Understanding Court Jurisdiction in Philippine Libel Cases

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G.R. No. 123263, December 16, 1996: PEOPLE OF THE PHILIPPINES, PETITIONER, VS. METROPOLITAN TRIAL COURT OF QUEZON CITY, BRANCH 32, AND ISAH V. RED, RESPONDENTS.

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Imagine someone publishes a damaging article about you. Where do you file the libel case? This decision clarifies which court has the power to hear libel cases, settling a jurisdictional dispute between the Regional Trial Court (RTC) and Metropolitan Trial Court (MeTC). The Supreme Court, in this case, definitively states that Regional Trial Courts have exclusive original jurisdiction over libel cases, regardless of the penalty involved.

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The Heart of the Matter: Jurisdiction Over Libel

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The central legal question revolves around which court, the RTC or the MeTC, has the power to initially hear criminal libel cases. This issue arose because of conflicting laws and interpretations regarding court jurisdiction based on the potential penalties involved in the crime.

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The Legal Landscape: Article 360 and Republic Act No. 7691

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The Revised Penal Code, particularly Article 360, specifically designates the Court of First Instance (now Regional Trial Court) as the venue for libel cases. This article states that criminal and civil actions for libel “shall be filed simultaneously or separately with the Court of First Instance 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.”

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However, Republic Act No. 7691 expanded the jurisdiction of Metropolitan Trial Courts, giving them exclusive original jurisdiction over offenses punishable by imprisonment not exceeding six years, irrespective of the amount of fine. Libel, under the Revised Penal Code, carries a penalty of imprisonment within this range, leading to confusion about which court should handle such cases.

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To illustrate, consider a scenario where a defamatory post is published online in Quezon City, where the offended party also resides. According to Article 360, the libel case should be filed with the RTC of Quezon City. However, R.A. 7691 seemingly grants jurisdiction to the MeTC due to the imposable penalty. This is the conflict the Supreme Court addressed.

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The Case Unfolds: From RTC to MetroTC and Back

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The case began when an information for libel was filed against Isah V. Red in the Regional Trial Court of Quezon City. Red then filed a motion to quash, arguing that the RTC lacked jurisdiction. The RTC initially agreed and remanded the case to the Metropolitan Trial Court, citing R.A. No. 7691.

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The private prosecutor, under the Fiscal’s supervision, filed a