Atty. Florlyn M. Pama-Atilano

25/08/2026

15/08/2026

SUPREME COURT: CYBER LIBEL PRESCRIBES IN ONE YEAR, NOT 15 YEARS

The Supreme Court has ruled that cyber libel prescribes in one year, rejecting the argument that the offense should be subject to the 15-year prescriptive period applicable to crimes punishable by other afflictive penalties.

In its En Banc Resolution¹ dated April 8, 2026, the Court explained that cyber libel is not an entirely new crime created by the Cybercrime Prevention Act. Rather, it is libel as defined under Article 353, in relation to Article 355, of the Revised Penal Code, committed through a computer system or information and communications technology (ICT).

The Court noted that Section 4(c)(4) of Republic Act No. 10175, or the Cybercrime Prevention Act, expressly refers to libel under the Revised Penal Code. Section 6 of the same law merely provides for a penalty one degree higher when crimes under the Revised Penal Code or special laws are committed through ICT. Thus, the use of a computer system constitutes a qualifying circumstance that increases the penalty; it does not transform cyber libel into an entirely different offense for purposes of prescription.

The Court therefore applied Article 90, paragraph 4 of the Revised Penal Code, which specifically provides that “libel or other similar offenses” prescribe in one year. The fact that cyber libel carries a heavier penalty does not, by itself, place it under the 15-year prescriptive period in Article 90, paragraph 2.

The Court further emphasized that the Legislature has historically treated libel differently from other offenses carrying comparable penalties. Republic Act No. 4661 shortened the prescriptive period for libel to one year, in part to synchronize it with the one-year period for civil actions involving defamation under Article 1147 of the Civil Code.

Applying the principle that penal laws on prescription must be construed in favor of the accused, the Court held that the one-year period under Article 90, paragraph 4 governs cyber libel.

Thus, while cyber libel carries a penalty one degree higher because it is committed through ICT, the prescriptive period remains one year. The Court denied the motions for partial reconsideration with finality.

FOOTNOTES

1 Causing v. People, SC En Banc, (2026) Per Inting, J. [https://dlsurf.com/l/f0a673e]

11/07/2026

𝗔𝗗𝗩𝗜𝗦𝗢𝗥𝗬 | 𝗧𝗘𝗠𝗣𝗢𝗥𝗔𝗥𝗬 𝗥𝗘𝗟𝗢𝗖𝗔𝗧𝗜𝗢𝗡 𝗢𝗙 𝗟𝗚𝗨 𝗣𝗔𝗦𝗦𝗜 𝗖𝗜𝗧𝗬 𝗢𝗙𝗙𝗜𝗖𝗘𝗦

Please be informed that in preparation for the construction of the new Passi City Hall, several LGU offices have been temporarily relocated to ensure the uninterrupted delivery of government services during the transition.

Kindly refer to the office location map below to guide you in visiting the appropriate office.

🏢 Building A – Finance Building
• City Assessor’s Office
• City Treasurer’s Office
• City Accounting Office
• Commission on Audit (COA)
• City Budget Office

🏢 Building B – Agriculture Building
• City Planning and Development Coordinator Office
• City Agriculture Office

🏢 Building C – ABC Hall
• Office of the Sangguniang Panlungsod
• Liga ng mga Barangay Office

🏢 Building D – SK Hall
• City Human Resources and Development Office (CHRDO)
• SK Federation Office

🏢 Building E – Evacuation Center
• Office of the City Mayor
• Department of the Interior and Local Government (DILG)

🏢 Building F – Sports Center
• City Engineering Office
• Bids and Awards Committee (BAC)
• City Waste Management Office

🏢 Building G – City Storage Facility
• City General Services Office (CGSO)

🏢 Building H – OFW Building (Ground Floor)
• Prosecutor’s Office
• Motorpool Section
• City Legal Office
• Public Employment Service Office (PESO)
• Social Security System (SSS)
• National Bureau of Investigation (NBI)

🏢 Building H – OFW Building (Second Floor)
• PAG-IBIG Fund
• Bureau of Internal Revenue (BIR)
• Public Attorney’s Office (PAO)
• BSP Regional Office
• BSP–Passi City Association Council

🏢 Building I - FITS Building

🏢 Building J
• Early Child Development Center

We encourage everyone to check the updated office locations before visiting City Hall to avoid inconvenience.

Thank you for your understanding and cooperation as we continue improving our facilities to better serve the people of Passi City.

12/06/2026

03/06/2026

Congratulations Passi City College, School of Criminal Justice, Class of 2026!

03/06/2026

Notice to the Public:

A fake account is using my name, photos and personal details in Facebook. Please beware in accepting friend requests and making transactions online from this account or any unverified accounts.