Title
People vs. Macasaet
Case
G.R. No. 196094
Decision Date
Mar 5, 2018
Libel charges against *Malaya* journalists over defamatory articles; Supreme Court ruled delay violated right to speedy disposition, dismissing cases.

Case Summary (G.R. No. 196094)

Procedural Posture and Consolidation

Three petitions for review on certiorari under Rule 45 were consolidated before the Supreme Court, assailing differing Court of Appeals (CA) dispositions and Regional Trial Court (RTC) orders arising from two Informations (Criminal Case Nos. 08-263272 and 08-263273) for libel. The petitions challenged: (1) the CA’s October 19, 2010 decision that granted a petition nullifying RTC Br. 37 orders and dismissing the Information in one case (G.R. No. 196094); (2) the CA’s February 10, 2011 decision that denied a petition and affirmed RTC Br. 37 orders in another case (G.R. No. 196720); and (3) the CA’s January 26, 2011 decision that denied a petition and affirmed RTC Br. 36 orders in the related libel information (G.R. No. 197324).

Factual Background and Antecedent Proceedings

Nine interrelated libel complaints arose from articles appearing in Malaya and Abante. Probable cause was found by the DOJ only for two Malaya articles: the April 21, 1999 Malaya article (“Santiago’s gambling habits”) and the March 1, 1999 Malaya article (“NCA-UCAP FEUD: Walang trabaho, personalan lang”), both written by Macasaet. Abante’s complaint was dismissed. The Rizal Provincial Prosecutor initially dismissed the complaints without prejudice for lack of venue/jurisdiction; the DOJ later issued a consolidated resolution (July 9, 2008) finding probable cause for two of the nine complaints, resulting in two Informations filed in August 2008 and arraignments thereafter.

G.R. No. 196720 — Santiago Complaint and Lower Court Rulings

Santiago filed an affidavit-complaint (April 27, 1999) alleging the April 21, 1999 Malaya article accused him of a serious gambling habit. After the DOJ consolidated resolution and filing of the Information, the accused moved to dismiss before RTC Br. 37 on speedy-disposition grounds (November 26, 2008); the RTC denied the motion (February 19, 2009) and denied reconsideration (June 1, 2009). The CA denied the accused’s petition for certiorari, affirming the RTC orders (February 10, 2011). The accused sought relief to the Supreme Court in G.R. No. 196720.

G.R. No. 196094 — Venue and Sufficiency of the Information

Separately, the accused challenged RTC Br. 37 orders on the ground that the Information was insufficient in form and substance because it did not expressly allege where the libelous article was “printed and first published.” RTC Br. 37 denied the motion to dismiss for lack of jurisdiction (Orders of November 3, 2009 and January 29, 2010); the CA granted the petition and nullified those RTC orders, dismissing the Information (October 19, 2010). This CA ruling formed the basis for G.R. No. 196094 before the Supreme Court.

G.R. No. 197324 — Ynares Complaint and Speedy Disposition Challenge

Ynares filed an affidavit-complaint dated March 16, 1999 concerning the March 1, 1999 Malaya article alleging Ynares pressured a mayor to cancel UCAP’s permit. The DOJ consolidated resolution led to an Information and arraignment before RTC Br. 36 (Criminal Case No. 08-263272). The accused moved to dismiss (October 7, 2008) on speedy-disposition grounds; RTC Br. 36 denied the motion (November 20, 2008) and denied reconsideration (May 5, 2009). The CA denied the petition for certiorari (January 26, 2011). This denial was brought to the Supreme Court in G.R. No. 197324.

Issues Presented to the Supreme Court

The consolidated petitions raised two principal legal issues: (1) whether the Information in G.R. No. 196094 was sufficient in form and substance to charge the accused with libel, specifically with respect to alleging the place where the libel was “printed and first published”; and (2) whether the cases in G.R. Nos. 196720 and 197324 must be dismissed because the accused’s constitutional right to a speedy disposition of their cases had been violated.

Governing Legal Provisions and Standards

The Court applied the 1987 Constitution (Article III, Section 14[2] — right to a speedy, impartial, and public trial; Article III, Section 16 — right to a speedy disposition of cases) and statutory/regulatory standards: Article 360 of the Revised Penal Code (as amended) on persons responsible and venue for libel, Republic Act No. 8493 (Speedy Trial Act of 1998), Rule 119 of the Rules of Court and the Court’s Circular No. 38-98 implementing RA 8493, and the four-factor balancing test from prior jurisprudence (Caballes) for determining speedy-disposition violations: (a) length of delay; (b) reason for the delay; (c) assertion of the right by the accused; and (d) prejudice to the accused. The Court also considered jurisprudential clarifications on venue (Agbayani v. Sayo; Bonifacio v. RTC of Makati) and on waiver and laches concerning the assertion of the right to a speedy trial or disposition (Nepomuceno; Valencia; Guerrero; Dela PeÑa).

Court’s Analysis on Venue and Sufficiency of the Information (G.R. No. 196094)

Article 360 requires that venue for written defamation may be laid where the libelous article is printed and first published or where the offended party actually resided, among other permutations. The CA had held the Information fatally defective because it failed to expressly allege the place where the article was “printed and first published,” noting that the publisher’s address is not necessarily the place of publication. The Supreme Court disagreed. The Court found that the Information’s allegation — that the accused defamed the complainant “in Manila City … by writing and publishing an article in the Malaya with address at Port Area, Manila City” — sufficiently identified the place of publication. The Court reasoned that the Information need not mechanically quote the phrase “printed and first published” when the place of publication is manifest from the alleged address and supported by the record (the DOJ consolidated resolution and other records showing Malaya’s editorial and business offices at Port Area, Manila). The Court concluded that the Information complied with Bonifacio’s requirement that the place of publication be alleged with particularity (for example by reference to the editorial/business office address), and that it was incumbent on the accused to show that Port Area was not Malaya’s editorial/business office. Accordingly, the CA erred in dismissing the Information in Criminal Case No. 08-263273 on venue grounds.

Court’s Analysis on Right to Speedy Disposition (G.R. Nos. 196720 and 197324)

The Court found merit in the accused’s speedy-disposition claims. The record showed that the complaints were filed in 1999, but the Rizal Provincial Prosecutor did not resolve venue issues and dismissed the complaints without prejudice only on September 28, 2007 — more than eight years later. The DOJ then summoned the accused in January 2008 and issued a consolidated probable-cause resolution on July 9, 2008, with Informations filed in August 2008 and arraignments later that year. The CA had treated the accused’s earlier silence and lack of early objection as laches or implied waiver, relying on case law that failure to timely assert the right may preclude later reliance on it. The Supreme Court disagreed with the CA’s application of waiver and laches because the CA failed to give appropriate weight to two crucial factors: the length of delay and the reason for it. The Court emphasized that the delay by the Provincial Prosecutor (over eight years to resolve a venue question) was inordinate, unjustified, and not reasonably attributable to ordinary processes of justice. Under the Caballes balancing test, such an inordinate delay, unexplained and originating in prosecutorial in

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