G.R. No. 139157 - Pader vs. People

On April 20, 1995, at about 8:00 p.m., Rogelio Pader (petitioner) appeared at the gate of Atty. Benjamin C. Escolango’s house in Morong, Bataan and shouted the words, "putang ina mo Atty. Escolango. Napakawalanghiya mo!"
At the time, Atty. Escolango was conversing with his political leaders and was a candidate for vice mayor in the May 8, 1995 elections. The words uttered embarrassed and dumbfounded him.
On June 16, 1995, Atty. Escolango filed a complaint for grave oral defamation against Pader before the Municipal Trial Court in Bagac, Bataan. Pader pleaded not guilty.

After trial, on October 30, 1997, the Municipal Circuit Trial Court, Bagac, Bataan convicted Pader of grave oral defamation under Article 358 of the Revised Penal Code.
The court sentenced Pader to one month and one day to one year imprisonment, considering extenuating circumstances of drunkenness.
Pader was also ordered to pay P20,000 as moral damages to the offended party, considering his social and professional stature.

On March 4, 1998, the Regional Trial Court, Branch 1, Balanga, Bataan affirmed the conviction and the penalty, maintaining the award of moral damages.
On May 3, 1999, the Court of Appeals affirmed the conviction but modified the penalty to a prison term of four months and one day of "arresto mayor," reducing the sentence from the prior range.

Petitioner filed a petition for review on certiorari questioning whether the offense committed was slight or serious oral defamation.
The case hinged on the nature of the defamatory words, context, relationship between parties, and petitioner’s state at the time of utterance.

Whether petitioner’s utterance constitutes grave oral defamation or slight oral defamation under Article 358 of the Revised Penal Code.

Whether the penalty of imprisonment and the award of moral damages as imposed are proper given the circumstances of the case.