Macasaet v. People
REITERATIONFacts
The Antecedents: Petitioners Allen A. Macasaet, Nicolas V. Quijano, Jr., and Alfie Lorenzo, along with Roger Parajes and Jordan Castillo, were charged with libel in an Information dated July 10, 1997, for an article published in the newspaper "Abante" on July 13, 1996. The article allegedly exposed Joselito Magallanes Trinidad (a.k.a. Joey Trinidad, a.k.a. Toto Trinidad) to public hatred, dishonor, discredit, and contempt. Procedural History: Petitioners filed an Urgent Motion to Suspend Arraignment, intending to elevate the prosecutor's resolution to the Department of Justice (DOJ). Despite this, their arraignment proceeded, and a plea of not guilty was entered for them. They later filed a Motion to Dismiss, arguing the Regional Trial Court (RTC) of Quezon City lacked jurisdiction because the offended party's residence was in Marikina City, as stated in the Information, contrary to Article 360 of the Revised Penal Code. The RTC initially dismissed the case for lack of jurisdiction, citing the article's publication in Manila and the respondent's address in Marikina, despite a handwritten notation on the Information indicating a Quezon City address. The RTC denied the private respondent's motion for reconsideration, deeming a subsequently submitted affidavit from the alleged lessor as curative evidence. The Court of Appeals (CA) reversed the RTC's dismissal, remanding the case for further proceedings, holding that the defect was cured by a supplemental affidavit during the preliminary investigation and that the barangay certifications lacked probative value. The CA also gave weight to the lessor's affidavit. The CA denied petitioners' motion for reconsideration. The Petition: Petitioners seek review of the CA's decision, raising issues of territorial jurisdiction, the admissibility of the lessor's affidavit, and the private respondent's personality to appeal a criminal case.
Issue(s)
Whether the Regional Trial Court of Quezon City has territorial jurisdiction over the crime of libel. Whether the affidavit of Cristina B. Del Rosario was admissible. Whether the private respondent had the personality to appeal the criminal case.
Ruling
The petition is granted. The Decision and Resolution of the Court of Appeals are reversed and set aside, and the Decision of the Regional Trial Court dismissing the case is reinstated.
Ratio Decidendi
On the issue of territorial jurisdiction: The Court held that jurisdiction in criminal cases, particularly venue in libel, is determined by the allegations in the Information. Article 360 of the Revised Penal Code requires that the Information allege either that the libelous article was printed and first published in the province or city, or that the offended party actually resided there at the time of the offense. The original Information in this case failed to make such allegations, stating only "Quezon City" perfunctorily without specifying the basis for jurisdiction. The Court reiterated that a supplemental affidavit submitted during the preliminary investigation cannot cure a fatally defective Information regarding jurisdiction, as the resolution of a motion to dismiss based on lack of jurisdiction is generally limited to the allegations in the Information itself, unless exceptions apply. The Court found that the RTC correctly dismissed the case for lack of jurisdiction because the Information was insufficient on its face to vest jurisdiction in the RTC of Quezon City. The Court emphasized that the venue for libel cases is strictly defined, allowing suits either where the article was printed and first published or where the private individual offended party actually resided. On the admissibility of the affidavit of Cristina B. Del Rosario: The Court found the Court of Appeals' reliance on the affidavit of Cristina B. Del Rosario to be without merit. The Court noted that the affidavit was executed on January 19, 1998, long after the proceedings had advanced, and was attached to a supplemental motion for reconsideration. The Court characterized it as "curative evidence" whose weight and sufficiency were highly suspect. Furthermore, the Court pointed out that supplemental pleadings, under Rule 10, Section 6 of the Rules of Court, are meant to set forth transactions or events that have happened after the pleading sought to be supplemented, and their admission is discretionary. The affidavit did not present new matters that occurred after the original motion for reconsideration and was submitted without explanation for its belated submission. The Court concluded that the private respondent failed to overcome his lethargy in presenting this evidence earlier. On the personality of the private prosecutor to appeal: The Court affirmed that while the Office of the Solicitor General (OSG) is the sole representative of the government in appellate courts for criminal cases, its authority begins only when the case reaches the appellate courts. The trial court retains jurisdiction until the perfection of appeals by all parties. Therefore, the filing of a notice of appeal by the private prosecutor and the public prosecutor before the trial court was proper, as the trial court's jurisdiction had not yet ceased. The Court clarified that the private complainant has an interest in the civil aspect of a dismissed criminal case and can appeal that aspect. In this case, the appeal was treated as pertaining to the civil aspect, given that the dismissal was based on jurisdiction, not the merits of the criminal case.
Main Doctrine
The jurisdiction of a court over a criminal case is determined by the allegations in the complaint or information. Amendments to cure defects in jurisdiction, particularly regarding venue in libel cases, must be made in accordance with the Rules of Court, and the admission of supplemental pleadings is discretionary. A belatedly submitted affidavit, especially one that appears to be curative in nature, may be given little weight.