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People vs. Benipayo 586 SCRA Facts

The Supreme Court ruled that the regional trial court, not the Sandiganbayan, has jurisdiction over the libel case against the COMELEC chairman. The RPC specifically gives regional trial courts exclusive jurisdiction over cases involving written defamation. While the Sandiganbayan has jurisdiction over offenses committed in relation to public office, this does not override the RPC's explicit grant of jurisdiction to regional trial courts for libel cases. Therefore, the regional trial court erred in dismissing the case against the COMELEC chairman for lack of jurisdiction. The case is remanded to the regional trial court for further proceedings.

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85 views2 pages

People vs. Benipayo 586 SCRA Facts

The Supreme Court ruled that the regional trial court, not the Sandiganbayan, has jurisdiction over the libel case against the COMELEC chairman. The RPC specifically gives regional trial courts exclusive jurisdiction over cases involving written defamation. While the Sandiganbayan has jurisdiction over offenses committed in relation to public office, this does not override the RPC's explicit grant of jurisdiction to regional trial courts for libel cases. Therefore, the regional trial court erred in dismissing the case against the COMELEC chairman for lack of jurisdiction. The case is remanded to the regional trial court for further proceedings.

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Paula Bitor
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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b-2 Private individuals committing the offense/crime with public officers

People vs. Benipayo

586 SCRA

Facts:

Photokina Marketing Inc. filed an affidavit complaint for libel against respondent Benipayo,
COMELEC Chairman, for allegedly being the one alluded to by the respondent in his speech at
UP Diliman which was published in Manila Bulletin issues.

Said speech is as follows: “Now, they are at it again, trying to hoodwink us into contract that is
so grossly disadvantageous to the government that it offends common sense to say that it would
be worth the 6.5 billion-peso price tag.”

Arguing that he’s an impeachable officer, respondent questioned the jurisdiction of the Office of
the Prosecutor of QC. City prosec. Still filed an information for libel against him.

Respondent, for his part, moved for the dismissal of the case on the assertion that the trial court
had no jurisdiction over his person for he was an impeachable officer and thus, could not be
criminally prosecuted before any court during his incumbency; and that, assuming he can be
criminally prosecuted, it was the Office of the Ombudsman that should investigate him and the
case should be filed with the Sandiganbayan.

Trial court dismissed the case for lack of jurisdiction considering that the alleged libel was
committed by respondent in relation to his office when he delivered speech in his official capacity
as COMELEC Chair. Accordingly, it was the Sandiganbayan that had jurisdiction over the case
to the exclusion of all other courts.

On motion for reconsideration, the trial court adhered to its ruling that it was not vested with
jurisdiction to hear the libel case.

ISSUE:

Whether the respondent committed the crime of libel in relation to his office and that the trial court
is correct in saying that it has no jurisdiction over the case?

HELD:

Criminal and civil actions for damages in cases of written defamations shall be filed
simultaneously or separately with the RTC to the exclusion of all other courts. A subsequent
enactment of a law defining the jurisdiction of other courts cannot simply override, in the absence
of an express repeal or modification, the specific provision in the RPC vesting in the RTC, as
aforesaid, jurisdiction over defamations in writing or by similar means.1 The grant to the
Sandiganbayan2 of jurisdiction over offenses committed in relation to (public) office, similar to the
expansion of the jurisdiction of the MTCs, did not divest the RTC of its exclusive and original
jurisdiction to try written defamation cases regardless of whether the offense is committed in
relation to office. The broad and general phraseology of Section 4, Presidential Decree No. 1606,
as amended by Republic Act No. 8249,3 cannot be construed to have impliedly repealed, or even
simply modified, such exclusive and original jurisdiction of the RTC.

Since jurisdiction over written defamations exclusively rests in the RTC without qualification, it is
unnecessary and futile for the parties to argue on whether the crime is committed in relation to
office. Thus, the conclusion reached by the trial court that the respondent committed the alleged
libelous acts in relation to his office as former COMELEC chair, and deprives it of jurisdiction to
try the case, is, following the above disquisition, gross error. This Court, therefore, orders the
reinstatement of Criminal Cases Nos. Q-02-109406 and Q-02-109407 and their remand to the
respective Regional Trial Courts for further proceedings. Having said that, the Court finds
unnecessary any further discussion of the other issues raised in the petitions.

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