Facts:
The consolidated petitions revolve around charges of libel filed against Hilarion M. Henares, Jr. (“Henares”) due to his defamatory remarks against the Tieng brothers (William Tieng, Wilson Tieng, and Willy Tieng) on his radio and television programs titled “Make My Day with Larry Henares.” The cases under scrutiny evolved through various legal proceedings across different forums, from the Regional Trial Courts (RTCs) of Parañaque and Makati Cities to the Court of Appeals, eventually reaching the Supreme Court. At the heart of the dispute is the application of Articles 355 and 360 of the Revised Penal Code (RPC), particularly how these articles’ provisions on written defamation apply to libelous statements aired on radio and television.
Issues:
1. Whether the rules of venue and jurisdiction under Article 360 of the RPC extend to defamation through radio and television broadcasts.
2. Whether dismissal of Civil Case No. 02-359 by the RTC of Makati, Branch 62, accorded with Article 360 of the RPC.
3. Whether the venue for the civil action stipulated in Article 360 of the RPC is also jurisdictional.
Court’s Decision:
The Supreme Court decided that charges of defamation arising from radio and television broadcasts fall within the ambit of Article 360 of the RPC, thus subject to its provisions on venue and jurisdiction. The Court clarified that just as written defamations have specific venues where actions can be instituted, so do defamatory statements made through radio and television broadcasts. Consequently, for the criminal or civil actions to be properly instituted, they must be filed in the court where the broadcasting station is located or where the offended party resides at the time of the offense.
Doctrine:
This case is groundbreaking in establishing that Article 360’s provisions on venue and jurisdiction not only pertain to written defamations but also extend to libelous utterances conveyed through radio and television. It clarifies the process for instituting defamation charges emanating from such broadcasts, thereby broadening the scope of Article 360 of the RPC.
Class Notes:
– Article 360 of the RPC applies to libel through written forms, radio, and television broadcasts.
– For charges of defamation via radio and television to be properly filed, the Information must specifically allege the location of the radio or television station or the residence of the offended party at the time the defamatory statement was made.
– Venue and jurisdiction in libel cases are determined based on where the broadcast station is located or where the offended party resides, expanding the traditional understanding of Article 360.
Historical Background:
This decision marks a significant development in Philippine libel law, contextualized within a modern setting where media consumption transcends traditional print media. The inclusion of radio and television broadcasts under the provision of Article 360 of the RPC underscores the law’s adaptability to evolving forms of communication and its commitment to safeguarding individuals’ reputations against defamatory attacks, irrespective of the medium used.
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