In People v. Benipayo, the Supreme Court definitively ruled that Regional Trial Courts (RTCs) have exclusive original jurisdiction over libel cases, regardless of whether the alleged defamatory act was committed by a public official in relation to their office. This means that individuals or corporations seeking legal recourse for libel must file their cases directly with the RTC, ensuring proper venue and preventing jurisdictional errors that could delay or dismiss their claims. This decision clarifies the judicial process for defamation cases, ensuring consistent application of the law.

Defamation on Air and in Print: Who Decides Libel Cases?

The consolidated cases arose from statements made by Alfredo L. Benipayo, then Chairman of the Commission on Elections (COMELEC), which Photokina Marketing Corporation believed were libelous. The first case stemmed from a speech Benipayo delivered criticizing a proposed contract, while the second involved remarks made during a televised interview about the funding of a “PR” campaign. Both cases were initially dismissed by the Regional Trial Courts, which incorrectly concluded that the Sandiganbayan had jurisdiction because the alleged libel was related to Benipayo’s official duties. The Supreme Court, however, overturned these dismissals, clarifying the jurisdictional boundaries for libel cases.

The central legal question before the Supreme Court was whether the RTC had jurisdiction over libel cases to the exclusion of all other courts, including the Sandiganbayan. To resolve this, the Court emphasized the principle that jurisdiction is determined by the law in force at the time the action is instituted. Article 360 of the Revised Penal Code (RPC), as amended by Republic Act No. 4363, explicitly states that criminal and civil actions for written defamation shall be filed with the court of first instance, now the Regional Trial Court.

The criminal and civil action for damages in cases of written defamations as provided for in this chapter, shall be filed simultaneously or separately with the court of first instance [now, the Regional Trial Court] of the province or city where the libelous article is printed and first published or where any of the offended parties actually resides at the time of the commission of the offense xxx.

Building on this principle, the Supreme Court cited its previous rulings in Jalandoni v. Endaya and Bocobo v. Estanislao, which affirmed the RTC’s exclusive and original jurisdiction over written defamation cases. The Court reiterated that this jurisdiction remains with the RTC even if the libelous act is committed “by similar means,” as defined in Article 355 of the Revised Penal Code. This ensures that all forms of written defamation, whether through traditional means or modern media, are consistently adjudicated by the RTC.

The respondent argued that because he was a public official and the statements were made in relation to his office, the Sandiganbayan should have jurisdiction. However, the Supreme Court clarified that the grant of jurisdiction to the Sandiganbayan over offenses committed in relation to public office did not divest the RTC of its exclusive jurisdiction over written defamation cases. The Court emphasized that a general provision granting jurisdiction to one court does not automatically override a specific provision granting jurisdiction to another, absent an express repeal or modification.

To further illustrate this point, the Court referred to the case of Manzano v. Hon. Valera, which involved a similar jurisdictional issue. In Manzano, the Court held that Republic Act No. 7691, which expanded the jurisdiction of first-level courts, did not alter the provision of Article 360 of the RPC, which specifically lodges jurisdiction over libel cases with the RTC. The Court reasoned that laws vesting jurisdiction exclusively with a particular court are special in character and prevail over general laws defining the jurisdiction of other courts.

Laws vesting jurisdiction exclusively with a particular court, are special in character, and should prevail over the Judiciary Act defining the jurisdiction of other courts (such as the Court of First Instance) which is a general law.

The Court also noted that there was no manifest intent in Republic Act No. 7691 to repeal or alter the jurisdiction in libel cases. Implied repeals are not favored, and effect must be given to all enactments of the legislature. The Supreme Court also cited Administrative Order No. 104-96, which designated the RTCs as the courts with exclusive jurisdiction over libel cases, further solidifying this position.

This approach contrasts with the lower courts’ interpretation, which had focused on whether the alleged libel was committed in relation to the respondent’s public office. The Supreme Court clarified that this determination is irrelevant to the jurisdictional question. Jurisdiction over written defamation cases exclusively rests in the RTC without qualification, rendering arguments about the nature of the offense moot. The Court thus ordered the reinstatement of the criminal cases and their remand to the respective Regional Trial Courts for further proceedings.

The practical implications of this ruling are significant. It ensures that libel cases are consistently heard in the appropriate venue, preventing delays and jurisdictional disputes that could undermine the administration of justice. Moreover, it reinforces the principle that specific laws take precedence over general laws in determining jurisdiction, providing clarity and predictability in the legal system. This decision serves as a reminder to both the bench and the bar of the importance of adhering to established jurisdictional rules and statutory provisions.

In summary, the Supreme Court’s decision in People v. Benipayo reaffirms the Regional Trial Court’s exclusive jurisdiction over libel cases. By clarifying this jurisdictional boundary, the Court has provided a clear roadmap for those seeking legal recourse for written defamation, ensuring that their cases are heard in the proper forum. This decision underscores the importance of adhering to specific legal provisions and established precedents in determining jurisdiction, thereby promoting fairness and efficiency in the administration of justice.

FAQs

What was the key issue in this case?	The central issue was whether the Regional Trial Court (RTC) or the Sandiganbayan had jurisdiction over libel cases involving public officials. The Supreme Court clarified that the RTC has exclusive original jurisdiction.
What is Article 360 of the Revised Penal Code?	Article 360 of the Revised Penal Code, as amended, specifies that criminal and civil actions for written defamation should be filed with the Regional Trial Court. This provision was central to the Supreme Court’s decision.
Did Republic Act No. 7691 affect the RTC’s jurisdiction over libel cases?	No, Republic Act No. 7691, which expanded the jurisdiction of lower courts, did not alter the RTC’s exclusive jurisdiction over libel cases. The Supreme Court held that the specific provision in the RPC prevails over the general law.
What did the Court say about libel committed by public officials?	The Court clarified that even if a public official commits libel in relation to their office, the RTC still has jurisdiction. The Sandiganbayan’s jurisdiction over offenses related to public office does not override the RTC’s specific jurisdiction over libel.
What is the significance of Jalandoni v. Endaya and Bocobo v. Estanislao?	These cases were cited by the Supreme Court to reinforce the principle that the RTC has exclusive original jurisdiction over written defamation cases. They serve as precedents supporting the Court’s decision in People v. Benipayo.
What is the effect of Administrative Order No. 104-96?	Administrative Order No. 104-96 designates the RTCs as the courts with exclusive jurisdiction over libel cases. This administrative order further supports the Supreme Court’s ruling.
What was the final ruling of the Supreme Court in this case?	The Supreme Court granted the petitions, reinstated the criminal cases, and remanded them to the Regional Trial Court of Quezon City for further proceedings. This affirmed the RTC’s jurisdiction over the libel cases.
What is the practical implication of this decision for individuals and corporations?	This decision clarifies the proper venue for filing libel cases, ensuring that individuals and corporations seeking legal recourse for defamation file their cases directly with the RTC. This prevents jurisdictional errors that could delay or dismiss their claims.

In conclusion, the Supreme Court’s decision in People v. Benipayo provides clear guidance on the jurisdictional boundaries for libel cases, reinforcing the Regional Trial Court’s exclusive authority. This ruling ensures that defamation claims are handled efficiently and consistently, promoting justice and protecting the rights of individuals and corporations affected by libelous statements.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People v. Benipayo, G.R. No. 154473, April 24, 2009