PEOPLE OF THE PHILIPPINES vs. BENIPAYO G.R. No. 154473 & 155573, April 24, 2009

On January 31, 2002 Respondent, then Chairman of the Commission on Elections delivered a speech in a “Forum on Electoral Problems: Roots and Responses in the Philippines” and was subsequently published in Manila Bulletin. Petitioner corporation, believing that it was the one alluded to by the respondent filed, through its authorized representative, an Affidavit-Complaint for libel.

On March 13, 2002, respondent, was a guest of the talk show televised nationwide. In that episode, the respondent said statement which Petitioner considered as defamatory, and, through its authorized representative, filed a Complaint-Affidavit for libel.

Arguing that he was an impeachable officer, respondent questioned the jurisdiction of the Office of the City Prosecutor in both cases.

On June 18, 2002, the trial court issued the challenged Order dismissing the Cases and while the RTC found that respondent was no longer an impeachable officer because his appointment was not confirmed by Congress, it ruled that the case had to be dismissed for lack of jurisdiction considering that the alleged libel was committed by respondent in relation to his office—he delivered the speech in his official capacity as COMELEC Chair. Accordingly, it was the Sandiganbayan that had jurisdiction over the case to the exclusion of all other courts. On motion for reconsideration, the trial court adhered to its ruling that it was not vested with jurisdiction to hear the libel case. Aggrieved, Hence this case.

Whether the RTC has jurisdiction over libel cases to the exclusion of all other courts.

Yes, declare herein that the law, as it still stands at present, dictates that criminal and civil actions for damages in cases of written defamations shall be filed simultaneously or separately with the RTC to the exclusion of all other courts. A subsequent enactment of a law defining the jurisdiction of other courts cannot simply override, in the absence of an express repeal or modification, the specific provision in the RPC vesting in the RTC, as aforesaid, jurisdiction over defamations in writing or by similar means. The grant to the Sandiganbayan of jurisdiction over offenses committed in relation to (public) office, similar to the expansion of the jurisdiction of the MTCs, did not divest the RTC of its exclusive and original jurisdiction to try written defamation cases regardless of whether the offense is committed in relation to office. The broad and general phraseology of Section 4, Presidential Decree No. 1606, as amended by Republic Act No. 8249, cannot be construed to have impliedly repealed, or even simply modified, such exclusive and original jurisdiction of the RTC. Since jurisdiction over written defamations exclusively rests in the RTC without qualification, it is unnecessary and futile for the parties to argue on whether the crime is committed in relation to office. Thus, the conclusion reached by the trial court that the respondent committed the alleged libelous acts in relation to his office as former COMELEC chair, and deprives it of jurisdiction to try the case, is, following the above disquisition, gross error.


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