GR 123263; (December, 1996) (Digest)
G.R. No. 123263 December 16, 1996
PEOPLE OF THE PHILIPPINES, petitioner, vs. METROPOLITAN TRIAL COURT OF QUEZON CITY, Branch 32, and ISAH V. RED, respondents.
FACTS
An information for libel was filed against Isah V. Red in the Regional Trial Court of Quezon City. Red moved to quash, arguing the RTC lacked jurisdiction. The RTC granted the motion, citing Republic Act No. 7691, which vests in first-level courts exclusive original jurisdiction over offenses punishable by imprisonment not exceeding six years. It remanded the case to the Metropolitan Trial Court. The prosecution subsequently filed a motion to remand the case back to the RTC, invoking Article 360 of the Revised Penal Code, as amended, which designates the Court of First Instance (now RTC) to try libel cases. The MeTC denied this motion and subsequent motions for reconsideration, opining that R.A. 7691, being a later law, impliedly repealed the relevant provision of the 1932 Revised Penal Code.
ISSUE
Whether the Metropolitan Trial Court or the Regional Trial Court has exclusive original jurisdiction over criminal actions for libel.
RULING
The Supreme Court ruled that the Regional Trial Court retains exclusive original jurisdiction over libel cases. The legal logic is grounded in statutory construction. While R.A. 7691 generally grants first-level courts jurisdiction over offenses with penalties not exceeding six years, it explicitly excludes from this grant “cases falling within the exclusive original jurisdiction of the Regional Trial Courts.” Article 360 of the Revised Penal Code is a special law that specifically designates the Court of First Instance (RTC) to try libel cases. Under the principle that a special law prevails over a general law, and a subsequent general statute does not impliedly repeal a prior special one unless the intent to repeal is manifest, Article 360 remains operative. The Court reaffirmed its precedents, such as Jalandoni v. Endaya and Bocobo v. Estanislao, which established the RTC’s jurisdiction over libel. Consequently, the MeTC acted without jurisdiction. The challenged orders, being interlocutory, were properly assailed via certiorari. The petition was granted, and the MeTC was enjoined from proceeding and ordered to remand the case to the RTC.