G.R. No. L-11747; March 24, 1960
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. FELISA TE, ET AL., defendants-appellees.

FACTS

A libel case was commenced in the justice of the peace court of Balayan, Batangas, on March 4, 1955, based on a complaint filed by Edward Field regarding an alleged libelous article published in the “Bagong Buhay” newspaper on August 12, 1954. The defendants were residents of Pangasinan and Manila. After a preliminary investigation, the case was elevated to the Court of First Instance of Batangas, where the provincial fiscal filed an information on July 8, 1955. During the trial, after the prosecution rested, the defendants moved to dismiss on the ground of lack of jurisdiction. They pointed out that another information for libel based on the same publication had already been filed by the City Fiscal of Manila with the Court of First Instance of Manila on May 18, 1955 (Criminal Case No. 31319). The lower court granted the motion to dismiss, holding that the case should have been filed in the court of the province or city where the complainant or any accused resides (i.e., Pangasinan or Manila), not Batangas. The government appealed.

ISSUE

The primary issue is whether Republic Act No. 1289 , which amended the venue provisions for libel cases under Article 360 of the Revised Penal Code, is applicable to the instant case, and consequently, whether the Court of First Instance of Batangas had jurisdiction to take cognizance of the case.

RULING

The Supreme Court affirmed the order of dismissal. It held that Republic Act No. 1289 , which took effect on June 15, 1955, was applicable. The Court rejected the government’s contention that the Act’s final proviso (stating it shall not apply to cases where actions “have been filed in court at the time of the effectivity of this law”) exempted the case because a complaint had been filed with the justice of the peace court before the Act’s passage. The Court ruled that the phrase “filed in court” in the proviso refers to filing with a court of competent jurisdiction—one with the power to try and decide the case. The justice of the peace court was not such a court for libel, as it could only conduct a preliminary investigation. The criminal action commenced only upon the filing of the information in the Court of First Instance on July 8, 1955, which was after the Act’s effectivity. Applying Republic Act No. 1289 , specifically its proviso that “the court where the criminal action or civil action for damages is first filed, shall acquire jurisdiction to the exclusion of other courts,” the Court of First Instance of Manila, which first acquired jurisdiction by filing its information on May 18, 1955, had exclusive jurisdiction. Therefore, the Court of First Instance of Batangas correctly dismissed the case for lack of jurisdiction.