Case Digest (G.R. No. 246824)
Facts:
Argelyn M. Labargan v. People of the Philippines, G.R. No. 246824, December 06, 2023, Supreme Court Second Division, Leonen, SAJ., writing for the Court. Petitioner Argelyn M. Labargan (Labargan) was charged by separate Informations with grave oral defamation (Criminal Case No. 2754) and other light threats (Criminal Case No. 2755) before the Municipal Circuit Trial Court of Kolambugan-Tangkal, Kolambugan, Lanao del Norte. The grave oral defamation information alleged that on February 21, 2013 Labargan uttered statements calling barangay kagawad Aileen R. Macabangon ignorant and dumb, and the other information alleged that on March 13, 2013 Labargan threatened Macabangon with a bolo.At arraignment Labargan pleaded not guilty and trial followed. The prosecution presented Macabangon and other witnesses who testified that the alleged statements were yelled from the terrace of Labargan’s house and were heard by several persons; one witness (Jake) at one point said Macabangon was not present but otherwise corroborated hearing the utterances. For the threats charge, witnesses recounted Labargan waving a bolo and saying “I will kill you” and similar exclamations. Labargan testified in her defense, denied making the statements directed at Macabangon (asserting the dispute was with another person, Edna), and described text-message exchanges and provocation.
The Municipal Circuit Trial Court convicted Labargan of grave oral defamation and acquitted her of other light threats, sentencing her to imprisonment and awarding moral damages and attorney’s fees. The Regional Trial Court affirmed the conviction in an appeal. Labargan then filed a petition for review with the Court of Appeals, which affirmed the conviction but modified the penalty to a straight six-month imprisonment. Her motion for reconsideration in the Court of Appeals was denied. La...(Pro-only)
Issues:
- Was petitioner Argelyn M. Labargan proven guilty beyond reasonable doubt of grave oral defamation?
- When defamatory imputations concern a public officer’s discharge of official duties, must the prosecution prove actual malice before a convi...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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