Case Digest (G.R. No. 127694)
Facts:
Quirico Mari v. Court of Appeals and People of the Philippines, G.R. No. 127694, May 31, 2000, the Supreme Court First Division, Pardo, J., writing for the Court.Petitioner Quirico Mari and private complainant Norma Capintoy were co‑employees at the Department of Agriculture in Digos, Davao del Sur, Capintoy holding a higher position. On December 6, 1991, petitioner borrowed what Capintoy described as his 201 file; when he returned it three days later several documents were missing, including official communications and a copy of a complaint by the Rural Bank of Digos against petitioner. Capintoy, upon instruction of her superior, sent petitioner a memorandum asking for an explanation.
Rather than acknowledge receipt, petitioner allegedly confronted Capintoy, shouted invectives ("Putang ina, bullshit, bugo"), banged a chair before her, and choked her until a security guard intervened. Petitioner disputed parts of this account: he said he borrowed only a service record (not the 201 file), that the borrowed record did not contain the missing papers, and that Capintoy provoked him.
Capintoy filed a criminal complaint for slander by deed with the Municipal Trial Court (Criminal Case No. 7227) on January 7, 1992, later amending it to allege aggravation because the offended party was a woman. On September 22, 1994, the Municipal Trial Court found petitioner guilty of slander by deed, credited one ordinary aggravating circumstance, and imposed an indeterminate sentence (five months, eleven days to two years, eleven months, eleven days) plus P5,000 moral damages, P5,000 attorneys’ fees and costs.
The Regional Trial Court, Davao del Sur, Branch 19, on December 1, 1995, affirmed the municipal court decision in toto. Petitioner filed a petition for review with the Court of Appeals on June 18, 1996; the Court of Appeals, in a December 9, 1996 decision, affirmed the conviction but modified the penalty to an indeterminate sentence of one month and one day of arresto mayor as minimum to two years and four months of prision correccional as maximum...(Pro-only)
Issues:
- Did the Court of Appeals err in sustaining petitioner’s conviction for serious slander by deed given the factual record?
- Did the trial court, the Regional Trial Court, and the Court of Appeals err in applying the Indeterminate Sentence Law and in fixing the penalty; if so, what is the...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)