Following the principles laid down in the case of Bonifacio, the rules on venue of

criminal actions for Internet libel are as follows: (I) If the offended party is a
private individual, the criminal case can only be filed in either of two places,
namely: (a) where the complainant or offended party actually resides at the time of
the commission of the offense; or (b) where the alleged defamatory article was
printed and first published. (II) If the offended party is a public official, the
criminal case can only be filed in either of two places, namely: (a) in the place
(whether in or outside Manila) where he holds office at the time of the commission
of the crime; or (b) where the alleged defamatory article was printed and first
published.

see Bonifacio vs. RTC of Makati, G.R. No. 184800, 5 May 2010,