G.R. No. 237620, April 28, 2021
ERWIN TULFO, LILIBETH FRONDOSO, LYNDA JUMILLA, MARIA PROGENA, ESTONILLO REYES, ANNA LIZA EUGENIO, FERNANDO GARCIA, EUGENIO LOPEZ III, LUIS F. ALEJANDRO, JOSE RAMON OLIVES, JESUS “JAKE” MADERAZO, LUISITA CRUZ-VALDES, JOSE “JING” MAGSAYSAY, JR., AND ALFONSO “PAL” A. MARQUEZ III, PETITIONERS, VS. PEOPLE OF THE PHILIPPINES, FELIPE L. GOZON, GILBERTO R. DUAVIT, JR., MARISSA L. FLORES, JESSICA A. SOHO, GRACE DELA PEÑA-REYES, AND JOHN OLIVER T. MANALASTAS, RESPONDENTS.

FACTS

This is a Petition for Review on Certiorari assailing the Court of Appeals Decision dated August 17, 2017 that dismissed the petitioners’ Petition for Certiorari under Rule 65 and affirmed the Orders dated April 16, 2013 and June 11, 2013 of the Regional Trial Court (RTC), Branch 88, Quezon City in Criminal Case Nos. Q-13-180642-43. The RTC Orders denied the petitioners’ motions, including a motion for reconsideration of the judicial determination of probable cause and a motion to quash.
The case stemmed from two Informations dated January 28, 2013, charging the petitioners with Libel under Article 353 of the Revised Penal Code. The charges arose from the airing of reports on the ABS-CBN news program “Insider” on July 22 and 23, 2004, concerning the arrival of Angelo dela Cruz from Iraq. The reports alleged that GMA-7 had stolen or pirated exclusive video footage of the event taken by ABS-CBN. Specific statements made by petitioners Erwin Tulfo and Lynda Jumilla were quoted in the Informations, accusing GMA-7 of theft or piracy of video footage. The Informations alleged that these statements were false, made maliciously, and exposed the complainants—Felipe L. Gozon, Gilberto R. Duavit, Jr., Marissa L. Flores, Jessica A. Soho, Grace dela Peña-Reyes, and John Oliver T. Manalastas (officials of GMA Network)—to public ridicule, dishonor, and contempt.

ISSUE

The primary issue for resolution is whether the Court of Appeals committed reversible error in dismissing the petitioners’ Rule 65 petition and affirming the RTC Orders, which upheld the finding of probable cause and denied the motions to quash the Informations and recall the warrants of arrest.

RULING

The Supreme Court denied the petition. The Court held that the petitioners failed to sufficiently show that the Court of Appeals committed any reversible error in its assailed Decision. The Court found that the petitioners’ arguments essentially invited a review of factual findings, which is not the function of a Rule 45 petition. The Court emphasized that the determination of probable cause for the issuance of a warrant of arrest is a judicial function, and in this case, the RTC judge personally evaluated the evidence and found probable cause. The Court also noted that the elements of libel appeared to be present based on the allegations in the Informations. Furthermore, the Court ruled that the petitioners’ claim of prescription of the offense was unavailing, as the prescriptive period for libel is one year, and the filing of the complaint with the Office of the City Prosecutor in 2004 interrupted the period. The Informations were filed within the revived period. The Court also found no merit in the claim of violation of the right to speedy disposition of cases, as the petitioners failed to prove the factual elements of such a violation. Consequently, the Court affirmed the CA Decision dismissing the petitioners’ challenge to the RTC Orders.