- Petitioner
- Wonina M. Bonifacio
- Respondent
- Regional Trial Court of Makati
- Citation
- G.R. No. 184800
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Carpio Morales, J.
- Decided
- May 5, 2010
Whether the Amended Information for libel sufficiently establishes jurisdiction and venue requirements under Article 360 of the Revised Penal Code
Summary
This Supreme Court case arose from a petition for certiorari and prohibition challenging RTC orders that denied motions to quash an amended information for libel. The underlying criminal case involved 13 counts of libel filed against officers and trustees of PEPCI who posted allegedly defamatory articles about the Yuchengco Family and Malayan Insurance on their websites. The central legal issue was whether the amended information satisfied the venue requirements under Article 360 of the Revised Penal Code, as amended by RA 4363. The Supreme Court granted the petition, holding that mere internet access in Makati does not constitute 'printing and first publication' as required for venue purposes. The Court emphasized that allowing such interpretation would enable the very harassment and forum shopping that the amendment sought to prevent. The decision clarifies the strict venue requirements for libel cases involving internet publications and reinforces the jurisdictional nature of venue in criminal proceedings.
Intellegal Wiki · Key Holding
In libel, venue is jurisdictional; Article 360 of the Revised Penal Code requires a specific allegation of where the material was printed and first published, and a mere allegation that it was accessed online in a place does not satisfy that jurisdictional requirement.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.