People v. Olarte

PEOPLE v.
OLARTE
June 30, 1960 | Concepcion, J. | Legislative History – Explanatory Note
PETITIONER: People of the Philippines, et al.
RESPONDENT: Asceencion Olarte
SUMMARY: Miss Meris received a series of defamatory letters from Olarte on Feb 27, 1954. On Feb 22 1956, she filed a complaint before
the justice of the peace, ad the same was forwarded with the Information, in the CFI, on July 3, 1956. (notice that sa justice of peace,
within 2 yrs pa. sa CFI, sobra na sa 2 yrs). Since the crime has prescribed, the libel case was dismissed by CFI. Hence, this appeal.
SC held that, after consulting the legislative history of Libel (RPC, various legislative enactments, etc), it can be seen in the explanatory
note of the said act that the court being pertained to can likewise be contemplated as that of the justice of the peace. Having said this, SC
held that Meris accordingly filed within the period allowed, hence the crime of libel has not extinguished. SC then remanded the case
back to the lower court for further proceedings in accordance with law.
DOCTRINE: An explanatory note of a particular bill passed in Congress may also show the intent of the legislature in drafting the said
law. This can later on be consulted in terms of the true meaning of the law, since it is likewise part of the legislative history of the law in
question.
FACTS:
1. Miss Meris received a defamatory letter on Feburary 27, 1954 from Olarte.
2. She then lodged a complaint for libel against Olarte for writing letters which were libelous and deregatory, with purpose of
insulting and bringing contempt to her good name and reputation.
3. She filed with the Justice of the Peace Court on February 22, 1956, which forwarded it to the CFI where the information was
filed on July 3, 1956
4. CFI dismissed the case and ruled in favor of Olarte, on the basis of the crime having prescribed. Hence, this appeal.
ISSUE/s:
1. WoN the crime of libel has expired – NO
RULING: SC remanded the case to the lower court for further proceedings.
RATIO:
1. According to Art. 90, RPC, crime of libel shall prescribe in 2 years, which commences from the day the crime is discovered by
the offended party, and shall beinterrupted by the filing of the complaint or information.
2. In construing Art. 91 of the RPC, SC held in People v. Tayco that the complaint or information referred to in Art. 91 is that
which is filed in the proper court and not the denuncia or accusation lodged by the offended party in the City Fiscal’s office.
That, the proper court for this purpose is not the justice of the peace court but the CFI, which is expressly provided in Art. 360
fo the RPC “x x x criminal cation x x x may be filed x x x with the CFI x x x “
3. June 15, 1955, it was amended by RA 1289. But, prior to the RPC, libel was governed by Act No. 277, which also states that the
same must be filed before the CFI.
4. It is seen that the framers of Art. 360 of the RPC intended to introduce no substantial change in the existing law, except as
regards venue, and that, in all other aspects, they meant to preserve and continue the status quo under Act No. 277.
5. RA 1289 Explanatory note states: “Article 360 of the Revised Penal Code which permits the offended party to file as many civil
and criminal complaints for libel in as many places as the writing complained of has been circulated, has been abused so as to
harass and indirectly muzzle newspapers, their editors and reporters. The spectre of having to defend themselves at great
expense in time and money in many courts far away from their place of publication , has often caused many a newspaper to adopt
a less courageous and militant attitude and to temporize too long before exposing fraud, corruptions and other venalities in all
nooks and corners of our country.
It is for the purpose of remedying this anomalous procedural situation which undoubtedly lessens the effectiveness of our free
press to ferret out the evil and the wrong in our nation that this accompanying measure is presented. If passed, it would limit
the venue of both civil and criminal complaints for libel to the province or municipality where any of the accused or any of the
offended party resides.”
6. SC ultimately held that the filing of the complaint with the justice of the peace interrupted the running of the statute of
limitations as regards the crime of libel. Hence, the crime has not extinguished by prescription.

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