02/03/2026
The RTC Has Jurisdiction Over Unjust Vexation When Committed Through ICT (Cyber-Enabled Unjust Vexation)
Unjust vexation (UV) is punished under Article 287 of the Revised Penal Code, as amended by R.A. No. 10951. Article 287 expressly provides that “other coercions or unjust vexations” are punishable by arresto menor or a fine ranging from ₱1,000 to ₱40,000, or both.
When unjust vexation is committed by, through, and with the use of information and communications technology (ICT)—for example, harassment or annoying conduct carried out through Facebook, Messenger, email, or other online platforms—Section 6 of the Cybercrime Prevention Act (R.A. No. 10175) applies. Section 6 provides that all RPC crimes committed through ICT are covered by RA 10175, and the penalty to be imposed is one (1) degree higher.
Accordingly, cyber-enabled unjust vexation (UV “in relation to Sec. 6, RA 10175”) is penalized one degree higher than the penalty for ordinary unjust vexation under Article 287.
The correct basis for RTC jurisdiction is Section 21 of R.A. No. 10175, which expressly provides that the Regional Trial Court shall have jurisdiction over any violation of the provisions of the Act:
“SEC. 21. Jurisdiction. — The Regional Trial Court shall have jurisdiction over any violation of the provisions of this Act….”— RA 10175, Sec. 21 (2012)
Thus, once the prosecution alleges and proves that unjust vexation was committed through ICT (triggering Section 6 coverage), the case falls under RA 10175’s jurisdictional framework and should be filed in the RTC.
This is reinforced by the Rules on Cybercrime Warrants, which state that RPC crimes committed through ICT (i.e., Section 6 cases) shall be filed before the regular or specialized RTCs, as applicable.
References
RA 10951, Sec. 73 (amending Art. 287) (2017)
RA 10175, Sec. 21 (2012)
Catan v. People (2023)
A.M. No. 17-11-03-SC, Rules on Cybercrime Warrants (2018)