001 DIGESTED People vs. Benipayo - G.R. No. 154473

TOGUAY, Paul Jeffrey U.
2019-80129
Block 4
Citation G.R. No. 154473
Date April 24, 2009
Petitioner PEOPLE OF THE PHILIPPINES and PHOTLINA MKTG CORP
Respondent ALFREDO BENIPAYO (FORMER COMELEC CHAIRMAN)
PRINCIPLES/ 1. For, although RA 7691 was enacted to decongest the clogged dockets of the
DOCTRINES Regional Trail Courts by expanding the jurisdiction of first level courts, said law is
of a general character. Even if it is a later enactment, it does not alter the provision
of Article 360 of the RPC, a law of a special nature. "Laws vesting jurisdiction
exclusively with a particular court, are special in character, and should prevail over
the Judiciary Act defining the jurisdiction of other courts (such as the Court of
First Instance) which is a general law." A later enactment like RA 7691 does not
automatically
override an existing law, because it is a well-settled principle of construction that,
in case of conflict between a general law and a special law, the latter must prevail
regardless of the dates of their enactment. Jurisdiction conferred by a special law
on the RTC must therefore prevail over that granted by a general law on the MTC.
FACTS:
In January 2002 and March 2002, Respondent Benipayo then COMELEC CHAIRMAN delivered
a speech in UP DILIMAN which was published in Manila Bulletin and was invited in a television
interview respectively. During the said speech and interview, the respondent said that the contract
with the petitioner PHOTOLINA MKTG CORP was disadvantageous to the government because a 6-
Billion contract could have been just a 350M worth. He said also during the speech that the ID solution
was not even a requirement for voting. In the interview, the petitioner accused the respondent of
maliciously using its PR fund of COMELEC against the respondent. Consequently, petitioner filed
complaint-affidavits for LIBEL to the Office of the City Prosecutor of Quezon City (OCP-QC) who
immediately filed the information to braches 102 and 101 of the Regional Trial Court despite the
challenge made by the respondent that he was an “impeachable officer” and that his case should be
heard by the Sandiganbayan as his action was “related to his office.”
The petitioner filed a motion for inhibition of the judge of branch 102 who according to the
petitioner was recommended to the Judiciary by the father-in-law of the respondent. Subsequently, the
said court dismissed the case for lack of jurisdiction and rendered the motion for inhibition moot and
academic.
Branch 101 of the RTC of Quezon City rendered its decision as well dismissing the case for lack
of jurisdiction.
The petitioner brought the cases to the Supreme Court separately where the Court consolidated
the cases.
ISSUE:
1. Whether the Sandiganbayan or the Regional Trial Court should handle LIBEL cases even if the
accused was a government official or in this case an impeachable officer.
RULING:
1. It is the REGIONAL TRIAL COURTS who have the original jurisdiction to try cases of LIBEL
regardless the accused is a government official.
Article 360 of the Revised Penal Code states that “The criminal and civil action for damages in cases of
written defamations as provided for in this chapter, shall be filed simultaneously or separately with the
court of first instance [now, the Regional Trial Court] of the province or city where the libelous article
is printed and first published or where any of the offended parties actually resides at the time of the
commission of the offense xxx.
"Laws vesting jurisdiction exclusively with a particular court, are special in character, and should
prevail over the Judiciary Act defining the jurisdiction of other courts (such as the Court of First
Instance) which is a general law."
In the case at bar, the respondent, though a government official, should be tried before the REGIONAL
TRIAL COURT, not in the Sandiganbayan as the law is CATEGORICAL and CLEAR. “Its language is
categorical; its meaning is free from doubt. This is one of those statutory provisions that leave no room
for interpretation. All that is required is application. What the law ordains must then be followed.”
Therefore, the Regional Trial Courts of Quezon City erred in its ruling that they did not have
jurisdiction over libel cases involving government officials such as the respondent. Since the said
courts do not have concurrent jurisdiction to try the offense, it would be pointless to still determine
whether the crime is committed in relation to office. the provisions of R.A. 7691, there seems to be no
manifest intent to repeal or alter the jurisdiction in libel cases. If there was such intent, then the
amending law should have clearly so indicated because implied repeals are not favored.
The Supreme Court En Banc granted the petitions and ordered the Regional Trial Court of Quezon
City to proceed with the case.

001 DIGESTED People vs. Benipayo - G.R. No. 154473

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001 DIGESTED People vs. Benipayo - G.R. No. 154473

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TOGUAY, Paul Jeffrey U.

Citation G.R. No. 154473

Date April 24, 2009

Petitioner PEOPLE OF THE PHILIPPINES and PHOTLINA MKTG CORP

Respondent ALFREDO BENIPAYO (FORMER COMELEC CHAIRMAN)

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