People v. Hechanova
REITERATIONFacts
The Antecedents: Atty. Felipe C. Navarro filed a libel charge against Rufino G. Hechanova, Joaquin P. Roces, Jose Luna Castro, and Mario Macaranas. The charge stemmed from a letter written by Hechanova to the Department of Finance concerning Navarro's alleged offer of P200,000 for the Liberal Party in exchange for his appointment as Customs Attache, and a related news item in the Manila Times. Navarro had previously filed a similar charge with the Quezon City Fiscal's Office, which was dismissed for lack of a prima facie case after a preliminary investigation. Procedural History: Dissatisfied with the fiscal's dismissal, Navarro refiled the libel charge directly with the Court of First Instance (CFI) of Rizal, Quezon City Branch. The CFI, exercising its discretion, referred the complaint to the City Fiscal for preliminary examination. The City Fiscal recommended dismissal, noting it was the same complaint previously dismissed. Consequently, the CFI dismissed the case. The Petition: Atty. Navarro appealed the CFI's dismissal order, arguing that the CFI had the authority to conduct a preliminary investigation on a libel charge directly filed with it, citing Article 360 of the Revised Penal Code and Section 13, Rule 112 of the New Rules of Court.
Issue(s)
Whether the Court of First Instance of Rizal, Quezon City Branch, has the power to conduct a preliminary investigation on a charge of libel directly filed by the offended party. Whether Section 13, Rule 112 of the New Rules of Court applies to chartered cities whose charters exclusively vest the power to conduct preliminary investigations in the city fiscal.
Ruling
The appeal is dismissed, and the order of dismissal by the Court of First Instance is sustained.
Ratio Decidendi
On the issue of the Court of First Instance's power to conduct a preliminary investigation on a libel charge directly filed: The Court held that Article 360 of the Revised Penal Code does not grant Courts of First Instance the power to conduct preliminary investigations for libel; it mandates that such investigations be conducted by the provincial or city fiscal. Furthermore, Section 13, Rule 112 of the New Rules of Court explicitly states that a judge of the Court of First Instance may conduct a preliminary examination and investigation only on complaints filed directly with the court "without previous preliminary examination and investigation conducted by the fiscals." This implies that if a preliminary investigation has already been conducted by the fiscal, the court cannot entertain a direct filing for the same purpose. The Court emphasized that the appellant failed to disclose that a preliminary investigation had already been conducted by the Quezon City Fiscal. On the applicability of Section 13, Rule 112 to chartered cities: The Court clarified that Section 13, Rule 112 of the New Rules of Court has no application to chartered cities like Quezon City, whose respective charters authorize only the city fiscal to conduct preliminary investigations. The Revised Charter of Quezon City, specifically Section 28(g) and (h), lodges the charge of prosecuting crimes and investigating charges with the City Attorney (who is equivalent to the City Fiscal in this context). This provision grants the City Fiscal of Quezon City the exclusive power to conduct preliminary investigations, similar to the powers granted to the fiscals of Manila and Bacolod City in their respective charters. The Court cited Sayo v. Chief of Police and Montelibano v. Ferrer to support the principle that in chartered cities, criminal complaints must be filed with the city fiscal, who then conducts the investigation and files the information with the proper court if warranted. Therefore, the direct filing of the libel complaint with the Court of First Instance was irregular and improper.
Main Doctrine
A Court of First Instance in a chartered city cannot entertain a complaint for libel filed directly with it if the city charter exclusively vests the power to conduct preliminary investigations in the city fiscal.