In Urmaza v. Rojas, the Supreme Court addressed the proper procedure for appealing decisions in defamation cases within the National Prosecution Service (NPS). The Court upheld the dismissal of Meriam Urmaza’s petition, clarifying that when a complaint for Oral Defamation or Intriguing Against Honor is filed outside the National Capital Region (NCR) and falls under the jurisdiction of Municipal Trial Courts, the Regional Prosecutor’s ruling is final. This decision underscores the importance of adhering to procedural rules in legal challenges and clarifies the hierarchy of appeals within the NPS system, streamlining the process for resolving such disputes.

From Barangay Hall to Courtroom: Did a Word of Mouth Warrant Legal Action?

The case arose from a criminal complaint filed by Meriam Urmaza against Ramon Torres Domingo, accusing him of Intriguing Against Honor and/or Oral Defamation. Urmaza alleged that Domingo spread rumors about her being a thief, specifically in connection to a missing handgun. The dispute originated from a confrontation at the barangay level, where Domingo voiced his suspicions about Urmaza’s involvement in the theft. According to Urmaza, Domingo continued to defame her by shouting accusations whenever he passed by her house. Domingo denied these allegations, stating that he only expressed his suspicion during the barangay confrontation and later reported the incident to the police.

The Office of the Provincial Prosecutor (OPP) initially dismissed Urmaza’s complaint due to insufficient evidence. Urmaza filed a motion for reconsideration nearly two years later, claiming she never received the initial resolution. This motion was also denied, leading her to appeal to the Office of the Regional Prosecution (ORP). Initially, the ORP dismissed the appeal on procedural grounds but later addressed the merits, affirming the OPP’s dismissal due to a lack of credible corroborating evidence. Urmaza then took the matter to the Court of Appeals (CA) via a petition for certiorari, which was dismissed for being the wrong remedy. The CA pointed out that Urmaza should have filed a petition for review before the Department of Justice (DOJ) instead.

The Supreme Court then addressed the procedural correctness of Urmaza’s actions. The Court emphasized that the appeals process within the NPS is governed by DOJ Department Circular No. 70, also known as the “2000 NPS Rule on Appeal.” This circular generally requires resolutions of the ORP to be appealed via a verified petition for review before the Secretary of Justice (SOJ). However, Department Circular No. 70-A modified this procedure, delegating authority to the ORPs to rule with finality on cases subject to preliminary investigation/reinvestigation, provided that the case is not filed in the NCR and is cognizable by the Metropolitan Trial Courts (MeTCs), Municipal Trial Courts (MTCs), and Municipal Circuit Trial Courts (MCTCs).

In order to expedite the disposition of appealed cases governed by Department Circular No. 70 dated July 3, 2000 (“2000 NPS RULE ON APPEAL”), all petitions for review of resolutions of Provincial/City Prosecutors in cases cognizable by the Metropolitan Trial Courts, Municipal Trial Courts and Municipal Circuit Trial Courts, except in the National Capital Region,shall be filed with the Regional State Prosecutor concerned who shall resolve such petitions with finality in accordance with the pertinent rules prescribed in the said Department Circular.

Department Circular No. 018-14 further solidified this delegation of authority. This circular reinforces that appeals from resolutions of Provincial or City Prosecutors, except those from the National Capital Region, in cases cognizable by the Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts, shall be by way of a petition for review to the concerned Regional Prosecutor. The Regional Prosecutor’s resolution is deemed final, although the Secretary of Justice retains the power to review, modify, or reverse these resolutions.

The Supreme Court then laid out clear guidelines for the appeals process, distinguishing between cases filed within and outside the NCR, and those cognizable by MTCs/MeTCs/MCTCs. If a complaint is filed outside the NCR and is cognizable by the MTCs/MeTCs/MCTCs, the ruling of the OPP may be appealed by way of petition for review before the ORP, which ruling shall be with finality. If the complaint is filed outside the NCR and is not cognizable by the MTCs/MeTCs/MCTCs, the ruling of the OPP may be appealed by way of petition for review before the SOJ, which ruling shall be with finality.

The Court also noted a critical procedural lapse by Urmaza. Section 3, Rule 46 of the Rules of Court requires petitions for certiorari to indicate the material dates showing when the judgment or final order was received, when a motion for new trial or reconsideration was filed, and when notice of the denial thereof was received. Urmaza failed to provide these dates, making it impossible for the CA to determine if the petition was filed within the 60-day reglementary period.

Section 3.  Contents and filing of petition; effect of non-compliance with requirements.   – x x x

In actions filed under Rule 65, the petition shall further indicate the material dates showing when notice of the judgment or final order or resolution subject thereof was received, when a motion for new trial or reconsideration, if any, was filed and when notice of the denial thereof was received.

Even if the procedural issues were set aside, the Court proceeded to examine the merits of Urmaza’s claims. The Court reiterated that a public prosecutor’s determination of probable cause is an executive function generally beyond judicial scrutiny, except when tainted with grave abuse of discretion. Grave abuse of discretion transcends mere judgmental error and pertains to a capricious or whimsical exercise of judgment equivalent to lack of jurisdiction.

The elements of Oral Defamation include: (1) an imputation of a crime, vice, or defect; (2) made orally; (3) publicly; (4) maliciously; (5) directed to a natural or juridical person; and (6) tending to cause dishonor, discredit, or contempt. Meanwhile, Intriguing Against Honor penalizes creating intrigue with the principal purpose of blemishing a person’s honor or reputation. In this case, the OPP and ORP found insufficient evidence to indict Domingo for either crime. The ORP emphasized that a prosecution for oral defamation requires the utterance to be not only defamatory but also made publicly. There was a lack of corroborating evidence to support Urmaza’s claims that Domingo publicly called her a “thief.” Therefore, the Court found no grave abuse of discretion in the prosecutor’s determination.

FAQs

What was the key issue in this case?	The key issue was whether the Court of Appeals correctly dismissed the certiorari petition outright due to improper remedy, specifically regarding the appeals process within the National Prosecution Service for defamation cases.
What is the correct procedure for appealing decisions in defamation cases outside the NCR?	If the case falls under the jurisdiction of the Municipal Trial Courts, the Regional Prosecutor’s ruling is final. If it does not, the appeal should be directed to the Secretary of Justice.
What did the Court say about the evidence presented by Urmaza?	The Court agreed with the lower courts that there was insufficient evidence to prove that Domingo publicly defamed Urmaza. The court pointed to the lack of corroborating witnesses to prove the utterances was made publicly.
What is the significance of Department Circular No. 70-A?	Department Circular No. 70-A delegates to the Regional State Prosecutors the authority to rule with finality on certain appealed cases. This delegation aims to expedite the disposition of cases by streamlining the appeals process.
What information must be included in a petition for certiorari?	The petition must indicate the material dates showing when notice of the judgment or final order was received, when a motion for new trial or reconsideration was filed, and when notice of the denial thereof was received.
What are the elements of Oral Defamation under Philippine law?	The elements include an imputation of a crime, vice, or defect; made orally; publicly; maliciously; directed to a person; and tending to cause dishonor, discredit, or contempt.
What is the definition of Intriguing Against Honor?	Intriguing Against Honor is defined as any intrigue which has for its principal purpose to blemish the honor or reputation of a person.
Can a public prosecutor’s determination of probable cause be reviewed by the courts?	Yes, a public prosecutor’s determination can be reviewed if it is tainted with grave abuse of discretion. This ensures that the prosecutor acts within the bounds of their authority.

The Supreme Court’s decision in Urmaza v. Rojas provides clarity on the appeals process for defamation cases within the NPS, emphasizing the importance of procedural compliance and the need for sufficient evidence to support claims of defamation. It also underscores the limited scope of judicial review over a prosecutor’s determination of probable cause. Understanding these principles is crucial for both complainants and respondents in defamation cases.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Urmaza v. Rojas, G.R. No. 240012, January 22, 2020