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People v.

Piccio (2014): Jessie Gimenez, President of the The CA correctly dismissed the notice of appeal interposed by
Philippine Integrated Advertising Agency — the advertising arm of petitioners against the RTC’s order because they, being mere private
the Yuchengco Group of Companies, to which Malayan Insurance complainants, lacked the legal personality to appeal the dismissal of
Company, Inc. is a corporate member — filed a Complaint-Affidavit the criminal case (i.e. quashal of the information on the ground of lack
for libel before the City Prosecutor of Makati City against a group of jurisdiction). It is well-settled that the authority to represent the
called the Parents Enabling Parents Coalition, Inc. (PEPCI) for State in appeals of criminal cases before the Court and the CA is
posting an online article entitled "Back to the Trenches: A Call to vested solely in the OSG which is the law office of the
Arms, AY/HELEN Chose the War Dance with Coalition" which the Government. It’s specific powers and functions include that of
Yuchengco Family found to be defamatory and libelous. The City representing the Republic and/or the people before any court in any
Prosecutor found probable cause and filed the case with RTC action which affects the welfare of the people as justice may require.
Makati. However, the Information was quashed for lack of The foregoing is expressed in Section 35 (1), Chapter 12, Title III,
jurisdiction. Respondents averred that it failed to allege where the Book IV of the 1987 Administrative Code. Jurisprudence further
article was first printed and published or where the offended parties provides that if there is a dismissal of a criminal case by the trial court
reside which is needed in libel charges. Petitioners appealed the or if there is an acquittal of the accused, it is only the OSG that may
decision to the CA while the OSG sought the DOJ’s endorsement on bring an appeal on the criminal aspect representing the People. The
whether it is the People or the private complainant that should file the private complainant may, however, file an appeal without the
same. Although the respondents opposed this appeal for not having intervention of the OSG but only insofar as the civil liability of
the conforme of the OSG, petitioners claim that the latter is not the accused is concerned. He may also file a special civil action for
required when grave errors are committed by the trial court or where certiorari even without the intervention of the OSG, but only to the end
there is lack of due process. The CA dismissed the appeal, leading of preserving his interest in the civil aspect of the case.
to the case at bar.

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