People v. Marquez
REITERATIONFacts
The Antecedents: On March 11, 1937, the chief of police of Barbaza, Antique, filed an amended complaint charging Aniceto Marquez with serious slander by deeds. The justice of the peace conducted a preliminary investigation and forwarded the case to the Court of First Instance. The provincial fiscal filed an information alleging that the accused, on or about March 10, 1937, in Barbaza, Antique, publicly uttered injurious and insulting words, calling Presentacion Ellaga, a young school teacher, "bigatot" and "patotot" (prostitute), and simultaneously slapped her twice, causing her to fall and sustain injuries requiring medical attention and taking three days to heal, to her dishonor, discredit, and contempt. Procedural History: The defendant filed a demurrer to the information, arguing that the court lacked jurisdiction because the complaint was initiated by the chief of police, not the offended party. The trial judge sustained the demurrer and dismissed the case. The Petition: The People of the Philippines appealed the dismissal order.
Issue(s)
Whether the Court of First Instance had jurisdiction over the criminal case for serious slander by deeds despite the lack of a complaint filed personally by the offended party.
Ruling
The Supreme Court reversed the order of dismissal and remanded the case to the lower court for further proceedings. The Court held that the offense charged, 'injurias graves con lesiones' under Article 359 of the Revised Penal Code, does not fall under the specific provision of Article 360, paragraph 4, which pertains to defamation involving the imputation of crimes not prosecutable de oficio and requires the offended party to file the complaint. Therefore, the jurisdictional challenge was unfounded.
Ratio Decidendi
On Issue 1: The Supreme Court held that the trial court erred in dismissing the case for lack of jurisdiction. The Court clarified that Article 360, paragraph 4 of the Revised Penal Code, which prohibits criminal actions for defamation unless filed by the offended party, is specifically limited to defamation consisting of the imputation of a crime that cannot be prosecuted de oficio. The crimes that cannot be prosecuted de oficio are strictly those listed in Article 344, which include adultery, concubinage, seduction, abduction, rape, and acts of lasciviousness. In this instance, the information charged the defendant with injurias graves con lesiones (serious slander by deeds) under Article 359, which is not one of the crimes requiring a private complaint for its prosecution. The Court emphasized that when the words of a statute are plain and clear, there is no room for construction, and the law must be followed as written. Therefore, because the defamation did not impute a private crime, the Chief of Police and the Provincial Fiscal were authorized to initiate the action de oficio. Consequently, the trial court possessed jurisdiction to hear the case, and the dismissal was improper.
Main Doctrine
A criminal action for 'injurias graves con lesiones' under Article 359 of the Revised Penal Code does not require a complaint expressly filed by the offended party, unlike defamation involving imputation of crimes not prosecutable de oficio under Article 360.