Case Digest (G.R. No. L-2990) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Oscar Espuelas y Mendoza vs. The People of the Philippines, petitioner Oscar Espuelas y Mendoza arranged for a photograph of himself appearing to hang from a tree limb, when in fact he merely stood on a barrel, and thereafter published that image nationwide and abroad between June 9 and June 24, 1947. He accompanied the photograph with a pseudonymous “suicide note” signed “Alberto Reveniera,” addressed to a fictitious wife and children, in which he denounced President Roxas’s administration as “dirty,” likened it to “Hitlers and Mussolinis,” urged the burning of the President’s pictures, and called for rebellion against lawful authorities. Espuelas admitted authorship and dissemination in various newspapers and periodicals. Tried before the Court of First Instance of Bohol, he was convicted of violating Article 142 of the Revised Penal Code for writing, publishing, and circulating scurrilous libels against the Government. The conviction was affirmed by the Court of Appeals, l Case Digest (G.R. No. L-2990) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural History
- Oscar Espuelas y Mendoza (petitioner) was charged under Article 142 of the Revised Penal Code for writing, publishing, and circulating scurrilous libels against the Government and its authorities.
- He was convicted by the Court of First Instance of Bohol; the conviction was affirmed by the Court of Appeals; he then appealed to the Supreme Court (G.R. No. L-2990, Dec. 17, 1951).
- Underlying Acts
- From June 9 to June 24, 1947, in Tagbilaran, Bohol, petitioner had his photograph taken to simulate hanging by a rope (standing on a barrel).
- He authored a fictitious suicide note under the pseudonym “Alberto Reveniera,” addressed to a nonexistent wife and children, and mailed copies with his photo to various newspapers and weeklies in Bohol, throughout the Philippines, and abroad.
- Contents and Dissemination
- The note expressed shame at the administration of President Roxas; labeled the government “dirty” and “infested with Hitlers and Mussolinis”; urged readers to burn Roxas’s pictures; and to inform President Truman and Churchill of Filipino discontent.
- Petitioner admitted writing the note, assuming the pseudonym, and causing its publication in the Free Press, the Evening News, Bisaya, Lamdag, and other periodicals.
Issues:
- Scurrilous Libel Under Article 142
- Whether petitioner’s forged suicide note and photograph constitute a “scurrilous libel” against the Government or its duly constituted authorities.
- Incitement to Sedition
- Whether the publications “suggest or incite rebellious conspiracies or riots” or “tend to stir up the people against the lawful authorities,” as prohibited by Article 142.
- Constitutional Free Speech Guarantee
- Whether applying Article 142 to petitioner’s conduct violates the constitutional right to freedom of speech and of the press.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)