Tulfo v. People
REITERATIONFacts
The Antecedents: This case originated from two Informations filed on January 28, 2013, charging petitioners with Libel under Article 353 of the Revised Penal Code. The charges stemmed from news broadcasts aired by ABS-CBN on July 22 and 23, 2004, concerning the arrival of Angelo dela Cruz, an overseas contract worker. The broadcasts, featuring statements by Erwin Tulfo and Lynda Jumilla, alleged that GMA-7 had stolen or pirated exclusive video footage of dela Cruz's arrival, which ABS-CBN had covered. These imputations were alleged to have been made publicly and maliciously, intending to expose GMA-7 and its personnel to public ridicule, dishonor, discredit, and contempt. Procedural History: A criminal complaint for Libel was initially filed by GMA-7 personnel on July 27, 2004. After nearly a decade, on February 6, 2013, two Informations were filed before the Regional Trial Court (RTC) of Quezon City. The RTC found probable cause and issued warrants of arrest, which the petitioners subsequently posted bail for. Petitioners filed a motion for reconsideration of the judicial determination of probable cause, a motion to suspend proceedings, a motion to recall warrants of arrest, and an ad cautelam motion to quash the Informations. The RTC denied these motions on April 16, 2013, finding the Informations sufficient in form and substance and stating that issues of truth and malice were matters of defense for trial. A subsequent motion to disqualify was also denied on June 11, 2013. Aggrieved, petitioners filed a Petition for Certiorari with the Court of Appeals (CA), alleging grave abuse of discretion by the RTC. The Petition: The Court of Appeals dismissed the Petition for Certiorari, affirming the RTC's Orders. The CA ruled that certiorari was an improper remedy to assail the denial of a motion to quash, as petitioners had a plain, speedy, and adequate remedy in the ordinary course of law by proceeding to trial and appealing any adverse judgment. The CA also found the Informations sufficient in form and substance, stating that the elements of libel, including identifiability and malice, were adequately alleged and that any defenses could be raised during trial. Furthermore, the CA held that even if GMA-7 admitted unauthorized use of footage, the imputation of libel was presumed malicious, and the truth or falsity of the statements were matters for trial. Petitioners now seek review of the CA's Decision via a Petition for Review on Certiorari under Rule 45 of the Rules of Court, raising issues regarding the propriety of certiorari, the sufficiency of the Informations, and the alleged grave abuse of discretion by the RTC.
Issue(s)
Whether the Court of Appeals (CA) erred in ruling that a petition for certiorari is improper. Whether the CA erred in ruling that the Informations are sufficient in form and substance. Whether the CA erred in upholding the trial court's alleged grave abuse of discretion. Whether the CA erred in upholding the validity of the Informations despite the private respondents' alleged admissions of unauthorized use of the footage.
Ruling
The petition is denied. The Decision of the Court of Appeals is affirmed in toto.
Ratio Decidendi
On the propriety of Certiorari: The Court held that the CA correctly ruled that a petition for certiorari under Rule 65 is generally improper to assail the denial of a motion to quash an information. Such denial is an interlocutory order, and the plain and speedy remedy is to proceed to trial. The accused can raise the denial as an error on appeal if an unfavorable judgment is rendered. A petition for certiorari is an exception, allowed only if the denial was tainted with grave abuse of discretion, which requires a showing of capricious, whimsical, or despotic exercise of judgment amounting to an evasion of duty. The petitioners failed to demonstrate such grave abuse of discretion. On the sufficiency of the Informations: The Court found that the CA correctly upheld the sufficiency of the Informations in form and substance. The Informations stated the names of the accused, the designation of the offense (Libel), the acts or omissions constituting the offense, the names of the offended parties, the approximate date and place of commission. The allegations sufficiently established the elements of libel: (a) a discreditable act or condition concerning another, (b) publication of the charge, (c) identity of the person defamed, and (d) existence of malice. The Court noted that the specific wording does not need to be a verbatim reproduction of the law, and the essential elements were present. On the alleged grave abuse of discretion: The Court reiterated that the RTC did not commit grave abuse of discretion in denying the motion to quash. The RTC's evaluation that the Informations were prima facie complete, sufficient in form and substance, and compliant with procedural rules was a valid exercise of its discretion. The petitioners' arguments regarding the absence of identifiability and malice were matters of defense to be threshed out during trial, not grounds for quashing the Information at that stage. On GMA-7's alleged admissions: The Court found no merit in the petitioners' claim that the CA erred in upholding the validity of the Informations despite alleged admissions by GMA-7. The imputation of stealing video footage and broadcasting it on national television is presumed malicious under Article 354 of the Revised Penal Code, unless good intention and justifiable motive are shown. Whether the statements were malicious, made in good faith, or constituted a news report were issues to be determined during the trial proper, not grounds for quashing the Informations.
Main Doctrine
The denial of a motion to quash an information is an interlocutory order and is generally not appealable. The proper remedy is to proceed to trial and, if convicted, to raise the denial as an error on appeal. A petition for certiorari is only proper if the denial was tainted with grave abuse of discretion amounting to lack or excess of jurisdiction.