The People of the Philippines, plaintiff-appellant, vs. Juan B. Santos and Francisco Guballa, accused-appellees.
FACTS
Two informations for libel were filed by the Assistant Provincial Fiscal of Nueva Ecija against Juan B. Santos and Francisco Guballa. In the first case, the information reproduced a story entitled “Ahas Bahay” (House Snake), allegedly written by Juan B. Santos and published in “Bulaklak,” a magazine claimed to be edited by Francisco Guballa. The story depicted the offended party, Pastor Tayao, as an ingrate compared to a snake, detailing a scheme where he gained the confidence of a family and married their daughter. In the second case, the information reproduced a story entitled “Biniling Pagibig” (Purchased Love), also allegedly written by Santos and published in Guballa’s magazine, portraying Mercedes Tayao, daughter of Pastor Tayao, as a desperate and frustrated woman who failed to marry a doctor she supported. Upon arraignment, the defendants pleaded not guilty. Before the presentation of evidence, their counsel moved to quash the informations on the ground that the imputations did not constitute a crime prosecutable de oficio, and thus the court lacked jurisdiction without a complaint expressly filed by the offended parties. The trial court, following the rule in People vs. Jose de Martinez, dismissed the informations for want of such complaints. The Government appealed.
ISSUE
Whether a complaint expressly filed by the offended party is necessary for the court to acquire jurisdiction over libel cases where the imputation is of a vice or defect, real or imaginary, or any act tending to cause dishonor, discredit, or contempt, but does not constitute a crime that may be prosecuted de oficio.
RULING
No. The Supreme Court reversed and set aside the order of dismissal and remanded the cases for further proceedings. The Court held that the last paragraph of Article 360 of the Revised Penal Code, which requires the instance and complaint of the offended party, applies only to libel consisting of the imputation of a crime that cannot be prosecuted de oficio (such as adultery, concubinage, seduction, abduction, rape, and acts of lasciviousness). This is the sole exception provided by law. A libel imputing a vice or defect, real or imaginary, or any act, omission, condition, status, or circumstance tending to cause dishonor, discredit, or contempt-but which does not constitute a crime-is not included in this exception. Therefore, an information filed by the prosecuting officer alone is sufficient to confer jurisdiction on the court. The Court noted that the filing of the informations in these cases was the outcome of the prosecuting officer’s investigation after receiving written complaints from the offended parties, addressing any concern that prosecuting officers might act without such basis. The trial court’s dismissal, based on an extension of the People vs. Jose de Martinez rule, was not authorized by law.
