Case Digest (G.R. No. 183623)
Facts:
The case involves Leticia B. Agbayani (petitioner) and Loida Marcelina J. Genabe (respondent), both employees of the Regional Trial Court (RTC), Branch 275 in Las Piñas City. On December 29, 2006, Agbayani filed a criminal complaint for grave oral defamation against Genabe, alleging that Genabe made derogatory remarks about her in front of their colleagues while she was performing her duties. The statements included accusations of incompetence and unprofessional behavior, suggesting that Agbayani was "feeling lawyer" and insinuating that she was selling cases. The complaint was initially found to have probable cause by the Office of the City Prosecutor of Las Piñas City on February 12, 2007. However, Genabe filed a petition for review with the Department of Justice (DOJ), which led to a reversal of the initial finding. The DOJ concluded that the remarks constituted only slight oral defamation, made in the heat of anger, and noted that the complaint had not undergone...
Case Digest (G.R. No. 183623)
Facts:
Parties Involved: Petitioner Leticia B. Agbayani (Agbayani) and Respondent Loida Marcelina J. Genabe (Genabe), both employees of the Regional Trial Court (RTC), Branch 275 of Las Piñas City.
Incident: On December 29, 2006, Agbayani filed a criminal complaint for grave oral defamation against Genabe for allegedly uttering defamatory statements against her in the workplace.
Statements: Genabe allegedly said, "Ang galing mo Lety, sinabi mo na tinapos mo yung Marvilla case, ang galing mo. Feeling lawyer ka kasi, bakit di ka mag-duty na lang, stenographer ka magsteno ka na lang, ang galing mo, feeling lawyer ka talaga. Nagbebenta ka ng kaso, tirador ka ng judge. Sige high blood din ka, mamatay ka sana sa high blood mo."
Prosecutor’s Initial Finding: The Office of the City Prosecutor of Las Piñas City found probable cause for grave oral defamation on February 12, 2007.
DOJ’s Reversal: Upon review, the DOJ Undersecretary found that the statements constituted only slight oral defamation, made in the heat of anger, and dismissed the case for non-compliance with the Katarungang Pambarangay conciliation process under the Local Government Code of 1991.
Court of Appeals’ Decision: The CA upheld the DOJ’s decision, finding no grave abuse of discretion.
Issue:
- Whether the DOJ committed grave abuse of discretion in reversing the City Prosecutor’s finding of probable cause for grave oral defamation.
- Whether the statements constituted grave oral defamation or slight oral defamation.
- Whether the dismissal of the case due to non-compliance with the Katarungang Pambarangay conciliation process was proper.
- Whether the DOJ erred in allowing Genabe’s petition for review despite alleged procedural irregularities.
Ruling:
The Supreme Court denied Agbayani’s petition and affirmed the CA’s decision. The Court held:
- The DOJ did not commit grave abuse of discretion in downgrading the charge to slight oral defamation, as the statements were made in the heat of anger.
- The dismissal of the case was proper for non-compliance with the Katarungang Pambarangay conciliation process under the Local Government Code of 1991.
- The DOJ’s acceptance of Genabe’s petition for review, despite procedural irregularities, was within its discretion and did not constitute grave abuse of discretion.
Ratio:
- Nature of Defamation: Oral defamation is classified as grave or slight based on the expressions used, the relationship between the parties, and the circumstances of the case. Here, the statements were made in the heat of anger, constituting slight oral defamation.
- Katarungang Pambarangay Compliance: The Local Government Code mandates barangay conciliation for disputes between parties residing in the same city or municipality, unless an exception applies. Agbayani’s failure to comply with this requirement justified the dismissal of her complaint.
- Procedural Irregularities: The DOJ has discretion to relax procedural rules in the interest of justice. The Court found no clear evidence of extrinsic fraud or grave misconduct in the DOJ’s handling of the case.
- Prosecutorial Discretion: The determination of probable cause and the classification of offenses are within the discretion of the DOJ. Courts will not interfere unless there is grave abuse of discretion.