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JUANITO MANZANO v. REDENTOR VALERA

FACTS:

Juanito Manzano, a Senior Police Officer 1, filed a petition for certiorari and prohibition with temporary restraining order against the respondent Judge of the Municipal Trial Court (MTC) in Bangued, Abra. Manzano seeks to enjoin the respondent Judge from further proceeding with Criminal Case No. 5728, a case for criminal libel, on the grounds of lack of jurisdiction. The criminal complaint for libel was filed by Vilma Bobila against Manzano, alleging that Manzano maliciously caused false and defamatory statements against Bobila to be entered in the Bangued Police Station Blotter. Initially, the respondent Judge recognized that the Regional Trial Court (RTC) had jurisdiction over the case and forwarded the records to the Office of the Provincial Prosecutor. However, the Prosecutor opined that the MTC should take cognizance of the case based on the amendment in the law. The Assistant Provincial Prosecutor supported the petitioner's argument that the RTC has exclusive original jurisdiction over libel cases. Despite this, the respondent Judge denied the Motion to Dismiss and subsequently denied the Motion for Reconsideration. The sole issue in this case is whether the RTC or the MTC has exclusive original jurisdiction over a complaint for libel.

ISSUES:

  1. Whether the municipal trial court has jurisdiction over a complaint for libel.

  2. Whether Republic Act 7691, which expanded the jurisdiction of the MTC, should be applied.

RULING:

  1. The municipal trial court has jurisdiction over a complaint for libel. Republic Act 7691, which expanded the jurisdiction of the MTC, should be applied. There is no express provision in any other law conferring exclusive original jurisdiction over libel cases to the regional trial court or any other court.

PRINCIPLES:

  • Municipal trial courts have jurisdiction over criminal cases where the penalty does not exceed six (6) years, unless such cases fall within the exclusive original jurisdiction of the regional trial court or the Sandiganbayan.

  • Republic Act 7691, as the later enactment, should be applied to determine the jurisdiction of the municipal trial court.

  • There is no law that expressly confers exclusive original jurisdiction over libel cases on the regional trial court or any other court.