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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court decided that R.A. No. 7691 impliedly repealed Art. 360 of the RPC.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Whether or not R.A. No. 7691 repealed the provision on Art. 360 of the RPC mandating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.
Posted by sharppy38 at 7:38 PM

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