People vs. Benipayo
Facts:
Photo Photoki kina na Marke Marketin ting g Inc. Inc. filed filed an affi affidav davit it compl complain aintt for libel libel again against st resp respond onden entt Beni Benipa pay yo, COME COMELE LEC C Chai Chairm rman an,, for for alle allege gedl dly y bein being g the the one one all allde ded d to by the the respondent in his speech at !P "iliman #hich #as pblished in Manila Blletin isses. $aid speech is as follo#s : “Now, they are at it again, trying to hoodwink us into contract that is so grossly disadvantageous to the government that it offends common sense to say that it would be worth the 6.5 billion-peso price tag. %rging that he&s an impeachable impeachable officer, officer, respondent 'estioned the (risdiction (risdiction of the Office of the Prosector of )C. City prosec. $till filed an information for libel against him. *espondent, for his part, moved for the dismissal of the case on the assertion that the trial cort had no (risdiction over his person for he #as an impeachable officer and ths, cold not be criminally prosected before any cort dring his incmbency+ and that, assming he can be criminally prosected, it #as the Office of the Ombdsman that shold investigate him and the case shold be filed #ith the $andiganbayan. rial cort dismissed the case for lack of (risdiction considering that the alleged libel #as committed by respondent in relation to his office #hen he delivered speech in his official capacity as COMELEC Chair. %ccordingly, it #as the $andiganbayan that had (risdiction (risdiction over the case case to the e-clsion e-clsion of all other other corts. corts. On motion for reconsideration, the trial cort adhered to its rling that it #as not vested #ith (risdiction to hear the libel case. ISSUE:
hether the respondent committed the crime of libel in relation to his office and that the trial cort is correct in saying that it has no (risdiction over the case/ HELD:
Criminal and civil actions for damages in cases of #ritten defamations shall be filed siml simltan taneo eos sly ly or sepa separat rately ely #ith #ith the the *C *C to the the e-cl e-clsio sion n of all all other other corts corts.. % sbse'ent enactment of a la# defining the (risdiction of other corts cannot simply override, in the absence of an e-press repeal or modification, the specific provision in
the *PC vesting in the *C, as aforesaid, (risdiction over defamations in #riting or by similar means. 0 he grant to the $andiganbayan 1 of (risdiction over offenses committed in relation to 2pblic3 office, similar to the e-pansion of the (risdiction of the MCs, did not divest the *C of its e-clsive and original (risdiction to try #ritten defamation cases regardless of #hether the offense is committed in relation to office. he broad and general phraseology of $ection 4, Presidential "ecree 5o. 0676, as amended by *epblic %ct 5o. 8149, : cannot be constred to have impliedly repealed, or even simply modified, sch e-clsive and original (risdiction of the *C. $ince (risdiction over #ritten defamations e-clsively rests in the *C #ithot 'alification, it is nnecessary and ftile for the parties to arge on #hether the crime is committed in relation to office. hs, the conclsion reached by the trial cort that the respondent committed the alleged libelos acts in relation to his office as former COMELEC chair, and deprives it of (risdiction to try the case, is, follo#ing the above dis'isition, gross error. his Cort, therefore, orders the reinstatement of Criminal Cases 5os. );71;079476 and );71;07947< and their remand to the respective *egional rial Corts for frther proceedings. =aving said that, the Cort finds nnecessary any frther discssion of the other isses raised in the petitions.
1
2
3