G.R. No. 212623 - De Leon vs. People

Enrique G. De Leon was charged with Grave Oral Defamation for allegedly uttering on April 17, 2006 at the People’s Law Enforcement Board (PLEB) premises in Manila the words: “Walanghiya kang mangongotong na pulis ka, ang yabang yabang mo noon. Patay ka sa akin mamaya.”
The Metropolitan Trial Court (MeTC), Branch 6, Manila convicted him on April 15, 2011 and sentenced him to the indeterminate penalty for grave oral defamation with P10,000 moral damages.
The Regional Trial Court (RTC), Branch 27, Manila and the Court of Appeals (CA) affirmed the conviction, the CA modifying only the minimum term. De Leon filed a petition for review on certiorari before the Supreme Court.

Private respondent SPO3 Pedrito L. Leonardo, Carlito Principe, and Jennifer Malupeng testified that De Leon publicly insulted Leonardo, intending to besmirch his honor and reputation, causing him public contempt.
Leonardo promptly reported the incident to the police blotter and filed charges the same day; Principe had no ill motive and corroborated the testimony.
The MeTC found the accusation credible, noting the spontaneity of the report and the complainant’s demeanor.

De Leon and his witnesses claimed a prior gun‐pointing incident on February 27, 2006 in which Leonardo allegedly threatened De Leon, provoking his outburst.
At the PLEB hearing, De Leon responded in anger and did not apologize; he later filed counter‐charges only after receiving the OCP subpoena.
Defense witnesses asserted that Leonardo’s conduct, not De Leon’s words, was the real offense and that the utterances were emotional reactions, not malicious defamation.

Whether the MeTC decision failed to state clearly and distinctly the facts and law on which it was based, in violation of Constitution Article VIII, Section 14 and Rule 36, Section 1.
Whether De Leon’s guilt for oral defamation was proven beyond reasonable doubt.