Ortiz v. Cajucom
REITERATIONFacts
The Antecedents: A complaint for libel was filed by private respondent Benedicto S. Cajucom against petitioner Ramil P. Ortiz. The complaint indicated a postal address in Sta. Mesa, Manila. Based on this, the Office of the City Prosecutor of Manila filed an Information for libel with the Regional Trial Court (RTC) of Manila. Petitioner sought a reinvestigation, after which an Amended Information was filed, detailing the alleged libelous letter written and circulated by petitioner, intended to impeach the virtue, honor, character, and reputation of Cajucom. Procedural History: Petitioner filed a Motion to Quash with the RTC, arguing that the court lacked jurisdiction because Article 360 of the Revised Penal Code requires libel cases against private individuals to be filed in the province or city where the libelous article was first published or where the offended party actually resided. Petitioner contended that Cajucom's complaint only provided a postal address, not an actual residence, in Manila. He also submitted evidence suggesting Cajucom's actual residence was in Antipolo City. The RTC denied the motion to quash, ruling that a person can have multiple residences and that the case was properly filed in Manila. Petitioner's motion for reconsideration was also denied. He then elevated the matter to the Court of Appeals (CA) via a petition for certiorari, which was dismissed for being the improper remedy; the CA stated that the proper recourse was to proceed to trial and then appeal. The CA subsequently denied petitioner's motion for reconsideration. The Petition: Petitioner filed the present petition for certiorari and/or prohibition with the Supreme Court, seeking to nullify the CA's resolutions. He argues that the CA committed grave abuse of discretion by disregarding his evidence and arguments, specifically that Cajucom did not state Sta. Mesa, Manila as his actual residence but merely a postal address, that evidence showed Cajucom's actual residence was in Antipolo City, and that the CA itself noted the Sta. Mesa address was his parents' residence, not his. Petitioner contends that the CA should have considered that the intention of Article 360 is to exclude domicile as a venue for libel complaints. The Supreme Court, however, found the petition dismissible, stating that certiorari is for errors of jurisdiction, not errors of judgment, and that the issues raised by petitioner concerned the correctness of the CA's legal conclusions. Furthermore, the Court noted that the Amended Information sufficiently alleged Cajucom's residence in Manila, thereby vesting jurisdiction in the RTC of Manila, and that the proper remedy for petitioner would have been a petition for review on certiorari under Rule 45.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion amounting to lack of jurisdiction in dismissing petitioner's petition for certiorari. Whether the Regional Trial Court of Manila had jurisdiction over the Information for libel given the offended party's stated postal address. Whether certiorari under Rule 65 was a proper remedy given the existence of other plain, speedy, and adequate remedies, including a petition for review under Rule 45. Whether an allegation in the information that the offended party was "then residing at this City [Manila]" suffices to vest jurisdiction in the RTC of Manila under Article 360 of the Revised Penal Code.
Ruling
The petition for certiorari and/or prohibition is DISMISSED for lack of merit. The Resolutions of the Court of Appeals dated June 25, 2002 and February 17, 2003 are sustained. No temporary restraining order or preliminary injunction is warranted.
Ratio Decidendi
On Whether the CA committed grave abuse of discretion: The Court reiterated that the special civil action for certiorari is limited to correction of errors of jurisdiction and not errors of judgment, citing the principle explained in People v. Court of Appeals and Land Bank of the Philippines v. Court of Appeals. The petition showed that petitioner was primarily attacking the correctness and legal soundness of the CA's conclusions rather than jurisdictional defects; such errors are beyond the scope of certiorari. The CA's Resolutions were found to have addressed the essential arguments raised by petitioner, and in the absence of credible proof to the contrary the CA is presumed to have performed its official duty. Thus, petitioner failed to establish the grave abuse of discretion necessary to sustain certiorari relief. The petition was therefore dismissed on this procedural ground. On Whether the RTC had jurisdiction given the offended party's postal address: The Court applied the rule that jurisdiction in criminal cases for libel is determined by the allegations in the complaint or information. Applying Macasaet v. People, the Court noted that the complaint or information must allege whether the offended party was a private individual and where he was actually residing at the time of the offense. The Amended Information here expressly alleged that the offended party was "then residing at this City [Manila]," which the Court held to be sufficient to vest jurisdiction in the RTC of Manila. The Court further observed that a person may have two or more residences and that the presence of a postal address does not negate a claim of residence when the information so alleges. Given these principles, the Court concluded that the allegation in the Information satisfied Article 360's requirement and that the RTC of Manila had jurisdiction. On Whether certiorari was the proper remedy given available remedies: The Court emphasized that Rule 65 of the 1997 Rules of Civil Procedure requires the absence of any other plain, speedy, and adequate remedy and that here petitioner had adequate remedy by way of a petition for review on certiorari under Rule 45. The CA correctly held that the proper remedy to assail the correctness of the RTC's order was to proceed to trial and appeal, or to file the appropriate petition under Rule 45. Because an adequate remedy existed, certiorari under Rule 65 was not available. The Court therefore dismissed the petition on this independent ground. On Whether the allegation in the information that the offended party was "then residing at this City [Manila]" suffices: The Court reasoned that jurisdiction is determined by the allegations in the information and that the Amended Information's clear allegation regarding the offended party's residence in Manila complied with the requirement articulated in Macasaet v. People. The Court noted that the CA discussed whether the postal address constituted actual residence and concluded that the CA considered the arguments and evidence; absent credible proof rebutting the presumption that the CA took the matters into account, the Supreme Court will not disturb that conclusion. Therefore, the allegation in the Information was sufficient to vest jurisdiction in the RTC of Manila.
Main Doctrine
The special civil action for certiorari under Rule 65 is limited to correction of errors of jurisdiction and not errors of judgment; jurisdiction in a criminal action for libel is determined by the allegations in the complaint or information regarding the offended party's residence.