In ordinary libel, which is Article 355 of the Revised Penal Code (RPC), “the crime of libel or other similar offenses shall prescribe in one year.
”The article in question – a story that links the late former Chief Justice Renato Corona to the businessman and complainant Wilfredo Keng – was published in May 2012.
Under the RPC, the complaint should have been filed before May 2013. It was only filed in October 2017.
In the resolution of the Department of Justice (DOJ) indicting Ressa, prosecutors cited Section 1(d) of Act 3326 in saying that special acts such as the Cybercrime Law prescribe “after twelve years.”
Source: Maria Ressa arrest tests the bounds of Philippine cyber libel law
Legal Notes 