Title
People vs. Metropolitan Trial Court of Quezon City, Branch 32
Case
G.R. No. 123263
Decision Date
Dec 16, 1996
Libel case jurisdiction dispute: MTC vs. RTC; SC ruled RTC retains exclusive jurisdiction under RPC Article 360, nullifying MTC orders.

Case Summary (G.R. No. 188747)

Factual background and initial filing

An information for libel was filed against Isah V. Red in the Regional Trial Court (RTC) of Quezon City on January 30, 1995, docketed as Criminal Case No. 95-60134 and raffled to Branch 82. Red moved to quash the information on the ground that the RTC lacked jurisdiction over the offense.

RTC action and remand to the Metropolitan Trial Court

The RTC judge found merit in the motion to quash and, by Order dated March 29, 1995, remanded the case to the Metropolitan Trial Court of Quezon City “for proper action/disposition in the premises.” The RTC judge relied on his interpretation of R.A. No. 7691—declaring that, under Section 2 of R.A. No. 7691, exclusive original jurisdiction over all offenses punishable with imprisonment not exceeding six years is vested in the Municipal Trial Courts (including Metropolitan Trial Courts), thereby implying municipal-level jurisdiction over libel.

Proceedings at the Metropolitan Trial Court

The case was transferred to the MetroTC and docketed as Case No. 43-00548, Branch 43. The private prosecutor, “under the control and supervision of the Fiscal,” filed a “Manifestation and Motion to Remand” on August 1, 1995, invoking Article 360 of the Revised Penal Code, which mandates that criminal and civil actions for written defamation be filed with the Court of First Instance (now RTC) of the province or city where the libelous article is printed and first published or where any offended party actually resides at the time of the offense. The private prosecutor argued that Article 360 designated a specific court of first instance for libel and that a general law such as R.A. No. 7691 cannot be construed to repeal or supersede a special statutory provision unless manifest legislative intent exists to do so.

MetroTC’s denial of remand and rulings on appeal

The MetroTC denied the motion to remand in an August 14, 1995 Order, taking the position that R.A. No. 7691 should be treated as a later, modern statute that implicitly revised older provisions of the Revised Penal Code; the MetroTC further held that when a later statute makes the penalty lighter, the new law applies. The MetroTC also denied a motion for reconsideration on September 7, 1995, and denied a subsequent motion on October 18, 1995, directing the prosecution to present its next witness, as trial had commenced.

Petition to the Supreme Court and primary legal contention

The People filed a special civil action (certiorari, prohibition and mandamus) asking the Supreme Court to: (1) declare the MetroTC orders null and void for lack of jurisdiction; (2) enjoin the MetroTC from further conducting trials in Criminal Case No. 43-00548; and (3) command remand of the case to the Executive Judge of the RTC of Quezon City. The People relied on Article 360’s categorical designation of a court of first instance (historically the Court/now RTC) as the forum for libel and cited Jalandoni v. Endaya and a line of authority holding that municipal courts do not have jurisdiction over libel cases. The People also invoked the principle that a general statute should not be construed to repeal a specific enactment unless manifest legislative intent exists, citing authorities such as De Joya v. Lantin and Berces v. Guingona.

Supreme Court’s consideration of controlling precedents and related rulings

The Court observed that this jurisdictional question had been previously addressed in a closely related case (Lydia Caro v. Court of Appeals, G.R. No. 122126), where the Court resolved that R.A. No. 7691 did not divest the RTCs of jurisdiction to try libel cases. The Court reiterated prior holdings (including Bocobo v. Estanislao and Jalandoni v. Endaya) that established the RTCs’ exclusive jurisdiction over libel cases. The Court further cited Administrative Order No. 104-96, issued by the Chief Justice with the Court En Banc’s advice and consent, which expressly provides that “LIBEL CASES SHALL BE TRIED BY THE REGIONAL TRIAL COURTS HAVING JURISDICTION OVER THEM TO THE EXCLUSION OF THE METROPOLITAN TRIAL COURTS, MUNICIPAL TRIAL COURTS IN CITIES, MUNICIPAL TRIAL COURTS AND MUNICIPAL CIRCUIT TRIAL COURTS.”

Rulings on finality of orders and interlocutory nature

The Court addressed the respondents’ contention that the MetroTC orders had become immutable because the prosecution did not appeal. The Court reiterated the established distinction: only final orders that finally dispose of a case and le

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