- Petitioner
- Causing
- Respondent
- People
- Citation
- G.R. No. 258524
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Inting, J.
- Decided
- 2023-10-11
Cyberlibel prescribes in one year from discovery
Summary
This Supreme Court case involves petitioner Causing challenging cyber libel charges filed by Rep. Hernandez over Facebook posts accusing him of stealing Marawi relief funds. The core issue was the prescriptive period for cyber libel. The RTC denied Causing's Motion to Quash, applying either 12-year or 15-year prescription periods. The Supreme Court denied the petition but significantly clarified that cyber libel is not a new crime but merely libel committed through computer systems, prescribing in one year from discovery under Article 90 of the RPC. The Court abandoned the Tolentino doctrine that applied 15-year prescription, holding that the specific provision on libel prescription (one year) prevails over general provisions on afflictive penalties. However, the Court affirmed the RTC's denial because prescription requires factual determination with evidence, which was not established in the motion to quash.