G.R. No. 154473 - People vs. Benipayo

Case Summary (G.R. No. 154473)

Factual Background

In G.R. No. 154473 respondent, then Chairman of the Commission on Elections, delivered a speech at the University of the Philippines on January 31, 2002 which was published in the Manila Bulletin on February 4 and 5, 2002; Photokina alleged the speech contained defamatory imputations against it and filed an Affidavit-Complaint for libel. In G.R. No. 155573 respondent, during a nationally televised program on March 13, 2002, made statements that Photokina likewise considered defamatory and filed a Complaint-Affidavit for libel.

Trial Court Proceedings

The Office of the City Prosecutor of Quezon City filed Informations in the Regional Trial Court of Quezon City: Criminal Case No. Q-02-109407 (Branch 102) arising from the published speech and Criminal Case No. Q-02-109406 (Branch 101) arising from the television appearance. Respondent challenged jurisdiction on grounds that he was an impeachable officer and that, if prosecutable, the offenses arose in relation to his official functions and therefore fell within the jurisdiction of the Sandiganbayan. The RTC, Branch 102, issued an Order of dismissal on June 18, 2002 and adhered to that dismissal on reconsideration; the RTC, Branch 101, issued an Order of dismissal on June 25, 2002 and denied reconsideration on September 18, 2002.

Parties' Contentions Presented to the Court

Petitioners argued, on pure questions of law, that the trial courts erred by dismissing the Informations and by concluding that the libel was committed in relation to respondent’s office so as to oust the RTC’s jurisdiction. Petitioners also contended that the trial courts should have resolved motions to inhibit before disposing the cases, and that, if the Sandiganbayan had jurisdiction, the cases should have been endorsed rather than dismissed. Respondent maintained that he was an impeachable officer and that the alleged libelous acts were committed in relation to his office; he therefore asserted lack of jurisdiction of the RTC and urged that jurisdiction lay with the Sandiganbayan.

Issue Presented

Whether the Regional Trial Court has jurisdiction to try the crimes of libel, to the exclusion of the Sandiganbayan, and whether it was necessary to decide whether the alleged libel was committed in relation to respondent’s office.

Ruling of the Court (Disposition)

The Court granted the consolidated petitions. Criminal Cases Nos. Q-02-109406 and Q-02-109407 were reinstated and remanded to the Regional Trial Court of Quezon City for further proceedings.

Legal Basis and Reasoning

The Court observed that the parties and the trial courts had focused on whether the libelous acts were committed in relation to office, but had overlooked the antecedent question whether jurisdiction over written defamation is shared by the RTC and the Sandiganbayan. The Court recalled the settled rule that jurisdiction is governed by the law in force at the time of institution of the action. It then examined Art. 360, Revised Penal Code, as amended by Republic Act No. 4363, which expressly provides that criminal and civil actions for written defamations shall be filed with the court of first instance (now the Regional Trial Court) where the libelous article is printed and first published or where any offended party actually resides, and that the court where the criminal or civil action is first filed shall acquire jurisdiction to the exclusion of other courts. The Court traced controlling precedents—Jalandoni v. Endaya, Bocobo v. Estanislao, and others—where it had consistently held that jurisdiction over libel cases is lodged exclusively in the RTC and cannot be exercised by inferior courts despite subsequent statutes expanding lower courts’ jurisdiction. The Court applied the same principle here and rejected the premise that the Sandiganbayan’s grant of jurisdiction over offenses committed in relation to office, as found in Presidential Decree No. 1606 and as amended by Republic Act No. 8249, impliedly divested the RTC of its exclusive jurisdiction over written defamations. The Court explained that a later general enactment cannot impliedly repeal or modify a special provision vesting exclusive jurisdiction in a particular court absent express repeal or irreconcilable conflict. The Court further relied on Administrative Order No. 104-96, which designated libel cases to be tried by the RTC to the exclusion of met

Case Syllabus (G.R. No. 154473)

Parties and Procedural Posture

People of the Philippines and Photokina Marketing Corporation filed two consolidated petitions for review on certiorari under Rule 122 in relation to Rule 45 of the Rules of Court contesting orders of the Regional Trial Court of Quezon City.
Alfredo L. Benipayo was the respondent in both petitions and was then Chairman of the Commission on Elections (COMELEC).
The petitions assailed RTC Branch 102 Orders dated June 18 and June 23, 2002 in Criminal Case No. Q-02-109407 and RTC Branch 101 Orders dated June 25 and September 18, 2002 in Criminal Case No. Q-02-109406.
The Court consolidated the two petitions because they involved the same legal issue and substantially the same parties.

Key Factual Allegations

Benipayo delivered a speech on January 31, 2002 at the University of the Philippines that was published in the February 4 and 5, 2002 issues of the Manila Bulletin and which Photokina regarded as imputing that it had overcharged the government.
Benipayo made statements on March 13, 2002 on the televised program "Point Blank" that Photokina funds were being used for a campaign and that funds in excess of 2.4 million U.S. dollars had been spent on the Photokina deal, which Photokina regarded as defamatory.
Photokina filed Complaint-Affidavits for libel in both instances through its authorized representative.

Procedural History

The Office of the City Prosecutor of Quezon City filed Informations for libel in RTC Branch 102 (Criminal Case No. Q-02-109407) and Branch 101 (Criminal Case No. Q-02-109406).
Benipayo challenged the jurisdiction of the City Prosecutor and the RTC on the ground that he was an impeachable officer and that, if prosecutable, his acts were in relation to office and therefore within the jurisdiction of the Sandiganbayan.
The RTC in Branch 102 dismissed Criminal Case No. Q-02-109407 on June 18, 2002 for lack of jurisdiction on the ground that the alleged libel was committed in relation to respondent's office.
The RTC in Branch 101 dismissed Criminal Case No. Q-02-109406 on June 25, 2002 for lack of jurisdiction and denied a motion for reconsideration on September 18, 2002.
Petitioners filed the present petitions to the Supreme Court raising pure questions of law.

Issues Presented

Whether the Regional Trial Court has exclusive and original jurisdiction to try cases of written defamation to the exclusion of all other courts.
Whether libel committed by a public officer in relation to his office places jurisdiction exclusively in the Sandiganbayan to the exclusion of the RTC.
Whether the trial courts erred in dismissing rather than endorsing the cases to the Sandiganbayan if that court had jurisdiction.
Whether the trial court should have resolved the motion to inhibit before resolving the motion to dismiss.

Contentions of Parties

Petitioners contended that the RTC had exclusive jurisdiction over written defamations under Article 360 of the Revise