GR 13985; (September, 1918) (Digest)
G.R. No. 13985 ; September 16, 1918
VICENTE GARCIA VALDEZ, petitioner, vs. THE DIRECTOR OF PRISONS, respondent.
FACTS:
Vicente Garcia Valdez was convicted of libel in 1902 and sentenced to six months imprisonment and a fine. The complaint was signed by a private person, Pardo de Tavera, and not by the prosecuting attorney. Valdez appealed, and the Supreme Court affirmed the conviction in 1903. After the appeal, Valdez left the Philippines and later returned. In 1918, he was arrested to serve his sentence. He then filed a petition for a writ of habeas corpus, arguing that the trial court lacked jurisdiction because the complaint was not signed by the prosecuting attorney, in violation of Section 14 of Act No. 277 (the Libel Law), which requires criminal actions for libel to be “begun and prosecuted under the direction and control of the prosecuting officers.”
ISSUE:
Whether a criminal action for libel must be commenced exclusively by an information signed by the prosecuting attorney, or whether it may be validly initiated by a complaint signed by a private person, provided the prosecution is under the direction and control of the prosecuting officer.
RULING:
The Supreme Court DENIED the petition for habeas corpus. The Court held that a criminal action for libel may be validly commenced by a complaint signed by a private person, as long as the prosecution is conducted under the direction and control of the prosecuting officer. Section 14 of Act No. 277 does not require the prosecuting attorney to personally sign the complaint or information; it only mandates that the action be begun and prosecuted under their control. In this case, the prosecuting attorney actively directed the prosecution, and Valdez had admitted in his earlier appeal that the complaint was presented by the prosecuting attorney. Moreover, Valdez failed to object to the complaint during trial, and such an objection raised for the first time nearly fifteen years after the final judgment is untimely. The Court distinguished this from crimes like adultery and estupro, which by statute require a complaint signed by specific aggrieved persons. Thus, the trial court had jurisdiction, and the sentence is valid.