Facts:

The case involves Roberto Brillante as the petitioner against the Court of Appeals and the People of the Philippines as respondents. The events leading to this case began on January 6, 1988, when Brillante's friend’s house was bombed, resulting in the deaths of three individuals. This incident prompted Brillante to hold a press conference on January 7, 1988, where he accused certain private respondents, including Jejomar Binay, of committing terrorist acts against the electorate of Makati City. The accusations made by Brillante were published in various newspapers, leading to his conviction for libel. The case was initially decided by the lower court, which found Brillante guilty and imposed a penalty of imprisonment along with a fine. Brillante subsequently filed a motion for reconsideration on November 25, 2004, challenging the decision of the Court of Appeals dated October 19, 2004, which affirmed his conviction but reduced the amount of moral damages he was ordered to...

Facts:

1. Background of the Case:
   Roberto Brillante (petitioner) was convicted of libel for publishing defamatory materials against private respondents, including Jejomar Binay. The libelous materials were published in newspapers, and Brillante was held liable for multiple counts of libel.

2. Brillante's Claims:

   • He argued that his conviction violated his right to equal protection since the writers, editors, and owners of the newspapers were not convicted.
   • He contended that he should only be convicted of one count of libel, as the publications were driven by a single criminal intent.
   • He claimed that there was a "semblance of truth" to his accusations, citing alleged violent acts committed by private respondents against him.

3. Private Respondent's Position:

   • Jejomar Binay countered that the equal protection clause did not apply due to substantial distinctions between Brillante and his co-accused.
   • He asserted that there could be as many convictions for libel as there were persons defamed.

4. OSG's Position:

   • The Office of the Solicitor General (OSG) argued that the issues raised by Brillante had already been addressed by the Court in its earlier decision.

5. Court's Observation:

   • The Court noted that the penalty of imprisonment imposed on Brillante should be reconsidered, even though this issue was not raised by the parties.

6. Mitigating Circumstances:

   • Brillante claimed that the libelous publications were made in response to a bombing incident on January 6, 1988, which killed three people. He stated that he acted out of moral and social duty to expose what he believed were terrorist acts by private respondents.

7. Court's Finding on Penalty:

   • The Court found that the circumstances surrounding the libelous publications warranted the imposition of a fine only, instead of both imprisonment and fine.

Issue:

1. Whether Brillante's conviction violated his right to equal protection.
2. Whether Brillante should be convicted of only one count of libel.
3. Whether the penalty of imprisonment should be reconsidered.

Ruling:

The Court affirmed Brillante's conviction for libel but modified the penalty by deleting the imprisonment and retaining only the fine.

Ratio:

1. Equal Protection Clause:

   • The Court held that the equal protection clause was not violated because there were substantial distinctions between Brillante and his co-accused, justifying dissimilar treatment.

2. Multiple Counts of Libel:

   • The Court ruled that there can be as many convictions for libel as there are persons defamed. Each publication constituted a separate offense.

3. Reconsideration of Penalty:

   • The Court reconsidered the penalty of imprisonment, citing the circumstances surrounding the libelous publications. The Court found that the intense emotions during the election period and Brillante's incomplete privilege under Art. 354 of the Revised Penal Code justified the imposition of a fine only.

4. Incomplete Privilege:

   • Although Brillante failed to prove all elements of qualified privileged communication, the Court appreciated incomplete privilege in his favor, considering the wide latitude traditionally given to defamatory utterances against public officials and figures.