VENUE IN LIBEL CASES WHERE THE COMPLAINANT IS A PRIVATE INDIVIDUAL IS WHERE HE ACTUALLY RESIDES AT THE TIME OF THE COMMISSION OF THE OFFENSE OR WHERE THE DEFAMATORY ARTICLE WAS PRINTED AND FIRST PUBLISHED:

     In criminal prosecution for libel where defamatory article was posted on a website, an allegation that the defamatory article was first published and accessed in Makati is not sufficient to vest jurisdiction upon the Makati RTC.  There is no way of determining the situs of the article’s first printing and publication. The place where the article was first accessed cannot be equated to the first publication. (Bonifacio vs. Regional trial court of Makati, May 5, 2010).