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:

Background of the Case

• Roberto Brillante was convicted for the crime of libel as affirmed by the Court's Decision dated October 19, 2004.
• The conviction included a penalty for both imprisonment and a fine, although the amount for moral damages was reduced.
• Brillante’s conviction was rendered despite the absence of a corresponding conviction against the writers, editors, and owners of the newspapers where the allegedly libelous material was published.

The Motion for Reconsideration

• Brillante filed a Motion for Reconsideration on November 25, 2004, challenging the Court’s decision.
• His arguments included:
• A claim of violation of his right to equal protection because his co-accused (the newspaper personnel) were not similarly convicted.
• The contention that he should have been convicted on a single count of libel because the libelous publications stemmed from a single criminal intent, rather than separate acts against different private respondents.
• The assertion that there was a "semblance of truth" in his allegations against the private respondents, citing several instances of alleged violent acts committed by them.

Positions of the Parties and Responses

• Brillante maintained his arguments in his initial motion and reiterated them in a Consolidated Reply on May 26, 2005.
• Private respondent Jejomar Binay submitted a Comment on March 3, 2005, arguing:
• The equal protection clause was inapplicable due to substantial distinctions among the co-accused, warranting different treatment.
• There could be multiple convictions for libel if distinct persons were defamed, countering Brillante’s claim for a single count.
• The issue regarding the number of counts should have been raised during the separate filing of complaints, not in the motion for reconsideration.
• The Office of the Solicitor General (OSG) filed a Comment on April 4, 2005, emphasizing:
• That the issues raised by Brillante had already been discussed and decided upon by the Court in its prior decision.
• That the motion for reconsideration should consequently be denied based on established conclusions.

Factual and Contextual Background Leading to the Libelous Incident

• On January 6, 1988, Brillante alleged that his friend’s house was bombed, resulting in the death of three persons.
• The incident was claimed to have impelled him to hold a press conference on January 7, 1988.
• During the press conference, Brillante read an open letter intended to expose what he believed were terrorist acts committed by private respondents against the electorate of Makati City.
• The open letter formed the basis of the libelous publications for which he was convicted.

Considerations Raised by the Court

• The Court observed that many arguments in the motion had been addressed in its prior Decision, hence the issues were not entertained anew except for those concerning the proper imposition of penalties.
• The Court noted that the appeal in a criminal proceeding permits the review of all aspects of the case, even those not raised by the parties, as emphasized in the precedent Mari v. Court of Appeals.
• The Court found compelling reasons to reevaluate the imposition of the penalty of imprisonment considering mitigating circumstances inherent in the case.

Issue:

Equal Protection Challenge

• Whether Brillante’s conviction—without convicting the writers, editors, and owners of the newspapers—violated his right to equal protection.

Multiple Counts of Libel

• Whether Brillante should have been convicted on only one count of libel on the basis that the libelous publications were driven by a single criminal intent rather than separate defamatory acts against different individuals.

"Semblance of Truth" Defense

• Whether the alleged "semblance of truth" in Brillante’s accusations against private respondents should have played a role in mitigating his liability.

Reconsideration of the Penalty

• Whether the penalty of imprisonment imposed against Brillante should be re-examined in light of the circumstances of the case, particularly considering the tempering factors (such as the heat of passion and the reaction to a perceived provocation) that might justify imposing a lesser penalty.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)