PEOPLE OF THE
PHILIPPINES
vs.
METROPOLITAN
TRIAL COURT OF QUEZON CITY, Branch 32,
and ISAH V. RED
FACTS:
Private respondent, Isah V. Red, was charged
with the crime of libel before the Regional Trial Court of Quezon City.
Thereafter, Red filed a motion to quash the information on the ground that the
Regional Trial Court has no jurisdiction over the offense charged. The Regional
Trial Court granted the motion and remanded the case to the Metropolitan Trial
Court of Quezon City.
The
prosecution, citing the provision of Article 360 of the Revised Penal Code
filed a manifestation and motion to remand praying that the case be returned to
the Regional Trial Court.
ISSUE:
Whether or not the crime of libel falls on the jurisdiction of the
Regional Trial Court.
HELD:
Yes, the crime of libel falls under the
jurisdiction of the Regional Trial Court.
Article
360 of the Revised Penal Code pertinently provides that:
“The criminal
action and civil action for damages in case of written defamation, as provided
for in this chapter, shall be filed simultaneously or separately with the Court of First Instance 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…”
Republic
Act 7691, placing the exclusive and original jurisdiction of offenses punishable
by not more than six years of imprisonment under the Municipal Trial Court did
superseded Article 360 of the Revised Penal Code, as there is no manifest
legislative purpose to do so or an irreconcilable inconsistency and repugnancy
exist between them.