Time, Inc. v. Reyes
REITERATIONFacts
The Antecedents: Respondents Antonio J. Villegas (Mayor of Manila) and Juan Ponce Enrile (Undersecretary of Finance and Acting Commissioner of Customs) filed a civil case for damages against petitioner Time, Inc., publisher of 'Time' magazine, alleging libel. The libelous article, published in the August 18, 1967 issue of 'Time' (Asia Edition), was titled "Corruption in Asia" and purportedly imputed graft, corruption, and nepotism to the respondents, specifically detailing circumstances of alleged financial assistance to Mayor Villegas from a high government official, identified as respondent Enrile. Procedural History: The respondents-plaintiffs obtained a writ of attachment and leave to take depositions. Petitioner Time, Inc. received the summons and complaint on December 13, 1967, and subsequently filed a motion to dismiss based on lack of jurisdiction and improper venue, citing Republic Act No. 4363. The respondent court, on February 26, 1968, deferred the resolution of the motion to dismiss until after trial on the merits. A motion for reconsideration was denied, with the respondent judge reaffirming the deferment, stating that Republic Act No. 4363 was not applicable to non-resident defendants and that issues of harassment and inconvenience were not indubitable. The Petition: Petitioner Time, Inc. filed a petition for certiorari and prohibition with preliminary injunction, seeking to annul the orders of the respondent court for taking depositions, deferring the motion to dismiss, and reaffirming the deferment, as well as the writ of attachment. Petitioner argued that the respondent court lacked jurisdiction due to improper venue under Republic Act No. 4363, as the offended parties were public officers with offices in Manila, and the libelous article was not printed or first published in Rizal.
Issue(s)
Whether or not the respondent Court of First Instance of Rizal has jurisdiction to take cognizance of the civil suit for damages arising from an allegedly libelous publication, considering that the action was instituted by public officers whose offices were in the City of Manila at the time of the publication, under Republic Act No. 4363. Whether or not Republic Act No. 4363 is applicable to actions against a foreign corporation or non-resident defendant. Whether or not the respondent court's deferment of the motion to dismiss for lack of jurisdiction is correctible by certiorari or prohibition.
Ruling
The Supreme Court granted the writs applied for. It declared the respondent Court of First Instance of Rizal without jurisdiction to take cognizance of Civil Case No. 10403, annulled and set aside its orders issued in connection therewith, and commanded the respondent court to desist from further proceedings. The preliminary injunction was made permanent.
Ratio Decidendi
On Whether or not the respondent Court of First Instance of Rizal has jurisdiction to take cognizance of the civil suit for damages arising from an allegedly libelous publication, considering that the action was instituted by public officers whose offices were in the City of Manila at the time of the publication, under Republic Act No. 4363: The Court held that under the first proviso of Section 1 of Republic Act No. 4363, the venue for a civil action for damages in cases of written defamation against a public officer whose office is in Manila is limited to two choices: the Court of First Instance of the City of Manila or the city or province where the libelous article is printed and first published. Since the respondents-plaintiffs were public officers with offices in Manila at the time of the alleged offense, and the offending publication was not printed in the Philippines, the only proper venue was the Court of First Instance of Manila. The complaint lodged in the Court of First Instance of Rizal did not allege that the libelous article was printed and first published in Rizal, thus rendering the Rizal court without jurisdiction. The legislative intent behind Republic Act No. 4363 was to minimize 'out-of-town' libel suits against public officials to protect the public service and prevent harassment. On Whether or not Republic Act No. 4363 is applicable to actions against a foreign corporation or non-resident defendant: The Court ruled that Republic Act No. 4363 is applicable to actions against foreign corporations or non-resident defendants. The law's effectivity was conditioned upon the organization of a Philippine Press Council, and this condition applied to the entire statute, not selectively to resident defendants. The argument that a foreign corporation is not inconvenienced by an out-of-town suit was deemed irrelevant, as venue and jurisdiction are not dependent on convenience but on the policy of the law to protect public service. The inability to file a criminal case against a non-resident, whether natural or corporate, is a matter of international jurisdiction and does not render the venue provisions of Republic Act No. 4363 incongruous or absurd, especially since the case at bar is a civil action for damages. On Whether or not the respondent court's deferment of the motion to dismiss for lack of jurisdiction is correctible by certiorari or prohibition: The Court affirmed that the action of a court in refusing to rule, or deferring its ruling, on a motion to dismiss for lack of jurisdiction over the subject matter or for improper venue, is an excess of jurisdiction and is correctible by a writ of prohibition or certiorari. Such a deferment is not a mere interlocutory order when it clearly appears that the court is proceeding without jurisdiction, as it would be useless and a waste of time to continue with the proceedings. The jurisdiction of a court over the subject matter is determined by the allegations in the complaint, and these allegations are deemed admitted for the purpose of a motion to dismiss based on lack of jurisdiction, allowing the motion to be resolved without waiting for the trial. The Court cited several precedents establishing this principle, emphasizing that the consideration of such a motion may not be postponed in the hope that evidence might later confer jurisdiction.
Main Doctrine
Under Article 360 of the Revised Penal Code, as amended by Republic Act No. 4363, civil actions for damages arising from libelous publications against public officers must be filed in the Court of First Instance of the city or province where the offended functionary held office at the time of the offense, if the libelous article was printed and first published outside the Philippines. Furthermore, a court's refusal or deferment of a ruling on a motion to dismiss for lack of jurisdiction or improper venue constitutes an excess of jurisdiction, which is correctable by a writ of prohibition or certiorari.