G.R. No. 192856 - Gonzalez vs. Commission on Elections

On August 18, 1995, Atty. Jose J. Pieraz's wife found an open letter addressed to her husband in their mailbox, which she placed on his desk.
The letter was written by petitioner Jose Alemania Buatis, Jr., styled as a communication from the office of the Assistant Court Administrator concerning a threatening letter Pieraz had sent to Mrs. Teresita Quingco, a member of the association headed by petitioner.
The letter contained insulting language against Atty. Pieraz, calling his threatening letter “lousy but inutile,” accusing him of using “carabao English,” labeling him “stupid,” and ending with a derogatory closing, “Yours in Satan name.”
Upon reading this, Pieraz responded with a communication sent by registered mail to petitioner.
Petitioner sent a second letter dated August 24, 1995, in reply.

The libelous letter became known not only to Pieraz but also to his wife and children, who verbally chided him.
Pieraz filed a libel complaint against petitioner due to the insulting words and the defamatory nature of the letter.
Petitioner denied authorship initially but later admitted before the Pasig City Prosecutor’s Office that he sent both letters, including the one dated August 18 and August 24, 1995.

After trial, the Regional Trial Court (RTC), Branch 167 of Pasig City, convicted petitioner of libel under Articles 353 and 355 of the Revised Penal Code.
The RTC found the letter defamatory per se, prejudicial to Pieraz’s reputation as a lawyer, published to others since copies were circulated, and malicious due to the insulting and offensive language used.
Petitioner’s defense of mistake or negligence was rejected as he admitted intentional sending of the letter.
The RTC awarded compensatory damages of P20,000.00, moral damages of P10,000.00, and exemplary damages of P10,000.00.

The Court of Appeals (CA), in a Decision dated January 18, 2000, affirmed the RTC ruling.
The CA held that the letter was defamatory and malicious and that the claim of privilege was unsubstantiated because of the excessive insults and public circulation of the letter.
The CA denied petitioner’s Motion for Reconsideration on March 13, 2000.

Petitioner filed a petition for review on certiorari with the Supreme Court assailing the findings of the CA.
Petitioner alleged lack of malice, claimed privileged communication status for defending a member of his association, and questioned full criminal responsibility for the letter.

Whether malice, an essential element of libel, can be attributed to petitioner, acting as counsel in defense of a threatened member of his association?
Whether the libelous letter falls under the ambit of privileged communication, thus exempting petitioner from liability?
Whether petitioner can be held criminally liable without full responsibility given the context and purpose of his letter?