Case Summary (G.R. No. L-13027)
Procedural Background
On January 7, 1956, Visitacion Meris filed a complaint for libel against Ascencion Olarte with the provincial fiscal of Pangasinan. Following procedural guidance, Meris filed a complaint in the Justice of the Peace Court of Pozorrubio on February 22, 1956, which led to the case being forwarded to the Court of First Instance on July 3, 1956, after Olarte waived a preliminary investigation. The defendant sought to quash the information citing prescription due to the alleged expiration of the two-year limitation for libel under the Revised Penal Code.
Legal Framework Governing Libel
According to Article 90 of the Revised Penal Code, the offense of libel prescribes in two years as specified. Article 91 further stipulates that the prescriptive period is interrupted by the filing of a complaint or information. The central issue revolves around whether the statute of limitations was suspended by the filing of the complaint in the Justice of the Peace Court or whether it continued until the information was formally filed in the Court of First Instance.
Court Decisions and Reasoning
The trial court ruled in favor of the defendant, concluding that the prescriptive period had lapsed before the information was filed. This ruling relied on the interpretation of Article 91, where it was determined that the proper court to interrupt the statute of limitations was the Court of First Instance, not the Justice of the Peace Court. The court cited the precedent set in People vs. Tayco, emphasizing that complaints filed in lower courts do not suffice to interrupt the prescription of libel actions.
However, the appellate court disagreed with the lower court's interpretation. It argued that the filing of a complaint in the Justice of the Peace Court effectively interrupted the statute of limitations as per the procedure established by law. The court noted the historical perspective of jurisdiction concerning libel, highlighting the authority granted to justices of the peace to conduct preliminary investigations without undermining the original jurisdiction of the Court of First Instance.
Amendment Analysis
The amendments made by Republic Act No. 1289, which changed the language in Article 360 regarding where libel actions should be filed, were aimed at preventing abuse of venue to harass publishers and journalists. The Court articulated that these amendments were intended t
...continue readingCase Syllabus (G.R. No. L-13027)
Case Overview
- The case involves a charge of libel against defendant Ascencion P. Olarte, alleged to have committed the offense by writing letters that were derogatory towards Miss Visitacion M. Meris.
- The information claims that Olarte's letters were written "on or about the 24th day of February, 1954 and subsequently thereafter" with malicious intent to harm Meris’s reputation.
Procedural History
- Miss Meris lodged the libel charge with the provincial fiscal of Pangasinan on January 7, 1956.
- Following the advice of the assistant provincial fiscal, she filed a complaint for libel with the Justice of the Peace Court on February 22, 1956.
- The defendant waived her right to a preliminary investigation, leading to the case being forwarded to the Court of First Instance of Pangasinan, where the information was filed on July 3, 1956.
- Olarte filed a motion to quash the information, citing the prescription of the offense, which was granted by the trial court, resulting in the dismissal of the case.
Appeal and Denial of Motion to Dismiss
- Miss Meris appealed the trial court’s dismissal with the approval of the provincial fiscal's office.
- Olarte attempted to dismiss the appeal based on the claim that the brief filed was not prepared by the Solicitor General, rendering it null and void.
- The motion to dismiss was denied as the Solicitor General later adopted the brief as their own.
Legal Framework
- The crime of libel prescribes in two years according to Article 90 of the Revised Penal Code, which begins to run from