G.R. No. 46578 ; September 22, 1939
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. ANICETO MARQUEZ, defendant-appellee.

FACTS

Aniceto Marquez was charged with the crime of serious slander by deeds (injurias graves con lesiones) for allegedly insulting and slapping a public school teacher. The complaint was filed by the chief of police. The defendant filed a demurrer, arguing the court lacked jurisdiction because the complaint was not filed by the offended party, as allegedly required for defamation cases. The trial judge sustained the demurrer and dismissed the case, prompting the prosecution’s appeal.

ISSUE

Whether the trial court has jurisdiction over the criminal action for serious slander by deeds (injurias graves con lesiones) even if the complaint was filed by the chief of police and not by the offended party.

RULING

Yes. The trial court has jurisdiction. The order of dismissal is reversed, and the case is remanded for further proceedings. The requirement that the complaint be filed by the offended party under Article 360, paragraph 4 of the Revised Penal Code applies only to defamation cases that consist of the imputation of specific crimes that cannot be prosecuted de oficio (e.g., adultery, concubinage, seduction, abduction, rape, acts of lasciviousness). The offense charged here is serious slander by deeds under Article 359, which is not among those private crimes. Therefore, the rule on complaint by the offended party does not apply, and a complaint filed by the chief of police is sufficient to confer jurisdiction.

AI Generated by Armztrong.