Case Summary (G.R. No. 154473)
Factual and Procedural Background: G.R. No. 154473
On January 31, 2002, Respondent delivered a speech at the University of the Philippines–Diliman, later published in the Manila Bulletin (February 4–5, 2002), criticizing a proposed COMELEC contract allegedly benefiting Photokina. Photokina filed an Affidavit-Complaint for libel before the Quezon City Office of the City Prosecutor. Respondent challenged that court’s jurisdiction on grounds that, as an impeachable officer, he could be prosecuted only by the Sandiganbayan. The City Prosecutor nevertheless indicted him before RTC Branch 102 (Criminal Case No. Q-02-109407). Photokina also moved for Judge Salazar’s inhibition and for consolidation with a related libel case pending in Branch 101. While those motions remained unresolved, Respondent moved to dismiss for lack of personal jurisdiction and for improper venue before any court other than the Sandiganbayan.
RTC Branch 102 Orders and Petition for Certiorari: G.R. No. 154473
On June 18 and June 23, 2002, RTC Branch 102 dismissed Criminal Case No. Q-02-109407, ruling that the alleged libel was committed in Respondent’s official capacity and thus fell under the Sandiganbayan’s exclusive jurisdiction. The court deemed Photokina’s inhibition motion moot. Photokina’s motion for reconsideration was denied. On pure questions of law, Photokina and the People filed a Rule 122/Rule 45 Petition for Review on Certiorari before the Supreme Court, contesting the dismissal, the characterization of Respondent’s speech as “in relation to office,” and the RTC’s purported lack of jurisdiction.
Factual and Procedural Background: G.R. No. 155573
On March 13, 2002, Respondent appeared on ANC’s “Point Blank” and alleged that Photokina funds were being used in a covert “PR” campaign against him, amounting to USD 2.4 million. Photokina filed a libel complaint and affidavit in the Quezon City prosecutor’s office. Despite Respondent’s jurisdictional challenge, the Information was docketed before RTC Branch 101 (Criminal Case No. Q-02-109406). Respondent filed a similar motion to dismiss, asserting exclusive Sandiganbayan jurisdiction.
RTC Branch 101 Orders and Petition for Certiorari: G.R. No. 155573
On June 25, 2002, RTC Branch 101 dismissed Criminal Case No. Q-02-109406 for lack of jurisdiction over Respondent’s person, labeling the alleged libel “in relation to office.” A motion for reconsideration was denied on September 18, 2002. Photokina filed a separate Rule 122/Rule 45 Petition for Review on Certiorari, asserting that the RTC erred in finding the offense office-related, in holding that it lacked jurisdiction, and in dismissing rather than transferring the case to the Sandiganbayan.
Consolidation and Issue Framing
The Supreme Court consolidated both petitions to address the common issue: whether the RTC has jurisdiction over libel offenses to the exclusion of all other courts, including the Sandiganbayan. Both parties had focused on whether the libel was committed “in relation to office,” but the Court recognized that jurisdiction must first be determined under the statutes governing libel before considering office-relation.
Statutory Jurisdiction over Libel: Article 360, RPC
Article 360 of the Revised Penal Code (RPC), as amended by R.A. 4363, grants exclusive original jurisdiction over written defamation (libel) to the court of first instance (now Regional Trial Court) in the province or city of first publication or residence of the offended party. The provision is categorical and admits no exception. This exclusivity survives subsequent general statutes expanding the jurisdiction of lower courts, including R.A. 7691 (expanding Municipal Trial Court jurisdiction).
RTC vs. Sandiganbayan Jurisdiction
The Sandiganbayan’s grant of exclusive original jurisdiction over crimes “committed in relation to office”
...continue readingCase Syllabus (G.R. No. 154473)
Procedural Posture – G.R. No. 154473
- Two consolidated petitions filed under Rule 122 in relation to Rule 45, Rules of Court: G.R. No. 154473 (Criminal Case No. Q-02-109407, Branch 102 RTC Quezon City) and G.R. No. 155573 (Criminal Case No. Q-02-109406, Branch 101 RTC Quezon City).
- Photokina Marketing Corporation filed an Affidavit-Complaint for libel against then-COMELEC Chair Alfredo L. Benipayo based on a published speech.
- Respondent challenged the jurisdiction of the City Prosecutor, citing his status as an impeachable officer.
- The City Prosecutor nonetheless filed Informations in both cases before the respective RTC branches.
- In No. Q-02-109407, petitioner moved for inhibition of Judge Salazar (Branch 102) and consolidation with Q-02-109406 (Branch 101).
- Respondent moved to dismiss both cases for lack of jurisdiction over his person (impeachable officer) and for improper venue—arguing that only the Sandiganbayan (via Ombudsman) could hear the matter.
RTC Rulings Below
- June 18, 2002 (Branch 102): Dismissed Q-02-109407 for lack of jurisdiction, deeming the alleged libel committed in respondent’s official capacity; motion to inhibit rendered moot.
- June 25, 2002 (Branch 101): Dismissed Q-02-109406 for lack of jurisdiction over respondent’s person.
- Denial of motions for reconsideration in both branches (June 23 and September 18, 2002).
Petitions for Review – Grounds Invoked
- G.R. No. 154473:
• Trial court should have resolved the motion to inhibit before deciding on dismissal.
• Error in holding the libel was committed “in relation to office.”
• Error in ruling the RTC lacked jurisdiction. - G.R. No. 155573:
• Same contention on “relation to office” and jurisdiction.
• Even if Sandiganbayan had jurisdiction, trial court should have endorsed rather t