PEOPLE OF THE PHILIPPINES and PHOTOKINA MARKETING CORPORATION, Petitioners, vs. ALFREDO L.

BENIPAYO, Respondent
G.R. No. 154473, G.R. No. 155573, April 24, 2009

FACTS

Photonika Marketing Coporation believed that the speech delivered by Alfredo Benipayo, the COMELEC
Chairman on the Forum of Electoral Problems held in UP – Diliman which was also published in 2 issues
of Manila Bulletin alluding them of overpricing their products. The petitioner filed a complaint- affidavit
to the Office of the Prosecutor, QC against Benipayo which was docketed in a criminal case in RTC.
Petitioner filed a motion contending the judge could not partially decide because his appointment was
made possible by the respondent’s father-in- law and further moved that the case be ordered
consolidated with the pending case in another RTC Branch. Pending the motion unresolved, respondent
moved for the dismissal of the case on the assertion that the trial court had no jurisdiction over his
person for he was an impeachable officer and could not be criminally prosecuted in his incumbency, that
the Ombudsman should investigate him and the case should be filed with Sandiganbayan.

In an interview televised nationwide as well, Benipayo also gave a statement which the petitioner found
it defamatory and filed a complaint-affidavit for libel to Office of the Prosecutor, QC. The city prosecutor
however, instituted the criminal case by the filing the information with the RTC of Quezon City.
Respondent also moved for the dismissal of the information raising similar arguments to the former case
filed in RTC. The RTC, in the further assailed the Order, denied petitioner’s Motion for Reconsideration.

ISSUE

Whether or not the Regional Trial Court has jurisdiction over libel cases

ANSWER

Yes, uniformly applied is the familiar rule that the jurisdiction of the court to hear and decide a case is
conferred by the law in force at the time of the institution of the action, unless a latter statute provides
for a retroactive application thereof. Article 360 of the Revised Penal Code (RPC), as amended by
Republic Act No. 4363, is explicit on which court has jurisdiction to try cases of written defamations,
thus: 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.