RULES ON VENUE IN LIBEL CASES
1. General rule: criminal action for libel may be filed with the RTC of the province or city where the libelous article is printed and first published
2. If the offended party is a private individual, the criminal action may also be filed in the RTC of the province where he actually resided at the time of the commission of the offense
3. If the offended party is a public officer whose office is in Manila at the time of the commission of the offense, the criminal action may be filed in the RTC of Manila
4. If the offended party is a public officer whose office is outside Manila, the action may be filed in the RTC of the province or city where he held office at the time of the commission of the offense