G.R. No. 123782 - Caltex Refinery Employees Association vs. Brillantes

On January 7, 1988, Roberto “Bobby” Brillante, candidate for Makati councilor, held a press conference attended by some 50 journalists. He accused Atty. Jejomar Binay (OIC-Mayor and mayoral candidate) and Dr. Nemesio Prudente (PUP President) of plotting the assassination of rival candidate Augusto “Bobby” Syjuco and of election-related terrorism.
He circulated an open letter addressed to President Corazon Aquino detailing alleged meetings (e.g., “Winner at all Costs,” “Dirty Fingers”) with military officers and hitmen tasked to kill Syjuco.

Journalists Angel Gonong (People’s Journal) and Gloria Hernandez (News Today) reported Brillante’s allegations; the open letter was published as a paid advertisement in People’s Journal, Balita, Malaya, and Philippine Daily Inquirer.
Binay, Prudente, and Francisco Baloloy filed multiple libel complaints with the Makati Fiscal’s Office, resulting in five informations in the RTC-Makati. Prudente filed additional complaints leading to four informations in the RTC-Manila.

RTC-Makati convicted Brillante on five counts of libel, sentencing him to 4 months arresto mayor as minimum to 2 years prision correccional as maximum per count, plus fines and moral damages (₱1,000,000 to Binay; ₱50,000 to Baloloy). Co-accused editors and publishers were acquitted, had charges dismissed, or cases archived.
RTC-Manila convicted Brillante on four counts of libel, sentencing him to 4 months arresto mayor as minimum to 2 years prision mayor as maximum per count, plus fines and ₱1,000,000 moral damages to Prudente. Co-accused Sison was acquitted.

In CA-G.R. CR No. 14475 and CA-G.R. CR No. 15174, the Court of Appeals affirmed both RTC decisions, ruling:

The one-year prescriptive period was tolled by the filing of complaints with the Fiscal’s Office (Rule 110, Sec. 1).
The open letter and statements were malicious libel not entitled to privilege.
Multiple publications constitute separate offenses.
Convicting Brillante but not his co-accused did not violate equal protection.

Motions for reconsideration were denied. Brillante filed petitions for review before the Supreme Court, challenging prescription, malice, privilege, political libel exemption, equal protection, and penalty severity.

Did the libel offenses prescribe before the Informations were filed in RTC-Makati and RTC-Manila?

Were the elements of libel—defamatory imputation, publication, identity, and malice—proven beyond reasonable doubt?
Were Brillante’s statements privileged communication?
Can his statements be considered non-punishable “political libel”?

Did convicting Brillante while acquitting/dismissing charges against co-accused violate equal protection?

Are the penalties imposed, particularly the moral damages awards, excessive or cruel?