Title
Tulfo vs. People
Case
G.R. No. 237620
Decision Date
Apr 28, 2021
Libel case against ABS-CBN journalists for accusing GMA-7 of "stealing" exclusive footage; SC upheld CA, ruling certiorari improper, informations sufficient, and malice a trial issue.
libel charges
certiorari
exclusive video footage
A

Case Summary (G.R. No. 201672)

Petitioner and Respondent Roles

Petitioners: Accused in two criminal informations for libel filed by the Quezon City Prosecutor based on broadcasts aired on ABS‑CBN programs “Insider” and “Magandang Umaga Bayan.”
Respondents: Private offended parties (GMA‑7 management and news officers) who filed the original criminal complaint for libel; the People of the Philippines prosecuted the case.

Key Dates

  • July 22–23, 2004: Alleged broadcasts covering Angelo dela Cruz’s arrival and statements attributing unauthorized use of ABS‑CBN footage to GMA‑7.
  • July 27, 2004: Criminal complaint for libel filed by private respondents.
  • January 28, 2013: Two criminal informations for libel prepared by the prosecutor.
  • February 14, 2013: RTC issued order finding probable cause and ordered issuance of arrest warrants; petitioners posted bail (Feb 18–19, 2013).
  • April 16 and June 11, 2013: RTC Orders denying petitioners’ motions (reconsideration, to recall warrants, ad cautelam motion to quash, and motion to disqualify).
  • August 17, 2017: Court of Appeals rendered a decision dismissing petition for certiorari and affirming the RTC Orders.
  • April 28, 2021: Final disposition by the Supreme Court (decision under review).

Applicable Law and Authorities

  • 1987 Constitution (applicable given decision date after 1990).
  • Revised Penal Code: Article 353 (libel) and Article 354 (presumption of malice and exceptions).
  • Rules of Court: Rule 65 (special civil action of certiorari), Rule 110 Section 6 (sufficiency of complaint/information), and Rule 41 (appealability principles referenced in jurisprudence).
  • Controlling jurisprudence cited in the decision: Maximo v. Villapando; Galzote v. Briones; Pascua v. People; Atty. Zamorano v. People; People v. Cilot; and other authorities referenced in the Court’s analysis.

Factual Background (Antecedents)

ABS‑CBN prepared and conducted live coverage of Angelo dela Cruz’s arrival at NAIA on July 22–23, 2004; Reuters had an agreement with ABS‑CBN to air its footage and provided live feed to subscribers such as GMA‑7. GMA‑7 aired over a minute of the Angelo footage via its Reuters/CNN subscription; upon recognizing ABS‑CBN reporter Dindo Amparo in the feed, GMA‑7 personnel stopped the airing. ABS‑CBN aired reports alleging that GMA‑7 had “stolen” or “pirated” the exclusive footage. Private respondents later filed a criminal complaint for libel based on statements aired by petitioners.

Procedural History Through Trial Court

  • The Quezon City Prosecutor filed two criminal informations for libel against petitioners on January 28, 2013.
  • The RTC (Branch 88, Quezon City) found probable cause (Feb 14, 2013) and ordered issuance of arrest warrants; petitioners posted bail.
  • Petitioners filed a “Very Urgent Motion for Reconsideration of the Judicial Determination of Probable Cause with Motion to Suspend Proceedings, and to Recall Warrants of Arrest” and an ad cautelam motion to quash the informations.
  • On April 16, 2013, the RTC denied the motions, holding that the determination of probable cause in the preliminary investigation pertains to the public prosecutor and that the trial court should not override that finding absent grave circumstances; the RTC further found the informations sufficient in form and substance and that truth and absence of malice are defenses to be resolved at trial.
  • A subsequent motion to disqualify and motion for reconsideration were denied on June 11, 2013.

Court of Appeals Ruling

The Court of Appeals dismissed the petition for certiorari under Rule 65 and affirmed the RTC Orders. The CA held: (1) certiorari was not the proper remedy to assail the denial of an ad cautelam motion to quash because petitioners had an adequate remedy — to proceed to trial and raise alleged errors on appeal; (2) the informations were facially sufficient and complied with Section 6, Rule 110; and (3) factual defenses such as truth, lack of identifiability, and absence of malice are matters to be litigated during trial.

Issues Presented to the Supreme Court

A. Whether the Court of Appeals erred in ruling that a petition for certiorari was improper to challenge the denial of the motion to quash.
B. Whether the Court of Appeals erred in finding the informations sufficient in form and substance.
C. Whether the Court of Appeals incorrectly dismissed claims of grave abuse of discretion by the trial court.
D. Whether the Court of Appeals erred in upholding the validity of the informations despite private respondents’ admission of unauthorized use of the footage.

Supreme Court Ruling — Disposition

The Supreme Court denied the petition and affirmed the CA decision in toto.

Supreme Court Reasoning — Certiorari Remedy and Grave Abuse Threshold

  • The Court reiterated the general rule: denial of a motion to quash is ordinarily interlocutory and not properly challenged by a special civil action for certiorari under Rule 65 because an adequate remedy exists — to proceed to trial and, if convicted, raise the denial on appeal.
  • Certiorari is an exceptional remedy reserved for cases showing lack or excess of jurisdiction or grave abuse of discretion. The Court cited jurisprudence (Maximo; Galzote; Pascua) to enumerate exceptions permitting certiorari (e.g., order issued without or in excess of jurisdiction; patently erroneous interlocutory order where appeal is inadequate; matters of substantial public interest requiring expedition).
  • Petitioners had not shown the requisite grave abuse; they failed to demonstrate that the RTC acted capriciously, whimsically, or in a despotic or biased manner amounting to an evasion of duty or that any of the recognized exceptions applied. The RTC’s denial was based on a facial evaluation that the informations were prima facie complete and compliant with procedural requirements. The Court emphasized that without compelling circumstances, resort to certiorari after denial of a motion to quash constitutes delay and dilatory tactics.

Supreme Court Reasoning — Sufficiency of the Informations

  • The Court applied Section 6, Rule 110: an information is sufficient if it states the name of the accused; the statutory designation of the offense; the acts or omissions constituting the offense; the name of the offended party; the approximate date; and the place of the commission.
  • The test is whether the material facts alleged in the information will establish the essential elements of the offense charged, without considering matters aliunde. The information need not reproduce the statutory language verbatim but must adequately inform the accused to prepare a defense.
  • The Court found the two informations satisfied these requirements: they identified accused persons; designated the crime as libel; alleged the acts and participation of each petitioner; named the offended parties; and stated the date and place. The elements of libel (discreditable imputation, publication, identifiability of the person defamed, and existence of malice) were sufficiently pleaded.
  • Challenges to identifiability, truth, and malice were characterized as proper defenses more appropriately resolved at trial rather than through an interlocutory motion to quash.

Supreme Court Reasoning — Admission of Unauthorized Use and Presumption of Malice

  • Petitioners argued that private respondents admitted una
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