Case Digest (G.R. No. 142509)
Facts:
Jose Alemania Buatis, Jr. v. The People of the Philippines and Atty. Jose J. Pieraz, G.R. No. 142509, March 24, 2006, Supreme Court First Division, Austria‑Martinez, J., writing for the Court.
Petitioner Jose Alemania Buatis, Jr. was charged with libel after a letter he authored (and which he later admitted sending) was retrieved from the mailbox of respondent Atty. Jose J. Pieraz on August 18, 1995. The letter, not in an envelope, contained insulting language directed at Atty. Pieraz (describing his prior communication as "lousy," "inutile," written in "carabao English," and ending with "Yours in Satan name"), was addressed to Pieraz, and indicated it was "copy furnished" to "all concerned." Pieraz and his family read the letter; Pieraz alleged it caused public ridicule, aggravated his frail health, and led to monetary expenses in pursuing the complaint.
Petitioner initially disclaimed authorship but, when confronted with a counter‑affidavit filed before the Pasig City Prosecutor, admitted he had sent the August 18, 1995 letter and a subsequent August 24, 1995 reply. Petitioner explained he acted as attorney‑in‑fact of the administrator of the Don Hermogenes Rodriguez y Reyes estate and claimed he was defending a tenant, Teresita Quingco, at the behest of the association NASATAMA.
The Regional Trial Court (RTC), Branch 167, Pasig City, after trial, found petitioner guilty of libel in a Decision dated April 30, 1997. The RTC sentenced him to an indeterminate term (four months and one day to two years, eleven months and ten days), ordered P20,000 compensatory, P10,000 moral, and P10,000 exemplary damages, and imposed accessory penalties and costs. Petitioner appealed to the Court of Appeals (CA).
In a Decision dated January 18, 2000, the CA (penning justice identified in the rollo) affirmed the RTC in toto, finding the letter defamatory, published, identifiable as addressed to Pieraz, and not a privileged communication because it contained irrelevant insults and was indiscriminately circulated. The CA denied petitioner’s motion for reconsideration in a Resolution dated March 13, 2000.
Petitioner filed a petition for review on certiorari with the Supreme Court und...(Pro-only)
Issues:
- Can malice be imputed to petitioner, an urban poor leader acting as counsel defending a member, for purposes of libel?
- Was the letter a privileged communication exempting petitioner from liability?
- Can petitioner be held criminally responsible for the letter (i.e., is he fully liable f...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)