Castro vs. People

Facts:

Jerome Castro v. People of the Philippines, G.R. No. 180832, July 23, 2008, the Supreme Court First Division, Corona, J., writing for the Court. The petition for review on certiorari under Rule 45 arose from a complaint for grave oral defamation filed by Albert P. Tan against petitioner Jerome Castro.

On November 11, 2002, Reedley International School (RIS) dismissed Tan’s son, Justin Albert, from school for alleged violations of its disciplinary code. Upon parental protest, RIS imposed non-appealable conditions (including exclusion from graduation). Tan filed an administrative complaint with the Department of Education (Dep-Ed) alleging malice and denial of due process. The Dep-Ed investigated and found RIS’s point system violated due process and ordered reinstatement; on November 20, 2002, Dep-Ed directed RIS to readmit Justin Albert unconditionally, and he later graduated on March 30, 2003.

After the graduation, Tan told fellow parent Bernice C. Ching he might sue RIS officers in their personal capacities, including petitioner (then assistant headmaster). Ching telephoned petitioner in the first week of April and relayed this; petitioner allegedly replied, “OK, you too, take care and be careful talking to [Tan], that’s dangerous.” Ching informed Tan, who filed a complaint for grave oral defamation with the Office of the City Prosecutor of Mandaluyong City on August 21, 2003.

An Information for grave oral defamation was filed in the Metropolitan Trial Court (MeTC), Mandaluyong City (Criminal Case No. 93541). At trial, Ching testified to petitioner’s warning; petitioner denied making the statement but did not categorically disprove Ching’s account. On December 27, 2005, the MeTC convicted petitioner of grave oral defamation and sentenced him to arresto mayor (decision penned by Judge Lizabeth Gutierrez-Torres).

On appeal, the Regional Trial Court (RTC), Mandaluyong City, Branch 212 (Judge Rizalina T. Capco-Umali), affirmed the MeTC’s factual findings but downgraded the offense to slight oral defamation; however, because Tan filed the complaint on August 21, 2003—almost five months after discovery—the RTC ruled the offense had prescribed and acquitted petitioner on prescription grounds (RTC decision dated November 20, 2006).

The Office of the Solicitor General (OSG) filed a petition for certiorari in the Court of Appeals (CA-G.R. SP No. 98649) on April 19, 2007, contending the RTC committed grave abuse of discretion by downgrading the offense. The CA Seventh Division (Assoc. Justice Remedio A. Salazar-Fernandez, with...(Pro-only)

Issues:

• Did the Court of Appeals have jurisdiction to entertain the OSG’s petition for certiorari challenging the RTC’s acquittal where the OSG asserted only errors of judgment in the RTC’s appreciation of evidence?
• Does the constitutional protection against double jeopardy bar further prosecution of petitioner af...(Pro-only)

Ruling:

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Ratio:

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Doctrine:

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