Arambulo v. Laqui
REITERATIONFacts
The Antecedents: Private respondents filed a joint complaint-affidavit for libel against petitioner on February 2, 1994, alleging that petitioner circulated a letter containing malicious imputations on December 21, 1993. An information for libel was subsequently filed. Procedural History: The case was initially filed before the Metropolitan Trial Court (MTC), which, after the prosecution presented its evidence, ruled it lacked jurisdiction and ordered the case forwarded to the Regional Trial Court (RTC). The RTC dismissed the case due to lack of jurisdiction but ordered the re-filing of the information, stating the offense had not prescribed. The information was re-filed with the RTC, and petitioner's motion to quash on grounds of prescription was denied. This denial was upheld by the Court of Appeals, which also denied petitioner's motion for reconsideration. The Petition: Petitioner seeks a review on certiorari of the Court of Appeals' decision, arguing that the crime of libel had prescribed and that she was denied her constitutional right to a speedy trial. Petitioner contends that the filing of the information with the MTC, which lacked jurisdiction, did not interrupt the prescriptive period, and that the period continued to run until the information was properly filed with the RTC.
Issue(s)
Whether the Court of Appeals erred in ruling that the crime of libel has not yet prescribed. Whether the Court of Appeals erred in ruling that petitioner has not been denied her constitutional right to a speedy trial.
Ruling
The petition is DENIED, and the decision of the Court of Appeals dated May 1, 1999, is AFFIRMED.
Ratio Decidendi
On the issue of prescription of the crime of libel: The Court reiterated the doctrine established in People vs. Olarte, which holds that the filing of a complaint or information with a court, even if it lacks jurisdiction to try the case on the merits, interrupts the period of prescription. This is because such filing constitutes the initial step in the prosecution of the offender. The prescriptive period commences to run again only when such proceedings terminate without the accused being convicted or acquitted, or are unjustifiably stopped for reasons not imputable to the accused. The Court clarified that the filing of the complaint-affidavit with the City Prosecutor's Office on February 2, 1994, interrupted the one-year prescriptive period for libel, which had commenced on December 21, 1993. The subsequent filing of the information with the Metropolitan Trial Court (MTC), despite its lack of jurisdiction, did not allow the prescriptive period to resume running. The MTC's eventual dismissal of the case due to lack of jurisdiction was a termination of proceedings without conviction or acquittal, but the period did not resume running because the RTC subsequently ordered the re-filing of the case, which was considered a continuation of the original proceedings. The Court emphasized that it would be unjust to deprive the injured party of vindication due to delays not under their control, especially when they have taken the necessary steps to initiate prosecution. The confusion regarding jurisdiction was attributed to the passage of R.A. 7691 and was clarified by this Court's Administrative Order No. 104-96, which mandated that libel cases be tried by the RTCs. The Court cited People vs. Galano, People vs. Enrile, and Reodica vs. Court of Appeals to support the principle that filing in a court without jurisdiction interrupts prescription and that subsequent proceedings in the proper court are continuations of the original ones. On the issue of denial of the right to a speedy trial: The Court found this argument to be without merit. The right to a speedy trial is violated only when there is an unreasonable, vexatious, and oppressive delay without the participation or fault of the accused, or when unjustified postponements prolong the trial. In this case, the petitioner herself contributed to the delay by filing a Motion to Quash and a Motion for Reconsideration with the Regional Trial Court, in addition to the petitions filed before the Court of Appeals and the Supreme Court. Therefore, the petitioner cannot claim denial of her right to a speedy trial as she was not without fault in the delays encountered.
Main Doctrine
The filing of a complaint or information, even with a court that lacks jurisdiction, interrupts the prescriptive period for the crime, as it represents the initial step in the prosecution and prevents the period from running anew until such proceedings terminate without conviction or acquittal. The subsequent re-filing of the case in the proper court is considered a continuation of the original proceedings.