Petition for certiorari challenging RTC orders denying motion to quash in cyberlibel case under RA 10175
Summary
The Supreme Court dismissed Wilbert Tolentino's petition for certiorari challenging Regional Trial Court orders that denied his motion to quash a cyberlibel information under RA 10175. The case arose from Tolentino's 2015 Facebook post, for which Eva Rose Pua filed a complaint in 2017. The SC ruled the petition was procedurally defective for failing to state the receipt date of the assailed order and for not showing grave abuse of discretion. Substantively, the SC clarified that cyberlibel under RA 10175 now carries an afflictive penalty prescribing in 15 years, making the complaint timely. The Court also affirmed that RTC Quezon City had proper jurisdiction since the complainant resided there. The constitutional requirement for clearly stated facts and law was held inapplicable to interlocutory orders like motion to quash denials.
Focus of dispute
Petition for certiorari challenging RTC orders denying motion to quash in cyberlibel case under RA 10175
Legal facts
Wilbert Tolentino made a Facebook post on April 29, 2015. Eva Rose Pua filed a cyberlibel complaint against him on August 8, 2017 under RA 10175 (Cybercrime Prevention Act). Criminal Case No. R-QZN-17-14518-CR was filed in RTC Branch 90, Quezon City. Tolentino filed a motion to quash which was denied by RTC on March 19, 2018 and June 18, 2018. He then filed a petition for certiorari before the Supreme Court challenging these orders.
Judgement and reasoning
{"Regional Trial Court, Branch 90, Quezon City": "Denied petitioner's motion to quash the criminal information in Criminal Case No. R-QZN-17-14518-CR through Orders dated March 19, 2018 and June 18, 2018", "Supreme Court (SC)": "DISMISSED the petition for certiorari for: (1) failure to state date of receipt of assailed March 19, 2018 Order as required by Sec. 3, Rule 46 of Rules of Court; (2) failure to show grave abuse of discretion. SC ruled that constitutional requirement for clearly stated facts and law does not apply to interlocutory orders like motion to quash denial. On prescription, cyberlibel under RA 10175 carries afflictive penalty making it prescribe in 15 years, so 2017 complaint against 2015 Facebook post was timely. On jurisdiction, RTC of Quezon City has proper jurisdiction under Section 21 of RA 10175 since complainant Eva Rose Pua resides there. AFFIRMED the RTC Orders dated March 19, 2018 and June 18, 2018."}