Under Article 360 of the RPC, as amended by Republic Act No. 4363, libel cases where the complainant is a private individual is either (1) where the complainant actually resides at the time of the commission of the offense; or (2) where the alleged defamatory article was printed and first published.
If the private complainant opts for the second, the Information (formal indictment) must specifically state where the libelous article was printed and first published.
If the libelous article appears on a website, there is no way of finding out the location of its printing and first publication.
It is not enough for the complainant to lay the venue where the article was accessed, as this will open the floodgates to the libel suit being filed in all other locations where the website is also accessed or capable of being accessed, and spawn the very ills the amendment sought to prevent.
Thus, in cases where the libellous article appears on a website, the private complainant has the option to file the case in his/her place of residence, which will not necessitate finding out exactly where the libelous matter was printed and first published.