People vs. MTC of Quezon City, Br. 32, et. al., G.R. No. 123263, Dec. 16, 1996

Criminal Procedure - Jurisdiction

Facts:

On January 30, 1995, an Information charging libel was filed against Isah V. Red in the RTC of Quezon City. Red filed a motion to quash the information on the ground that the RTC has no jurisdiction over the offense. The RTC Judge found merit on the motion and remanded the case to the Metropolitan Trial Court of Quezon City. The Judge based his decision on Sec.2 of R.A. No. 7691 which says that "all offenses punishable with imprisonment not exceeding six (6) years, irrespective of the amount of fine, and regardless of other imposable accessory or other penalties, including the civil liability arising from such offenses or predicated thereon, irrespective of kind, nature, value or accessory thereof is vested in the Municipal Trial Court." 

Then, the private prosecutor filed a "Manifestation and Motion to Remand" praying for the case to be returned to the RTC. The prosecution invoked in his motion Art. 360 of the RPC, and several cases to support their stand that it is the RTC which has exclusive jurisdiction on libel cases. But, the lower court denied the motion. The respondent lower court decided that R.A. No. 7691 impliedly repealed Art. 360 of the RPC. The new law provides a lighter penalty to the offense making it the proper law to be applied to the case. The private prosecutor filed a motion for reconsideration but was again denied and the prosecution was ordered to present its next witness. Hence, this petition to the Supreme Court.

Issue:

Whether or not R.A. No. 7691 repealed the provision on Art. 360 of the RPC mandating that in cases of libel, criminal and civil actions should be filed in the Court of First Instance (now RTC) of the place where the offense was committed.

Who has exclusive jurisdiction over criminal actions of libel, the Regional Trial Court or the Metropolitan Trial Court?

Whether or not venue is merely procedural as claimed by the respondents.

Held:

The Supreme Court ruled in favor of the petitioner.

The Court held that R.A. 7691 did not repeal Art.360 of the RPC. While libel has the penalty of six months and one day to four years and two months, making it triable under municipal trial courts, R.A. No. 7691 excludes cases falling within the exclusive jurisdiction of the RTC. Prior decisions also say that the expansion of the MTC's jurisdiction conferred by the new law cannot be applied to libel cases.

Further, the Court also cited Administrative Order No. 104-96 which provides that "libel cases shall be tried by the Regional Trial Courts having jurisdiction over them to the exclusion of the Metropolitan Trial Courts, Municipal Trial Courts in Cities, Municipal Trial Courts and Municipal Circuit Trial Courts." So, the jurisdiction over libel cases falls under the exclusive jurisdiction of the Regional Trial Courts. 

Lastly, in civil cases, the venue is merely procedural; but in criminal cases, it is jurisdictional.