People v. Te
REITERATIONFacts
The Antecedents: Edward Field, an American citizen residing in Manila and working at Clark Airbase, filed a complaint on March 4, 1955, with the justice of the peace court of Balayan, Batangas, for libel based on an article published in 'Bagong Buhay' on August 12, 1954. The defendants were residents of Pangasinan and Manila. Procedural History: After a preliminary investigation, the justice of the peace court elevated the case to the Court of First Instance (CFI) of Batangas, Balayan Branch. The provincial fiscal filed an information on July 8, 1955. During the hearing, the defendants moved to dismiss, arguing that the CFI of Batangas lacked jurisdiction. They contended that another information for the same libelous publication had already been filed in the CFI of Manila on May 18, 1955, and that Republic Act No. 1289, which amended Article 360 of the Revised Penal Code, vested sole and exclusive jurisdiction in the CFI of Manila. The lower court granted the motion, not on the ground of prior filing in Manila, but because the case should have been filed in the province or city where the complainant or any of the accused resides (Pangasinan or Manila), not Batangas. The Petition: The government appealed the dismissal order, assigning errors related to the applicability of Republic Act No. 1289 and the jurisdiction of the CFI of Batangas.
Issue(s)
Whether Republic Act No. 1289 is applicable to the instant case. Whether the Court of First Instance of Batangas had jurisdiction to take cognizance of the case, considering that an information for the same offense was filed earlier in the Court of First Instance of Manila. Whether the action for libel should have been brought in the court of first instance of the province where the complainant or any of the accused resides.
Ruling
The Supreme Court affirmed the order of dismissal, but on the ground that the Court of First Instance of Manila had already acquired exclusive jurisdiction over the case by virtue of the prior filing of the information therein.
Ratio Decidendi
On the applicability of Republic Act No. 1289: The Court held that Republic Act No. 1289, which took effect on June 15, 1955, was applicable to the case. The proviso stating that the amendment shall not apply to cases where civil and/or criminal actions 'have been filed in court' refers to filing with the court of competent jurisdiction. The complaint filed with the justice of the peace court of Balayan on March 4, 1955, was merely for preliminary investigation and not the commencement of the criminal action, as the justice of the peace court was not the proper court to try the libel case. Therefore, the filing of the information on July 8, 1955, after the law took effect, meant the case was governed by Republic Act No. 1289. On the jurisdiction of the Court of First Instance of Batangas: The Court found that an information for libel based on the same publication was filed with the CFI of Manila on May 18, 1955, in Criminal Case No. 31319. The information in the Batangas case was filed on July 8, 1955. Republic Act No. 1289 explicitly states that 'the court where the criminal action or civil action for damage is first filed, shall acquire jurisdiction to the exclusion of other courts.' Consequently, the CFI of Manila, having acquired jurisdiction first, excluded all other courts of equal category, including the CFI of Batangas. Therefore, the CFI of Batangas did not have jurisdiction to take cognizance of the case. On the venue of the action: The Court found it unnecessary to pass upon the issue of whether the action should have been brought in the province where the complainant or any of the accused resides, as the issue of jurisdiction based on the prior filing in Manila had already been resolved.
Main Doctrine
The filing of a complaint for preliminary investigation with a justice of the peace court, which is not the court of competent jurisdiction to try the case, does not commence the criminal action for purposes of Republic Act No. 1289. Jurisdiction is acquired by the court where the information is first filed.