GR 122068; (July, 1998) (Digest)
G.R. No. 122068 July 8, 1998
JUANITO MANZANO, petitioner, vs. HON. REDENTOR VALERA, Judge, Municipal Trial Court of Bangued, Abra, and VILMA A. BOBILA, respondents.
FACTS
On June 2, 1994, a criminal complaint for libel was filed by private respondent Vilma Bobila against petitioner Juanito Manzano in the Municipal Trial Court (MTC) of Bangued, Abra. The complaint alleged that Manzano, a police officer, caused false and defamatory statements to be entered into the PNP police blotter against Bobila. Initially, the respondent Judge forwarded the case to the Office of the Provincial Prosecutor, recognizing the Regional Trial Court’s (RTC) jurisdiction. However, the prosecutor, invoking the amendment by Republic Act No. 7691 to Batas Pambansa Blg. 129, opined that the MTC had jurisdiction. The records were returned to the MTC. Petitioner filed a Motion to Dismiss for lack of jurisdiction. The Assistant Provincial Prosecutor, in his Comment, supported the motion, citing that libel is outside the jurisdiction of inferior courts based on Jalandoni vs. Endaya. Despite this, the respondent Judge denied the Motion to Dismiss and the subsequent Motion for Reconsideration, holding that R.A. 7691 amended the jurisdiction over libel cases. Petitioner filed this petition for certiorari and prohibition.
ISSUE
Whether the Municipal Trial Court or the Regional Trial Court has exclusive original jurisdiction over a criminal case for libel.
RULING
The Regional Trial Court has exclusive original jurisdiction over libel cases. The petition is GRANTED. The respondent court’s orders dated August 2 and August 30, 1995, are declared NULL and VOID for having been issued without jurisdiction. The MTC is permanently enjoined from proceeding with Criminal Case No. 5728 and is commanded to forward the case to the Executive Judge of the RTC.
The Supreme Court ruled that the applicable law is Article 360 of the Revised Penal Code, which categorically provides that jurisdiction over libel cases is lodged with the Courts of First Instance (now Regional Trial Courts). This special law prevails over the general provisions of R.A. 7691, which expanded the jurisdiction of first-level courts. The Court cited its previous rulings in People vs. MTC of Quezon City and Caro vs. Court of Appeals, which held that RTCs retain exclusive jurisdiction over libel cases. The principle that a special law prevails over a general law applies, and there is no manifest intent in R.A. 7691 to repeal the jurisdiction vested by Article 360. Implied repeals are not favored, and no irreconcilable inconsistency exists between the two laws. Furthermore, Administrative Order No. 104-96 issued by the Court explicitly designates that libel cases shall be tried by the RTC to the exclusion of the MTCs.