Case Digest (G.R. No. 139157)
Facts:
Rogelio Pader v. People of the Philippines, G.R. No. 139157, February 08, 2000, the Supreme Court En Banc, Pardo, J., writing for the Court. The petition assails a Court of Appeals decision affirming the conviction for oral defamation that had been entered against petitioner by lower courts.Petitioner Rogelio Pader was accused by Atty. Benjamin C. Escolango (the private offended party) of having shouted at him on April 20, 1995 at about 8:00 p.m. at Escolango’s residence in Morong, Bataan the words “putang ina mo Atty. Escolango. Napakawalanghiya mo!” At the time Escolango was a candidate for vice mayor in the May 8, 1995 elections. Escolango filed a complaint for grave oral defamation with the Municipal Trial Court (MTC), Bagac, Bataan on June 16, 1995; petitioner pleaded not guilty.
After trial the MTC (Municipal Circuit Trial Court, Bagac-Morong) convicted Pader on October 30, 1997 of grave oral defamation under Article 358, Revised Penal Code, sentenced him to an indeterminate imprisonment of one month and one day to one year, and ordered payment of P20,000 as moral damages, citing Escolango’s social and professional standing. On appeal the Regional Trial Court (RTC), Branch 1, Balanga, Bataan affirmed the MTC decision in toto on March 4, 1998. The Court of Appeals, in CA-G.R. CR No. 21710 (ponente Justice Romeo A. Brawner), affirmed the RTC decision but modified the penalty to a definite prison term of four months and one day of arresto mayor; the CA decision was promulgated May 3, 1999.
Petitioner filed a petition for certiorari with the Supreme Court (Rollo filed July 20, 1999). The Supreme Court resolved the ca...(Pro-only)
Issues:
- Was petitioner guilty of serious (grave) oral defamation or only slight oral defamation under Article 358, Revised Penal Code?
- Was the award of moral damages to the private offended party supported by proof?
- Was the imposition of an indeterminate sentence appropriate when the applicable penalty ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)