RTC Proceedings: Dismissal for Improper Venue and Amendment
The original complaint did not specify Tan’s residence or the place where the offending publications were printed and first published. Upon motion by defendants, the RTC dismissed the complaint without prejudice on February 10, 1999, for improper venue. Tan promptly filed an omnibus motion attaching an amended complaint that expressly alleged publication in Makati City. Invoking Rule 10 of the 1997 Rules of Civil Procedure, the RTC admitted the amendment and set aside its prior dismissal, finding the changes merely formal and not affecting substantive defenses.
Court of Appeals Ruling
Petitioners and co-defendants appealed. In CA-G.R. SP No. 55192 (consolidated with CA-G.R. SP No. 54894), the Court of Appeals on April 19, 2000, denied the petitions for certiorari and affirmed the RTC’s order admitting the amended complaint. Motions for reconsideration were denied on September 15, 2000.
Issue on Review
Whether the RTC acquired jurisdiction over the civil libel case upon the filing of the original complaint, despite its venue defects.
Distinction Between Jurisdiction and Venue
The Supreme Court reiterated that jurisdiction is the court’s power to hear a case—a substantive matter fixed by law—whereas venue is a procedural rule determining the proper place of trial. Under Article 360 of the Revised Penal Code, jurisdiction over libel actions lies with the Regional Trial Courts; the statute’s references to “where printed and first published” or “where the complainant resides” pertain to venue, not jurisdiction. Failure to allege venue facts in a civil libel complaint warrants dismissal without prejudice but does not divest the court of subject-matter jurisdiction once the action has been filed.
Analysis and Application
- The RTC had jurisdiction upon filing of the original complaint because libel falls within its exclusive competence under Article 360.
Case Syllabus (G.R. No. 145022)
Facts of the Case
- On September 27, 1998, Lucio Tan filed Civil Case No. 98-2288 in the RTC of Makati, Branch 56, for moral and exemplary damages arising from alleged malicious and defamatory imputations in two Philippine Daily Inquirer articles authored by Armand Nocum.
- The complaint named as respondents: Armand Nocum, Capt. Florendo Umali, the Airline Pilots Association of the Philippines (ALPAP), and The Philippine Daily Inquirer, Inc.
- The original complaint did not state the residence of Tan at the time of the alleged offense nor the place where the libelous articles were printed and first published.
Defendants’ Responsive Pleadings
- Inquirer and Nocum’s joint answer (October 27, 1998) contended:
- Failure to state a cause of action.
- Alleged defamatory statements were mere general conclusions without factual support.
- The report was a fair and true account on matters of public interest concerning a public figure (qualified privilege).
- Absence of malice—plaintiff’s side of the dispute was also published in the same article.
- Umali and ALPAP’s joint answer (October 31, 1998) asserted:
- No cause of action stated.
- Improper venue.
- Lucio Tan was not a real party in interest.
RTC Proceedings and Amendment
- The RTC issued an order dated February 10, 1999, dismissing the complaint without prejudice for improper venue.
- On February 24, 1999, Tan filed an Omnibus Motion for reconsideration and attached an amended complaint alleging:
- The article and caricature were printed and first published in the City of Makati.
- The RTC, invoking Rule 10 of the 1997 Rules of Civil Procedure, admitted the amended complaint and set aside its previous dismissal order on April 19, 1999.
Court of Appeals Proceedings
- Petitioners (Nocum and Inquirer) and defendants Umali and ALPAP filed separate petitions for certiorari (CA-G.R. SP No. 55192 and SP No. 54894), which were consolidated.
- On April 19, 2000, the Court of Appeals de