Title
Artajos vs. Court of Appeals
Case
G.R. No. 131113
Decision Date
Apr 21, 1999
A teacher accused of publicly defaming a colleague with slanderous remarks during a school flag ceremony; guilt proven, procedural errors barred appeal, penalty modified.
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Case Digest (G.R. No. 131113)

Facts:

Incident Details

  • Date and Place: On December 3, 1993, at Burgos Memorial West School in Vigan, Ilocos Sur.
  • Parties Involved: Petitioner Dionisia Artajos (accused) and complainant Nenita Uy (a teacher at the school).
  • Allegations: Petitioner publicly uttered slanderous and defamatory words against complainant, including "sika switik, salawasaw, ma[g]nanakaw" ("You are a swindler, liar, thief") and "Gaga, Baboy" ("Stupid, Pig").

Complainant’s Testimony

  • Morning Incident: During the recitation of the Panatang Makabayan, petitioner shouted at complainant, "Oy sika Mrs. Uy, okinnam rummuarka ta patayen ka" ("Hey, Mrs. Uy, come out so I can kill you").
  • Witnesses: Several pupils and teachers were present during the flag ceremony.
  • Aftermath: Complainant reported the incident to the principal, district supervisor, and barangay captain. A confrontation was held later that day, but no settlement was reached.

Petitioner’s Defense

  • Petitioner denied the accusations and claimed that it was complainant who shouted at her, saying, "Oki Artajos, uray ket no pinnatay" ("Artajos, even if you kill me").
  • Petitioner alleged that complainant harbored ill feelings toward her and had filed multiple criminal and administrative cases against her.

Trial Court Decision

  • The Municipal Trial Court (MTC) found petitioner guilty of grave slander and sentenced her to one (1) year and one (1) day to one (1) year and eight (8) months imprisonment, plus P10,000.00 in moral damages.
  • The Regional Trial Court (RTC) affirmed the MTC’s decision but removed the moral damages award.

Appeal to the Court of Appeals

  • Petitioner filed a notice of appeal instead of a petition for review, which was deemed late. The Court of Appeals denied the petition due to procedural errors and lack of merit.

Issue:

  1. Whether the Court of Appeals erred in not giving due course to the petition due to procedural lapses.
  2. Whether petitioner’s guilt was proven beyond reasonable doubt.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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