Arambulo v. Laqui

SUPREME COURT REPORTS ANNOTATED VOLUME 342
740
2/10/15, 4:18 PM
SUPREME COURT REPORTS ANNOTATED

Arambulo vs. Laqui, Sr.
*
G.R. No. 138596. October 12, 2000.
SR. FIDELIS ARAMBULO, petitioner, vs. HON.

HILARION LAQUI, SR., HELEN OJARIO and SR.
BERNADINE JUAREZ, respondents.
Criminal Law; Prescription of Offenses; Preliminary
Investigations; The filing of the complaint with the Municipal Court,
even if it be merely for purposes of preliminary examination or
investigation, should, and does, interrupt the period of prescription
of the criminal responsibility, even if the court where the complaint
or information is filed can not try the case on its merits.In the
landmark case of People vs. Olarte, this Court speaking through
Justice J.B.L. Reyes, finally resolved the then conflicting views as
to whether or not the filing of a complaint with the Municipal Trial
Court for purposes of preliminary investigation suspends the
running of the prescriptive period for the crime. The Court restated
the correct and prevailing doctrine, as follows: In view of this
diversity of precedents, and in order to provide guidance for the
Bench and Bar, this Court has reexamined the question and, after
mature consideration, has arrived at the conclusion that the true
doctrine is, and should be, the one established by the decisions
holding that the filing of the complaint with the Municipal Court,
even if it be merely for purposes of preliminary examination or
investigation, should, and does, interrupt the period of prescription
of the criminal responsibility, even if the court where the complaint
or information is filed can not try the case on the merits. Several
reasons buttress this conclusion: first, the text of Article 91 of the
Revised Penal Code, in declaring that the period of prescription
shall be interrupted by the filing of the complaint or information
without distinguishing whether the complaint is filed in the court
for preliminary examination or investigation merely, or for action on
http://central.com.ph/sfsreader/session/0000014b72907842881717f8000a0082004500cc/p/AKT066/?username=Guest
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the merits. Second, even if the court where the complaint or

information is filed may only proceed to investigate the case, its
actuations already represent the initial step of the proceedings
against the offender. Third, it is unjust to deprive the injured party
the right to obtain vindication on account of delays that are not
under his control. All that the victim of the offense may do on his
part to initiate the prosecution is to file the requisite complaint.
Same; Jurisdiction; Libel; 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
_______________
*
THIRD DIVISION.
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Courts and Municipal Circuit Trial Courts.The error was
probably due to the confusion as to the proper venue for the crime of
libel brought about by the passage of R.A. 7691 which took effect on
April 15, 1994. Under Section 2 of the said Republic Act, the
jurisdiction of Metropolitan Trial Courts, Municipal Trial Courts
and Municipal Circuit Trial Courts was expanded to include all
offenses punishable with imprisonment not exceeding six (6) years.
However, libel, which is punishable by imprisonment ranging from
six months and one day to four years is not covered as the said law
excludes from its coverage cases within the exclusive jurisdiction of
the Regional Trial Courts. Under Article 360 of the Revised Penal
Code, the information for libel should be filed with the Court of
First Instance, now the Regional Trial Court. The confusion was
cleared up when this Court issued Administrative Order No. 104-96
dated October 21, 1996 which categorically stated that LIBEL
CASES SHALL BE TRIED BY THE REGIONAL TRIAL COURTS
HAVING JURISDICTION OVER THEM TO THE EXCLUSION OF
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THE METROPOLITAN TRIAL COURTS, MUNICIPAL TRIAL

COURTS IN CITIES, MUNICIPAL TRIAL COURTS AND
MUNICIPAL CIRCUIT TRIAL COURTS.
Same; Same; The mistake of the Office of the City Prosecutor in
the filing of the complaint with, and of the Metropolitan Trial Court
in taking cognizance of the case should not operate to prejudice the
interest of the state to prosecute criminal offenses and, more
importantly, the right of the offended party to obtain grievance.
Evidently, Branch 215 of the Metropolitan Trial Court of Quezon
City was not spared the confusion brought about by R.A. 7691, as
its dismissal of the case then pending before it was made only on
November 8, 1996 or more than two years after it had taken
cognizance of the case. Notably, the dismissal by the Metropolitan
Trial Court took place a mere eighteen (18) days after the issuance
of S.C. Administrative Order No. 104-96. The mistake of the Office
of the City Prosecutor in filing the complaint and of the
Metropolitan Trial Court in taking cognizance of the case was thus
understandable. The error was immediately rectified by the said
court upon realizing its mistake when it ruled it was the Regional
Trial Court which had the proper jurisdiction over the case. This
mistake should not operate to prejudice the interest of the state to
prosecute criminal offenses and, more importantly, the right of the
offended party to obtain grievance.
Same; Same; The doctrine in People v. Olarte, 19 SCRA 494
(1967), was not meant to apply solely to cases where the filing of the
complaint with the municipal trial court or the prosecutors office
operates to interrupt the prescription period for the prosecution of a
crime.Moreover, the doctrine in People vs. Olarte, as applied in
later cases, was not meant to apply
742
742

solely to cases where the filing of the complaint with the municipal
trial court or the prosecutors office operates to interrupt the
prescription period for the prosecution of a crime.
Right to a Speedy Trial; Well established is the doctrine that the
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right to a speedy trial is violated only where there is an

unreasonable, vexatious and oppressive delay without participation
or fault of the accused, or when unjustified postponements are
sought which prolong the trial for an unreasonable length of time.
Petitioners other argument that she has been denied her right to a
speedy trial deserves scant consideration. Well-established is the
doctrine that the right to a speedy trial is violated only where there
is an unreasonable, vexatious and oppressive delay without
participation or fault of the accused, or when unjustified
postponements are sought which prolong the trial for an
unreasonable length of time. In the case at bench, besides the filing
of the petitions before the Court of Appeals and this Court,
petitioner had likewise filed a Motion to Quash and a Motion for
Reconsideration with the Regional Trial Court of Quezon City,
Branch 218. As such, it is clear that petitioner is not without fault
in the delay in the prosecution of the case against her.
PETITION for review on certiorari of a decision of the

Court of Appeals.
The facts are stated in the opinion of the Court.
Bengzon, Narciso, Cudala, Jimenez, Gonzales and
Liwanag for petitioner.
Aristotle O. Liwag and Rene V. Sarmiento for private
respondents.
GONZAGA-REYES, J.:
Before us is a Petition for Review on Certiorari of the
1
2
Decision of the Court of Appeals in CA-G.R. SP No. 47089
promulgated on
_______________
1
2
Rollo, pp. 23-27.

Twelfth Division composed of the ponente, J. Portia Alio-
Hormachuelos; and the members, J. Buenaventura J. Guerrero and J.

Teodoro P. Regino, concurring.
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March 01, 1999 and the subsequent Resolution dated May

11, 1999 denying petitioners Motion for Reconsideration.
The facts of the case, as summarized by the appellate
court, are as follows:
On February 2, 1994, private respondents filed a joint
complaintaffidavit for libel against petitioners before the Office of
the City Prosecutor of Quezon City alleging that the latter
circulated on December 21, 1993 a letter containing malicious
imputations against them.
An information for libel then was filed before the Metropolitan
Trial Court of Quezon City on May 18, 1994.
After the prosecution presented its evidence, petitioner filed a
Demurrer to Evidence. Without resolving the incident, the
Metropolitan Trial Court in its Order dated November 9, 1996 ruled
that it had no jurisdiction over the case as the same falls under the
original and exclusive jurisdiction of the Regional Trial Court, and
ordered that the case be forwarded to the RTC for further
proceedings.
On November 29, 1996, the case was forwarded to Branch 215
Regional Trial Court of Quezon City docketed as Criminal Case No.
96-6870.
On January 3, 1997, petitioner filed a Motion to Dismiss on the
ground of lack of jurisdiction and prescription of the offense of Libel.
The RTC dismissed the case in an Order dated April 2, 1997 but,
stating that the offense had not yet prescribed, ordered the City
Prosecutor of Quezon City to re-file the Information for Libel with
the RTC.
On April 27, 1997, the Information for Libel was re-filed with
respondent court docketed as Criminal Case No. 0-97-70948.
On June 17, 1997, petitioner filed a Motion to Quash on the
ground of prescription. The motion was denied in the assailed
Resolution dated October 3, 1997.
Petitioners Motion for Reconsideration was also denied in the
4
other Assailed Order dated December 4, 1997.
Not satisfied with the Resolution and Order of the trial

court, herein petitioner appealed to the Court of Appeals
raising the issue of whether or not public respondent
committed grave abuse of discretion or grossly erred in
holding that the offense of libel in the
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_______________
3
Rollo, p. 28.
Rollo, pp. 23-24.

744
744

5
instant case has not yet prescribed. The Court of Appeals,

in its decision dated March 01, 1999, upheld the contention
of the trial court that the offense of libel had not yet
prescribed and consequently, dismissed the said petition.
The appellate court likewise denied herein petitioners
Motion
for Reconsideration in its Resolution dated May 11,
6
1999.
Petitioner is now before this Court seeking a reversal of
the decision of the Court of Appeals and contending that
I.
THE COURT OF APPEALS ERRED IN RULING THAT THE
CRIME OF LIBEL HAS NOT YET PRESCRIBED.
II.
THE COURT OF APPEALS ERRED IN RULING THAT
PETITIONER
HAS
NOT
BEEN
DENIED
HER
7
CONSTITUTIONAL RIGHT TO A SPEEDY TRIAL.
Under Article 90 of the Revised Penal Code, as amended,

the crime of libel prescribes in one (1) year, to wit:
ART. 90. Prescription of crime.Crimes punishable by death,
reclusion perpetua or reclusion temporal shall prescribe in twenty
years.
Crimes punishable by other afflictive penalties shall prescribe in
fifteen years.
Those punishable by a correctional penalty shall prescribe in 10
years; with the exception of those punishable by arresto mayor,
which shall prescribe in five years.
The crime of libel or other similar offenses shall prescribe in one
year. (italics supplied)
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The said prescriptive period is computed under Article 91

of the Revised Penal Code, as follows:
_______________
5
Rollo, p. 25.
Annex B of Petition; Rollo, 28.
Rollo, p. 14.
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745

Art. 91. Computation of prescription of offenses.The period of
prescription shall commence to run from the day on which the crime
is discovered by the offended party, the authorities, or their agents,
and shall be interrupted by the filing of the complaint or
information, and shall proceed to run again when such proceedings
terminate without the accused being convicted or acquitted, or are
unjustifiably stopped for any reason not imputable to him.
The term of prescription shall not run when the offender is
absent from the Philippine Archipelago.
In the case at bench, the offense of libel allegedly occurred

on December 21, 1993 when petitioner circulated a letter
containing allegedly malicious imputations against private
respondents Srs. Helen Ojario and Bernadine Juarez. At
this point, the period of prescription for the alleged crime
had already started to run.
The one-year period of prescription for the crime was
interrupted on February 2, 1994 when respondents filed a
8
joint complaint-affidavit for libel against petitioner before
the Office of the City Prosecutor in Quezon City. At this
point, the prescription period had already run for forty-two
(42) days.
A preliminary investigation by the Office of the City
Prosecutor was thus conducted. On April 27, 1994, Asst.
City Prosecutor Ma. Aurora Escasa-Ramos issued a
Resolution stating that probable cause exists against
petitioner and recommended the filing of an information for
9
libel against her. Consequently, an information for libel
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was filed against petitioner on May 18, 1994 before

the
10
Metropolitan Trial Court of Quezon City, Branch 32.
Despite the fact that the Metropolitan Trial Court had
no jurisdiction over the crime of libel, the said court
proceeded to conduct trial on the merits. After the
prosecution had rested, petitioner filed a Demurrer to
Evidence dated September 18, 1996. However, instead of
acting on the said demurrer, the Metropolitan
Trial Court,
11
on November 08, 1996, issued an Order ruling that it had
no jurisdiction over the crime of libel as the same falls
under the
______________
8
Annex C of Petition; Rollo, pp. 29-30.
Annex D of Petition; Rollo, pp. 34-35.
10
Docketed as Criminal Case No. 24213.
11
Annex T of Petition; Rollo, 36-38.

746
746

exclusive jurisdiction of the Regional Trial Court. Instead of

dismissing the case outright, the MTC ordered the
forwarding of the records of the case to the Regional Trial
Court for further proceedings. The case was eventually
raffled off to12 Branch 215 of the Regional Trial Court of
Quezon City.
13
On the basis of a Motion to Dismiss filed by petitioner,
Branch 215 of the Regional Trial Court dismissed the case
on April 2, 1997 on the ground of lack of jurisdiction as the
information against petitioner should have been re-filed
anew. The court ruled, however, that the crime had
not yet
14
prescribed and ordered the refiling of the case. On April
27, 1997, the Office of the City Prosecutor re-filed the case
with the Regional Trial Court and eventually
the same was
15
raffled to Branch 218 of the said court. Petitioner tried to
have this case dismissed
on the ground of prescription but
16
her motion to quash the information was denied by
Branch 218 of the Quezon City Regional Trial Court in a
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17
Resolution dated October 3, 1997. The denial by the

Regional Trial Court of petitioners motion to quash was
subsequently upheld by the Court of Appeals.
It is the contention of petitioner that the prescription
period for the crime of libel charged against her commenced
to run again when the Assistant City Prosecutor
recommended the filing of the information for libel.
Petitioner further argues that the prescriptive period could
have been interrupted again had the information been filed
with the Regional Trial Court, the court with the proper
jurisdiction to try the case for libel. Considering however
that the case was filed before the Metropolitan Trial Court,
which under the law does not have jurisdiction over the
crime of libel, the period of prescription continued to run its
course. Consequently, petitioner concludes that when the
information for libel was finally filed with the Regional
Trial Court, the crime had already prescribed and the State
can no longer pursue the case against her.
_______________
12
Docketed as Crim. Case No. 96-68701.
13
Annex G of Petition; Rollo, pp. 39-45.
14
Annex H of Petition; Rollo, pp. 46-47.
15
Now docketed as Criminal Case No. 97-70948.
16
Annex I of Petition; Rollo, pp. 48-54.
17
Annex J of Petition; Rollo, pp. 55-57.

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VOL. 342, OCTOBER 12, 2000
747

In support of her arguments, petitioner questions the
reliance made by the Regional Trial Court and the Court of
18
Appeals in the landmark case of People vs. Olarte.
Petitioner submits that the adherence to the Olarte case
must be examined considering that in the said case, the
principal issue was whether or not the filing of a complaint
in the Municipal Trial Court for purposes of preliminary
investigation, interrupts the period of prescription of a
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crime. Petitioner argues that the cited case is inapplicable

as it is not disputed in the case at bench that the period of
prescription was interrupted during the process of
preliminary investigation.
We are not persuaded.
In the landmark case of People vs. Olarte, this Court
speaking through Justice J.B.L. Reyes, finally resolved the
then conflicting views as to whether or not the filing of a
complaint with the Municipal Trial Court for purposes of
preliminary investigation suspends the running of the
prescriptive period for the crime. The Court restated the
correct and prevailing doctrine, as follows:
In view of this diversity of precedents, and in order to provide
guidance for the Bench and Bar, this Court has reexamined the
question and, after mature consideration, has arrived at the
conclusion that the true doctrine is, and should be, the one
established by the decisions holding that the filing of the complaint
with the Municipal Court, even if it be merely for purposes of
preliminary examination or investigation, should, and does,
interrupt the period of prescription of the criminal responsibility,
even if the court where the complaint or information is filed can not
try the case on the merits. Several reasons buttress this conclusion:
first, the text of Article 91 of the Revised Penal Code, in declaring
that the period of prescription shall be interrupted by the filing of
the complaint or information without distinguishing whether the
complaint is filed in the court for preliminary examination or
investigation merely, or for action on the merits. Second, even if the
court where the complaint or information is filed may only proceed
to investigate the case, its actuations already represent the initial
step of the proceedings against the offender. Third, it is unjust to
deprive the injured party the right to obtain vindication on account
of delays that are not under his control. All that the victim of the
offense may do on his part to initiate the prosecution is to file the
requisite complaint.
_______________
18
19 SCRA 494 (1967).

748
748
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And it is no argument that Article 91 also expresses that the
interrupted prescription shall commence to run again when such
proceedings terminate without the accused being convicted or
acquitted, thereby indicating that the court in which the complaint
or information is filed must have the power to convict or acquit the
accused. Precisely, the trial on the merits usually terminates in
conviction or acquittal, not otherwise. But it is in the court
conducting a preliminary investigation where the proceedings may
terminate without conviction or acquittal, if the court should
discharge the accused because no prima facie case had been shown.
Subsequently, this Court, in Francisco vs. Court of

19
Appeals, broadened the scope of Olarte by holding that
the filing of the complaint with the fiscals office also
suspends the running of the prescriptive period.
Petitioner insists that the ruling in Olarte with respect
to the interruption of the prescriptive period is not
applicable. In the case at bench, the fact that the period of
prescription was interrupted by the filing of private
respondents joint affidavit with the Quezon City
Prosecutors Office is not disputed. The Olarte case,
however, makes several other pronouncements that are
determinative of the issues raised by petitioner.
It is clear from the Olarte case that the filing of the
complaint or information for purposes of preliminary
investigation represents the initial step of the proceedings
against the offender. This is one of the reasons why such
filing is deemed as having interrupted the period of
prescription for the prosecution of a crime. This period of
prescription commences to run again when the proceedings
terminate without conviction or acquittal, if the court (or
prosecutor) should discharge the accused because no prima
20
facie case has been shown.
It is thus evident that petitioners first premise that the
period of prescription commenced to run again when the
Quezon City Prosecutors Office recommended the filing of
a criminal complaint against her is incorrect. When the
City Prosecutor recommended
_______________
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19
122 SCRA, 538 (1983).
20
People vs. Olarte, supra; also cited in David vs. Santos, 31 SCRA
788 (1970) and Francisco vs. Court of Appeals, 122 SCRA 538 (1983).
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VOL. 342, OCTOBER 12, 2000
749

the filing of libel charges against petitioner, the
proceedings against her were not terminated, precisely
because a prima facie case for libel was found against her.
Instead of terminating the proceedings against petitioner,
the resolution of the city prosecutor actually directed the
continuation of the proceedings against the petitioner by
the filing of the appropriate information against her and by
the holding of trial on the merits. As such, when the
information for libel was filed with the Metropolitan Trial
Court, the period of prescription for the crime was still
suspended.
Another important teaching in Olarte is that it is
unjust to deprive the injured party of the right to obtain
vindication on account of delays that are not under his
control. This is because in criminal prosecutions, the only
thing that the victim of the offense may do on his part to
initiate the prosecution is to file the requisite complaint.
In the case at bench, private respondents were not
remiss in their right to seek grievance against respondent
as they filed their complaint before the city prosecutor
forty-two days after the alleged crime of libel occurred. It
was the Office of the City Prosecutor that committed an
error when it filed the complaint with the Metropolitan
Trial Court.
The error was probably due to the confusion as to the
proper venue for the21 crime of libel brought about by the
passage of R.A. 7691 which took effect on April 15, 1994.
Under Section 2 of the said Republic Act, the jurisdiction of
Metropolitan Trial Courts, Municipal Trial Courts and
Municipal Circuit Trial Courts was expanded to include all
offenses punishable with imprisonment not exceeding six
(6) years. However, libel, which is punishable by
imprisonment ranging from six months and one day to four
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22
years is not covered as the said law excludes from its

coverage cases within the exclusive jurisdiction of the
23
Regional Trial Courts.
________________
21
An Act Expanding the Jurisdiction of the Metropolitan Trial Courts,
Municipal Trial Courts, and Municipal Circuit Trial Courts, Amending

for the Purpose Batas Pambansa Blg. 129, otherwise known as the
Judiciary Reorganization Act of 1980.
22
Article 360, Revised Penal Code.
23
R.A. 7691, Section 2.

750
750

Under Article 360 of the Revised Penal Code, the

information for libel should be filed with the Court of First
Instance, now the Regional Trial Court. The confusion was
cleared up when this Court issued Administrative Order
No. 104-96 dated October 21, 1996 which categorically
stated 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
24
MUNICIPAL CIRCUIT TRIAL COURTS.
Evidently, Branch 215 of the Metropolitan Trial Court of
Quezon City was not spared the confusion brought about by
R.A. 7691, as its dismissal of the case then pending before
it was made only on November 8, 1996 or more than two
years after it had taken cognizance of the case. Notably, the
dismissal by the Metropolitan Trial Court took place a
mere eighteen (18) days after the issuance of S.C.
Administrative Order No. 104-96.
The mistake of the Office of the City Prosecutor in filing
the complaint and of the Metropolitan Trial Court in taking
cognizance of the case was thus understandable. The error
was immediately rectified by the said court upon realizing
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its mistake when it ruled it was the Regional Trial Court

which had the proper jurisdiction over the case. This
mistake should not operate to prejudice the interest of the
state to prosecute criminal offenses and, more importantly,
the right of the offended party to obtain grievance.
Moreover, the doctrine in People vs. Olarte, as applied in
later cases, was not meant to apply solely to cases where
the filing of the complaint with the municipal trial court or
the prosecutors office operates to interrupt the prescription
period for the prosecution
of a crime.
25
In People vs. Galano, an information was filed with the
Batangas Regional Trial Court even though the evidence of
both the prosecution and defense shows that the crime was
committed in
________________
24
People vs. Metropolitan Trial Court of Quezon City, Branch 32, 265
SCRA 645 (1996).

25
75 SCRA 193 (1977).

751
VOL. 342, OCTOBER 12, 2000
751

Manila. This Court, applying People vs. Olarte, held that it
was only when the trial court dismissed the case due to
lack of jurisdiction that the proceedings therein
terminated without conviction and acquittal and it was
only then that the prescriptive period (which was
interrupted during the pendency of the case in the
Batangas Court) commenced
to run again.
26
In People vs. Enrile, informations were filed against
civilians before military tribunals which had no jurisdiction
over the persons of these civilians. These civilians
questioned the re-filing of the cases against them before
the civil courts raising, among others, that the crimes for
which they are being charged have already prescribed. This
Court, applying by analogy the ruling in the Olarte case,
threw out the defense of prescription and held that the
filing of the first indictments suspended the running of the
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prescriptive period, and the prosecutions under the

informations to be filed should be regarded as mere
continuations of the previous proceedings. At the very
least, the Court ruled the filing of the first charges should
be considered as having interrupted the prescriptive period
notwithstanding the lack of jurisdiction of the military
tribunal in which they were filed.
More recently, in the case of Reodica vs. Court of
27
Appeals, an information for reckless imprudence resulting
in damage to property with slight physical injuries was
filed with the Regional Trial Court even though the offense
was within the exclusive jurisdiction of the municipal trial
court. The Court, even as it dismissed the cases pending
before the Regional Trial Court for lack of jurisdiction,
disregarded the defense of prescription raised by the
accused. The Court, citing Olarte and the
subsequent cases
28
of Francisco
vs. Court of Appeals
and People vs.
29
Cuaresma ruled that the prescriptive period for the quasi
offenses in question was interrupted by the filing of the
complaint with the fiscals office three days after the
vehicular mishap and remained tolled pending the
termination of the case.
______________
26
160 SCRA 700 (1988).
27
292 SCRA 91 (1998).
28
122 SCRA 538 (1983).
29
172 SCRA 415 (1989).

752
752

From these cases, it is clear that the Appellate Court

committed no reversible error in ruling that the offense of
libel charged against petitioner had not yet prescribed. The
period of prescription for the crime was interrupted when
the complaint was lodged with the Office of the City
Prosecutor and remained tolled pending the termination of
the case against petitioner. Branch 218 of the Regional
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Trial Court of Quezon City, therefore, correctly assumed

jurisdiction over the case of petitioner as the offense of libel
for which she was being charged has not yet prescribed.
Petitioners other argument that she has been denied
her right to a speedy trial deserves scant consideration.
Well-established is the doctrine that the right to a speedy
trial is violated only where there is an unreasonable,
vexatious and oppressive delay without participation or
fault of the accused, or when unjustified postponements are
sought which prolong the trial for an unreasonable length
30
of time. In the case at bench, besides the filing of the
petitions before the Court of Appeals and this Court,
petitioner had likewise filed a Motion to Quash and a
Motion for Reconsideration with the Regional Trial Court of
Quezon City, Branch 218. As such, it is clear that petitioner
is not without fault in the delay in the prosecution of the
case against her.
Wherefore, the petition is hereby DENIED, and the
decision of the Court of Appeals dated May 1, 1999 is
hereby AFFIRMED.
SO ORDERED.
Melo (Chairman), Vitug, Panganiban and Purisima,
JJ., concur.
Petition denied, judgment affirmed.
Notes.The filing by a dismissed employee of a
criminal action for libel during the pendency of the illegal
dismissal case does not constitute forum-shopping.
(Equitable Banking Corporation vs. National Labor
Relations Commission, 273 SCRA 352 [1997])
R.A. No. 7691 can by no means be considered another
special law on jurisdiction but merely an amendatory law
intended to
_______________
30
Guerrero vs. Court of Appeals, 257 SCRA 703 (1996).

753
VOL. 342, OCTOBER 12, 2000

753
Page 16 of 17
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Santos vs. Santos

amend specific sections of the Judiciary Reorganization Act
of 1980in a manner of speaking, R.A. No. 7691 was
absorbed by the mother law, the Judiciary Reorganization
Act of 1980. (Morales vs. Court of Appeals, 283 SCRA 211
[1997])
A later enactment like RA 7691 does not automatically
override an existing law, because it is a well-settled
principle of construction that, in case of conflict between a
general law and a special law, the latter must prevail
regardless of the dates of their enactmentjurisdiction
conferred by a special law on the RTC must therefore
prevail over that granted by a general law on the MTC.
(Manzano vs. Valera, 292 SCRA 66 [1998])
o0o
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Arambulo v. Laqui

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SUPREME COURT REPORTS ANNOTATED VOLUME 342

SUPREME COURT REPORTS ANNOTATED

G.R. No. 138596. October 12, 2000.

SR. FIDELIS ARAMBULO, petitioner, vs. HON.

SUPREME COURT REPORTS ANNOTATED VOLUME 342

the merits. Second, even if the court where the complaint or

VOL. 342, OCTOBER 12, 2000

Arambulo vs. Laqui, Sr.

SUPREME COURT REPORTS ANNOTATED VOLUME 342

THE METROPOLITAN TRIAL COURTS, MUNICIPAL TRIAL

SUPREME COURT REPORTS ANNOTATED

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right to a speedy trial is violated only where there is an

PETITION for review on certiorari of a decision of the

Rollo, pp. 23-27.

Hormachuelos; and the members, J. Buenaventura J. Guerrero and J.

VOL. 342, OCTOBER 12, 2000

Arambulo vs. Laqui, Sr.

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March 01, 1999 and the subsequent Resolution dated May

Not satisfied with the Resolution and Order of the trial

SUPREME COURT REPORTS ANNOTATED VOLUME 342

Rollo, pp. 23-24.

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instant case has not yet prescribed. The Court of Appeals,

Under Article 90 of the Revised Penal Code, as amended,

SUPREME COURT REPORTS ANNOTATED VOLUME 342

The said prescriptive period is computed under Article 91

Annex B of Petition; Rollo, 28.

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Arambulo vs. Laqui, Sr.

In the case at bench, the offense of libel allegedly occurred

SUPREME COURT REPORTS ANNOTATED VOLUME 342

was filed against petitioner on May 18, 1994 before

Annex C of Petition; Rollo, pp. 29-30.

Annex D of Petition; Rollo, pp. 34-35.

Docketed as Criminal Case No. 24213.

Annex T of Petition; Rollo, 36-38.

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exclusive jurisdiction of the Regional Trial Court. Instead of

SUPREME COURT REPORTS ANNOTATED VOLUME 342

Resolution dated October 3, 1997. The denial by the

Docketed as Crim. Case No. 96-68701.

Annex G of Petition; Rollo, pp. 39-45.

Annex H of Petition; Rollo, pp. 46-47.

Now docketed as Criminal Case No. 97-70948.

Annex I of Petition; Rollo, pp. 48-54.

Annex J of Petition; Rollo, pp. 55-57.

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Arambulo vs. Laqui, Sr.

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crime. Petitioner argues that the cited case is inapplicable

19 SCRA 494 (1967).

SUPREME COURT REPORTS ANNOTATED

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Arambulo vs. Laqui, Sr.

Subsequently, this Court, in Francisco vs. Court of

SUPREME COURT REPORTS ANNOTATED VOLUME 342

122 SCRA, 538 (1983).

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Arambulo vs. Laqui, Sr.

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years is not covered as the said law excludes from its

An Act Expanding the Jurisdiction of the Metropolitan Trial Courts,