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ARMAND NOCUM v. LUCIO TAN

FACTS:

Lucio Tan, the respondent in this case, filed a complaint against Filipino business daily INQUIRER and its columnist Rene Nocon (NOCUM) for damages arising from libel. The complaint alleged that the defendants published defamatory statements about Tan in an article and a caricature.

INQUIRER and NOCUM, as well as the defendants Captain Florendo Umali and the Airline Pilots Association of the Philippines (ALPAP), filed their respective joint answers denying the allegations in the complaint. They argued that the complaint failed to state a cause of action, that the statements in question were general conclusions without factual premises, and that the publication was privileged as it concerned a public figure. They also claimed that malice was negated by the inclusion of PAL's side of the dispute in the same article.

The Regional Trial Court of Makati dismissed the complaint without prejudice on the ground of improper venue. The court found that the complaint failed to state the residence of the complainant at the time of the alleged offense and the place where the libelous article was printed and first published.

Respondent Lucio Tan filed an Omnibus Motion seeking reconsideration of the dismissal and admission of the amended complaint. The amended complaint stated that the article and caricature were printed and first published in the City of Makati.

The lower court admitted the amended complaint and set aside the previous order of dismissal. It concluded that the mistake or deficiency in the original complaint was cured by the amended complaint, which was merely a formal amendment and did not affect the defendants' defenses.

Petitioners, along with defendants Umali and ALPAP, appealed the RTC decision to the Court of Appeals. The Court of Appeals denied the petitions and affirmed the lower court's order. Motions for reconsideration were denied, and both parties appealed to the Supreme Court.

The Supreme Court gave due course to the petition and required the parties to submit their memoranda. Petitioners argued that the lower court did not have jurisdiction over the case based on the original complaint's deficiencies in conferring jurisdiction. The question to be resolved is whether the lower court acquired jurisdiction over the civil case upon the filing of the original complaint for damages. The Supreme Court ruled in the affirmative, stating that jurisdiction is conferred based on the facts alleged in the complaint. From the allegations in the original complaint, the RTC acquired jurisdiction over the case. Article 360 of the Revised Penal Code vests jurisdiction over all civil and criminal complaints for libel in the RTC of the place where the libelous article was printed and first published, where the complainant, if a private person, resides, or where the complainant, if a public official, holds office.

ISSUES:

  1. Whether the lower court acquired jurisdiction over the civil case upon the filing of the original complaint for damages.

  2. Whether the amended complaint was properly allowed or admitted.

RULING:

  1. The lower court acquired jurisdiction over the civil case upon the filing of the original complaint for damages. It is settled that jurisdiction is conferred by law based on the facts alleged in the complaint since the latter comprises a concise statement of the ultimate facts constituting the plaintiff's causes of action. In this case, the original complaint alleges a cause of action for damages arising from libel, which falls within the jurisdiction of the RTC.

  2. The amended complaint was properly allowed or admitted. The lower court, after having dismissed the case for improper venue, admitted the amended complaint and deemed set aside the previous order of dismissal. The amendment in the amended complaint is merely formal and does not affect the defendants' defenses and their answers. The amendment cured the mistake or deficiency in the original complaint, and the admission of the amended complaint is in accordance with Rule 10 of the 1997 Rules of Civil Procedure.

PRINCIPLES:

  • Jurisdiction is conferred by law based on the facts alleged in the complaint. The court acquires jurisdiction over a civil case when it is filed before it and the allegations in the complaint establish a cause of action within its jurisdiction.

  • Amendments to the complaint may be allowed if they are merely formal and do not affect the defendants' defenses. The admission of an amended complaint may be allowed to cure any mistakes or deficiencies in the original complaint, provided it does not substantially affect the defendants' defenses and their answers.