Libel cases under the exclusive jurisdiction of the RTC

This Court has already had occasion to resolve the issue, substantially in line with the position taken by the People, account having been taken of substantially the same arguments adduced by the opposing parties in this case. In G.R. No. 122126 entitled Lydia Caro vs. Court of Appeals and Violeta Sarigumba, involving the same jurisdiction issue as that specifically presented in the case at bar, this Court promulgated a Resolution on June 19, 1996 pertinently reading as follows: "Anent the question of jurisdiction, we ** find no reversible error committed by public respondent Court of Appeals in denying petitioner's motion to dismiss for lack of jurisdiction. The contention ** that R.A. No. 7691 divested the Regional Trial Courts of jurisdiction to try libel cases cannot be sustained. While libel is punishable by imprisonment of six months and one day to four years and two months (Art. 360 Revised Penal Code) which imposable penalty is lodged within the Municipal Trial Courts' jurisdiction under R.A. No. 7691 (Sec. 32 [2]), said law, however, excludes therefrom' ** cases falling within the exclusive original jurisdiction of the Regional Trial Courts **.' The Court in Bocobo vs. Estanislao, 72 SCRA 520 and Jalandoni vs. Endaya, 55 SCRA 261, correctly cited by the Court of Appeals, has laid down the rule that Regional Trial Courts have the exclusive jurisdiction over libel cases, hence, the expanded jurisdiction conferred by R.A. 7691 to inferior courts cannot be applied to libel cases." Moreover, Administrative Order No. 104-96 - treating of the subject: "** DESIGNATION OF SPECIAL COURTS FOR KIDNAPPING, ROBBERY, CARNAPPING, DANGEROUS DRUGS CASES AND OTHER HEINOUS CRIMES; INTELLECTUAL PROPERTY RIGHTS VIOLATIONS AND JURISDICTION IN LIBEL CASES" - issued on October 21, 1996 by the Chief Justice upon the advice and consent of the Court En banc, inter alia, provides, in categorical acknowledgment of the validity of the doctrine just adverted to, that "LIBEL CASES SHALL BE TRIED BY THE REGIONAL TRIAL COURTS HAVING JURISDICTION OVER THEM TO THE EXCLUSION OF THE METROPOLITAN TRIAL COURTS, MUNICIPAL TRIAL COURTS IN CITIES, MUNICIPAL TRIAL COURTS AND MUNICIPAL CIRCUIT TRIAL COURTS." [G.R. No. 123263. December 16, 1996]

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