Arambulo v. Laqui

2/10/15, 4:18 PMSUPREME COURT REPORTS ANNOTATED VOLUME 342

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740 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; PreliminaryInvestigations; The filing of the complaint with the Municipal Court,even if it be merely for purposes of preliminary examination orinvestigation, should, and does, interrupt the period of prescriptionof the criminal responsibility, even if the court where the complaintor information is filed can not try the case on its merits.In thelandmark case of People vs. Olarte, this Court speaking throughJustice J.B.L. Reyes, finally resolved the then conflicting views asto whether or not the filing of a complaint with the Municipal TrialCourt for purposes of preliminary investigation suspends therunning of the prescriptive period for the crime. The Court restatedthe correct and prevailing doctrine, as follows: In view of thisdiversity of precedents, and in order to provide guidance for theBench and Bar, this Court has reexamined the question and, aftermature consideration, has arrived at the conclusion that the truedoctrine is, and should be, the one established by the decisionsholding that the filing of the complaint with the Municipal Court,even if it be merely for purposes of preliminary examination orinvestigation, should, and does, interrupt the period of prescriptionof the criminal responsibility, even if the court where the complaintor information is filed can not try the case on the merits. Severalreasons buttress this conclusion: first, the text of Article 91 of theRevised Penal Code, in declaring that the period of prescriptionshall be interrupted by the filing of the complaint or informationwithout distinguishing whether the complaint is filed in the courtfor preliminary examination or investigation merely, or for action on



the merits. Second, even if the court where the complaint orinformation is filed may only proceed to investigate the case, itsactuations already represent the initial step of the proceedingsagainst the offender. Third, it is unjust to deprive the injured partythe right to obtain vindication on account of delays that are notunder his control. All that the victim of the offense may do on hispart to initiate the prosecution is to file the requisite complaint.

Same; Jurisdiction; Libel; Libel cases shall be. tried by theRegional Trial Courts having jurisdiction over them to the exclusionof the Metropolitan Trial Courts, Municipal Trial Courts in Cities,Municipal Trial

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* THIRD DIVISION.

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Courts and Municipal Circuit Trial Courts.The error wasprobably due to the confusion as to the proper venue for the crime oflibel brought about by the passage of R.A. 7691 which took effect onApril 15, 1994. Under Section 2 of the said Republic Act, thejurisdiction of Metropolitan Trial Courts, Municipal Trial Courtsand Municipal Circuit Trial Courts was expanded to include alloffenses punishable with imprisonment not exceeding six (6) years.However, libel, which is punishable by imprisonment ranging fromsix months and one day to four years is not covered as the said lawexcludes from its coverage cases within the exclusive jurisdiction ofthe Regional Trial Courts. Under Article 360 of the Revised PenalCode, the information for libel should be filed with the Court ofFirst Instance, now the Regional Trial Court. The confusion wascleared up when this Court issued Administrative Order No. 104-96dated October 21, 1996 which categorically stated that LIBELCASES SHALL BE TRIED BY THE REGIONAL TRIAL COURTSHAVING JURISDICTION OVER THEM TO THE EXCLUSION OF



THE METROPOLITAN TRIAL COURTS, MUNICIPAL TRIALCOURTS IN CITIES, MUNICIPAL TRIAL COURTS ANDMUNICIPAL CIRCUIT TRIAL COURTS.

Same; Same; The mistake of the Office of the City Prosecutor inthe filing of the complaint with, and of the Metropolitan Trial Courtin taking cognizance of the case should not operate to prejudice theinterest of the state to prosecute criminal offenses and, moreimportantly, the right of the offended party to obtain grievance.Evidently, Branch 215 of the Metropolitan Trial Court of QuezonCity was not spared the confusion brought about by R.A. 7691, asits dismissal of the case then pending before it was made only onNovember 8, 1996 or more than two years after it had takencognizance of the case. Notably, the dismissal by the MetropolitanTrial Court took place a mere eighteen (18) days after the issuanceof S.C. Administrative Order No. 104-96. The mistake of the Officeof the City Prosecutor in filing the complaint and of theMetropolitan Trial Court in taking cognizance of the case was thusunderstandable. The error was immediately rectified by the saidcourt upon realizing its mistake when it ruled it was the RegionalTrial Court which had the proper jurisdiction over the case. Thismistake should not operate to prejudice the interest of the state toprosecute criminal offenses and, more importantly, the right of theoffended 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 thecomplaint with the municipal trial court or the prosecutors officeoperates to interrupt the prescription period for the prosecution of acrime.Moreover, the doctrine in People vs. Olarte, as applied inlater cases, was not meant to apply

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solely to cases where the filing of the complaint with the municipaltrial court or the prosecutors office operates to interrupt theprescription period for the prosecution of a crime.

Right to a Speedy Trial; Well established is the doctrine that the



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

PETITION for review on certiorari of a decision of theCourt 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 theDecision

1 of the Court of Appeals

2 in CA-G.R. SP No. 47089

promulgated on

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1 Rollo, pp. 23-27.2 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 Resolution3 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 jointcomplaintaffidavit for libel against petitioners before the Office ofthe City Prosecutor of Quezon City alleging that the lattercirculated on December 21, 1993 a letter containing maliciousimputations against them.

An information for libel then was filed before the MetropolitanTrial Court of Quezon City on May 18, 1994.

After the prosecution presented its evidence, petitioner filed aDemurrer to Evidence. Without resolving the incident, theMetropolitan Trial Court in its Order dated November 9, 1996 ruledthat it had no jurisdiction over the case as the same falls under theoriginal and exclusive jurisdiction of the Regional Trial Court, andordered that the case be forwarded to the RTC for furtherproceedings.

On November 29, 1996, the case was forwarded to Branch 215Regional Trial Court of Quezon City docketed as Criminal Case No.96-6870.

On January 3, 1997, petitioner filed a Motion to Dismiss on theground 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 CityProsecutor of Quezon City to re-file the Information for Libel withthe RTC.

On April 27, 1997, the Information for Libel was re-filed withrespondent court docketed as Criminal Case No. 0-97-70948.

On June 17, 1997, petitioner filed a Motion to Quash on theground of prescription. The motion was denied in the assailedResolution dated October 3, 1997.

Petitioners Motion for Reconsideration was also denied in theother Assailed Order dated December 4, 1997.

4

Not satisfied with the Resolution and Order of the trialcourt, herein petitioner appealed to the Court of Appealsraising the issue of whether or not public respondentcommitted grave abuse of discretion or grossly erred inholding that the offense of libel in the



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3 Rollo, p. 28.4 Rollo, pp. 23-24.

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

in its decision dated March 01, 1999, upheld the contentionof the trial court that the offense of libel had not yetprescribed and consequently, dismissed the said petition.The appellate court likewise denied herein petitionersMotion for Reconsideration in its Resolution dated May 11,1999.

6

Petitioner is now before this Court seeking a reversal ofthe decision of the Court of Appeals and contending that

I.

THE COURT OF APPEALS ERRED IN RULING THAT THECRIME OF LIBEL HAS NOT YET PRESCRIBED.

II.

THE COURT OF APPEALS ERRED IN RULING THATPETITIONER HAS NOT BEEN DENIED HERCONSTITUTIONAL RIGHT TO A SPEEDY TRIAL.

7

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 twentyyears.

Crimes punishable by other afflictive penalties shall prescribe infifteen years.

Those punishable by a correctional penalty shall prescribe in 10years; 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 oneyear. (italics supplied)



The said prescriptive period is computed under Article 91of the Revised Penal Code, as follows:

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5 Rollo, p. 25.6 Annex B of Petition; Rollo, 28.7 Rollo, p. 14.

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Art. 91. Computation of prescription of offenses.The period ofprescription shall commence to run from the day on which the crimeis discovered by the offended party, the authorities, or their agents,and shall be interrupted by the filing of the complaint orinformation, and shall proceed to run again when such proceedingsterminate without the accused being convicted or acquitted, or areunjustifiably stopped for any reason not imputable to him.

The term of prescription shall not run when the offender isabsent from the Philippine Archipelago.

In the case at bench, the offense of libel allegedly occurredon December 21, 1993 when petitioner circulated a lettercontaining allegedly malicious imputations against privaterespondents Srs. Helen Ojario and Bernadine Juarez. Atthis point, the period of prescription for the alleged crimehad already started to run.

The one-year period of prescription for the crime wasinterrupted on February 2, 1994 when respondents filed ajoint complaint-affidavit

8 for libel against petitioner before

the Office of the City Prosecutor in Quezon City. At thispoint, the prescription period had already run for forty-two(42) days.

A preliminary investigation by the Office of the CityProsecutor was thus conducted. On April 27, 1994, Asst.City Prosecutor Ma. Aurora Escasa-Ramos issued aResolution stating that probable cause exists againstpetitioner and recommended the filing of an information forlibel against her. Consequently, an information

9 for libel



was filed against petitioner on May 18, 1994 before theMetropolitan Trial Court of Quezon City, Branch 32.

10

Despite the fact that the Metropolitan Trial Court hadno jurisdiction over the crime of libel, the said courtproceeded to conduct trial on the merits. After theprosecution had rested, petitioner filed a Demurrer toEvidence dated September 18, 1996. However, instead ofacting on the said demurrer, the Metropolitan Trial Court,on November 08, 1996, issued an Order

11 ruling that it had

no jurisdiction over the crime of libel as the same fallsunder the

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8 Annex C of Petition; Rollo, pp. 29-30.9 Annex D of Petition; Rollo, pp. 34-35.10 Docketed as Criminal Case No. 24213.11 Annex T of Petition; Rollo, 36-38.

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exclusive jurisdiction of the Regional Trial Court. Instead ofdismissing the case outright, the MTC ordered theforwarding of the records of the case to the Regional TrialCourt for further proceedings. The case was eventuallyraffled off to Branch 215 of the Regional Trial Court ofQuezon City.

12

On the basis of a Motion to Dismiss13

filed by petitioner,Branch 215 of the Regional Trial Court dismissed the caseon April 2, 1997 on the ground of lack of jurisdiction as theinformation against petitioner should have been re-filedanew. The court ruled, however, that the crime had not yetprescribed and ordered the refiling of the case.

14 On April

27, 1997, the Office of the City Prosecutor re-filed the casewith the Regional Trial Court and eventually the same wasraffled to Branch 218 of the said court.

15 Petitioner tried to

have this case dismissed on the ground of prescription buther motion to quash

16 the information was denied by

Branch 218 of the Quezon City Regional Trial Court in a



Resolution17

dated October 3, 1997. The denial by theRegional Trial Court of petitioners motion to quash wassubsequently upheld by the Court of Appeals.

It is the contention of petitioner that the prescriptionperiod for the crime of libel charged against her commencedto run again when the Assistant City Prosecutorrecommended the filing of the information for libel.Petitioner further argues that the prescriptive period couldhave been interrupted again had the information been filedwith the Regional Trial Court, the court with the properjurisdiction to try the case for libel. Considering howeverthat the case was filed before the Metropolitan Trial Court,which under the law does not have jurisdiction over thecrime of libel, the period of prescription continued to run itscourse. Consequently, petitioner concludes that when theinformation for libel was finally filed with the RegionalTrial Court, the crime had already prescribed and the Statecan no longer pursue the case against her.

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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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In support of her arguments, petitioner questions thereliance made by the Regional Trial Court and the Court ofAppeals in the landmark case of People vs. Olarte.

18

Petitioner submits that the adherence to the Olarte casemust be examined considering that in the said case, theprincipal issue was whether or not the filing of a complaintin the Municipal Trial Court for purposes of preliminaryinvestigation, interrupts the period of prescription of a



crime. Petitioner argues that the cited case is inapplicableas it is not disputed in the case at bench that the period ofprescription was interrupted during the process ofpreliminary investigation.

We are not persuaded.In the landmark case of People vs. Olarte, this Court

speaking through Justice J.B.L. Reyes, finally resolved thethen conflicting views as to whether or not the filing of acomplaint with the Municipal Trial Court for purposes ofpreliminary investigation suspends the running of theprescriptive period for the crime. The Court restated thecorrect and prevailing doctrine, as follows:

In view of this diversity of precedents, and in order to provideguidance for the Bench and Bar, this Court has reexamined thequestion and, after mature consideration, has arrived at theconclusion that the true doctrine is, and should be, the oneestablished by the decisions holding that the filing of the complaintwith the Municipal Court, even if it be merely for purposes ofpreliminary 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 nottry the case on the merits. Several reasons buttress this conclusion:first, the text of Article 91 of the Revised Penal Code, in declaringthat the period of prescription shall be interrupted by the filing ofthe complaint or information without distinguishing whether thecomplaint is filed in the court for preliminary examination orinvestigation merely, or for action on the merits. Second, even if thecourt where the complaint or information is filed may only proceedto investigate the case, its actuations already represent the initialstep of the proceedings against the offender. Third, it is unjust todeprive the injured party the right to obtain vindication on accountof delays that are not under his control. All that the victim of theoffense may do on his part to initiate the prosecution is to file therequisite complaint.

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18 19 SCRA 494 (1967).

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And it is no argument that Article 91 also expresses that theinterrupted prescription shall commence to run again when suchproceedings terminate without the accused being convicted oracquitted, thereby indicating that the court in which the complaintor information is filed must have the power to convict or acquit theaccused. Precisely, the trial on the merits usually terminates inconviction or acquittal, not otherwise. But it is in the courtconducting a preliminary investigation where the proceedings mayterminate without conviction or acquittal, if the court shoulddischarge the accused because no prima facie case had been shown.

Subsequently, this Court, in Francisco vs. Court ofAppeals,

19 broadened the scope of Olarte by holding that

the filing of the complaint with the fiscals office alsosuspends the running of the prescriptive period.

Petitioner insists that the ruling in Olarte with respectto the interruption of the prescriptive period is notapplicable. In the case at bench, the fact that the period ofprescription was interrupted by the filing of privaterespondents joint affidavit with the Quezon CityProsecutors Office is not disputed. The Olarte case,however, makes several other pronouncements that aredeterminative of the issues raised by petitioner.

It is clear from the Olarte case that the filing of thecomplaint or information for purposes of preliminaryinvestigation represents the initial step of the proceedingsagainst the offender. This is one of the reasons why suchfiling is deemed as having interrupted the period ofprescription for the prosecution of a crime. This period ofprescription commences to run again when the proceedingsterminate without conviction or acquittal, if the court (orprosecutor) should discharge the accused because no primafacie case has been shown.

20

It is thus evident that petitioners first premise that theperiod of prescription commenced to run again when theQuezon City Prosecutors Office recommended the filing ofa criminal complaint against her is incorrect. When theCity 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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the filing of libel charges against petitioner, theproceedings against her were not terminated, preciselybecause 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 thecontinuation of the proceedings against the petitioner bythe filing of the appropriate information against her and bythe holding of trial on the merits. As such, when theinformation for libel was filed with the Metropolitan TrialCourt, the period of prescription for the crime was stillsuspended.

Another important teaching in Olarte is that it isunjust to deprive the injured party of the right to obtainvindication on account of delays that are not under hiscontrol. This is because in criminal prosecutions, the onlything that the victim of the offense may do on his part toinitiate the prosecution is to file the requisite complaint.

In the case at bench, private respondents were notremiss in their right to seek grievance against respondentas they filed their complaint before the city prosecutorforty-two days after the alleged crime of libel occurred. Itwas the Office of the City Prosecutor that committed anerror when it filed the complaint with the MetropolitanTrial Court.

The error was probably due to the confusion as to theproper venue for the crime of libel brought about by thepassage of R.A. 7691

21 which took effect on April 15, 1994.

Under Section 2 of the said Republic Act, the jurisdiction ofMetropolitan Trial Courts, Municipal Trial Courts andMunicipal Circuit Trial Courts was expanded to include alloffenses punishable with imprisonment not exceeding six(6) years. However, libel, which is punishable byimprisonment ranging from six months and one day to four



years22

is not covered as the said law excludes from itscoverage cases within the exclusive jurisdiction of theRegional Trial Courts.

23

________________

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.

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Under Article 360 of the Revised Penal Code, theinformation for libel should be filed with the Court of FirstInstance, now the Regional Trial Court. The confusion wascleared up when this Court issued Administrative OrderNo. 104-96 dated October 21, 1996 which categoricallystated that LIBEL CASES SHALL BE TRIED BY THEREGIONAL TRIAL COURTS HAVING JURISDICTIONOVER THEM TO THE EXCLUSION OF THEMETROPOLITAN TRIAL COURTS, MUNICIPAL TRIALCOURTS IN CITIES, MUNICIPAL TRIAL COURTS ANDMUNICIPAL CIRCUIT TRIAL COURTS.

24

Evidently, Branch 215 of the Metropolitan Trial Court ofQuezon City was not spared the confusion brought about byR.A. 7691, as its dismissal of the case then pending beforeit was made only on November 8, 1996 or more than twoyears after it had taken cognizance of the case. Notably, thedismissal by the Metropolitan Trial Court took place amere eighteen (18) days after the issuance of S.C.Administrative Order No. 104-96.

The mistake of the Office of the City Prosecutor in filingthe complaint and of the Metropolitan Trial Court in takingcognizance of the case was thus understandable. The errorwas immediately rectified by the said court upon realizing



its mistake when it ruled it was the Regional Trial Courtwhich had the proper jurisdiction over the case. Thismistake should not operate to prejudice the interest of thestate 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 inlater cases, was not meant to apply solely to cases wherethe filing of the complaint with the municipal trial court orthe prosecutors office operates to interrupt the prescriptionperiod for the prosecution of a crime.

In People vs. Galano,25

an information was filed with theBatangas Regional Trial Court even though the evidence ofboth the prosecution and defense shows that the crime wascommitted in

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24 People vs. Metropolitan Trial Court of Quezon City, Branch 32, 265

SCRA 645 (1996).25 75 SCRA 193 (1977).

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Manila. This Court, applying People vs. Olarte, held that itwas only when the trial court dismissed the case due tolack of jurisdiction that the proceedings thereinterminated without conviction and acquittal and it wasonly then that the prescriptive period (which wasinterrupted during the pendency of the case in theBatangas Court) commenced to run again.

In People vs. Enrile,26

informations were filed againstcivilians before military tribunals which had no jurisdictionover the persons of these civilians. These civiliansquestioned the re-filing of the cases against them beforethe civil courts raising, among others, that the crimes forwhich they are being charged have already prescribed. ThisCourt, applying by analogy the ruling in the Olarte case,threw out the defense of prescription and held that thefiling of the first indictments suspended the running of the



prescriptive period, and the prosecutions under theinformations to be filed should be regarded as merecontinuations of the previous proceedings. At the veryleast, the Court ruled the filing of the first charges shouldbe considered as having interrupted the prescriptive periodnotwithstanding the lack of jurisdiction of the militarytribunal in which they were filed.

More recently, in the case of Reodica vs. Court ofAppeals,

27 an information for reckless imprudence resulting

in damage to property with slight physical injuries wasfiled with the Regional Trial Court even though the offensewas within the exclusive jurisdiction of the municipal trialcourt. The Court, even as it dismissed the cases pendingbefore the Regional Trial Court for lack of jurisdiction,disregarded the defense of prescription raised by theaccused. The Court, citing Olarte and the subsequent casesof Francisco vs. Court of Appeals

28 and People vs.

Cuaresma29

ruled that the prescriptive period for the quasioffenses in question was interrupted by the filing of thecomplaint with the fiscals office three days after thevehicular mishap and remained tolled pending thetermination of the case.

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26 160 SCRA 700 (1988).27 292 SCRA 91 (1998).28 122 SCRA 538 (1983).29 172 SCRA 415 (1989).

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From these cases, it is clear that the Appellate Courtcommitted no reversible error in ruling that the offense oflibel charged against petitioner had not yet prescribed. Theperiod of prescription for the crime was interrupted whenthe complaint was lodged with the Office of the CityProsecutor and remained tolled pending the termination ofthe case against petitioner. Branch 218 of the Regional



Trial Court of Quezon City, therefore, correctly assumedjurisdiction over the case of petitioner as the offense of libelfor which she was being charged has not yet prescribed.

Petitioners other argument that she has been deniedher right to a speedy trial deserves scant consideration.Well-established is the doctrine that the right to a speedytrial is violated only where there is an unreasonable,vexatious and oppressive delay without participation orfault of the accused, or when unjustified postponements aresought which prolong the trial for an unreasonable lengthof time.

30 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 aMotion for Reconsideration with the Regional Trial Court ofQuezon City, Branch 218. As such, it is clear that petitioneris not without fault in the delay in the prosecution of thecase against her.

Wherefore, the petition is hereby DENIED, and thedecision of the Court of Appeals dated May 1, 1999 ishereby AFFIRMED.

SO ORDERED.

Melo (Chairman), Vitug, Panganiban and Purisima,JJ., concur.

Petition denied, judgment affirmed.

Notes.The filing by a dismissed employee of acriminal action for libel during the pendency of the illegaldismissal case does not constitute forum-shopping.(Equitable Banking Corporation vs. National LaborRelations Commission, 273 SCRA 352 [1997])

R.A. No. 7691 can by no means be considered anotherspecial law on jurisdiction but merely an amendatory lawintended to

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30 Guerrero vs. Court of Appeals, 257 SCRA 703 (1996).

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Santos vs. Santos

amend specific sections of the Judiciary Reorganization Actof 1980in a manner of speaking, R.A. No. 7691 wasabsorbed by the mother law, the Judiciary ReorganizationAct of 1980. (Morales vs. Court of Appeals, 283 SCRA 211[1997])

A later enactment like RA 7691 does not automaticallyoverride an existing law, because it is a well-settledprinciple of construction that, in case of conflict between ageneral law and a special law, the latter must prevailregardless of the dates of their enactmentjurisdictionconferred by a special law on the RTC must thereforeprevail over that granted by a general law on the MTC.(Manzano vs. Valera, 292 SCRA 66 [1998])

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Arambulo v. Laqui