Macasaet v. People and Joselito Trinidad, G.R. No.

156747,
February 23, 2005
Chico-Nazario, J.

Facts:
Alfie Lorenzo and co-petitioners faced libel charges in the Regional
Trial Court (RTC) of Quezon City, where a jurisdictional dispute arose due to
the information stating the private respondent's residence as Marikina. Despite
an arraignment order, the petitioners aimed to halt proceedings, intending to
appeal to the Department of Justice (DOJ). The trial court proceeded with
arraignment, resulting in a not guilty plea entered for the petitioners.
Subsequently, they filed a Motion to Dismiss, asserting lack of jurisdiction
based on the private respondent's Marikina residence. The trial court, in an
Order, dismissed the case, citing evidence suggesting the libelous article
originated in Manila and conflicting information on the private respondent's
address. The private respondent, claiming residence in Quezon City during
the article's publication, filed a motion for reconsideration, denied by the court
due to credibility concerns over supplemental evidence. On appeal, the Court
of Appeals overturned the trial court's decision, highlighting the importance
of actual residence for venue determination and valuing a supplemental
affidavit's curative effect. The court discredited barangay certifications and
gave weight to an affidavit supporting the private respondent's Quezon City
residence. The petitioners, dissatisfied with the appellate court's ruling, filed
this petition.

Issue:
Whether or not the Regional Trial Court (RTC) of Quezon City has
jurisdiction over the libel case filed against the petitioners.

Ruling:
The Supreme Court held that the RTC of Quezon City has no
jurisdiction over the case. In criminal cases, venue is jurisdictional, and the
place where the crime was committed determines jurisdiction. In libel cases,
the venue must be where the libelous article is printed and first published or
where the offended party resides at the time of the offense. The court finds the
information filed before the trial court insufficient to vest jurisdiction in the
RTC of Quezon City. The court dismisses the private respondent's argument
that the supplemental affidavit cured the defect, stating that jurisdiction is
determined by the allegations in the complaint or information.

The court also rejects the argument that the affidavit of Del Rosario
submitted during the preliminary investigation cured the defect, stating that
supplemental pleadings should deal with events occurring after the original
pleading. The court concludes that the private and public prosecutors had the
personality to file the notice of appeal before the trial court, and the OSG's
involvement begins at the appellate level after the trial court loses jurisdiction.