Facts:

• The case involves the People of the Philippines (plaintiff-appellant) and Sylvia Abonitalla de Ravidas (defendant-appellee).
• On July 8, 1961, Sylvia was charged with grave oral defamation in Criminal Case No. 6621 in the Municipal Court of Cagayan de Oro.
• The charge stemmed from a sworn complaint filed by Generosa Cariaga, the offended party.
• After pleading not guilty, the trial commenced with evidence presented by both sides.
• On June 30, 1962, the lower court dismissed the case, stating that Generosa Cariaga lacked the legal capacity to sign the complaint.
• The court cited Article 7, Section 24, Paragraph (f) of Republic Act No. 521, which requires the City Attorney to investigate crimes and prepare complaints.
• The court concluded that grave oral defamation was not a private crime and could only be validly prosecuted if signed by the City Attorney or an assistant.
• The dismissal was influenced by a similar ruling in Criminal Case No. 6612.
• The City Attorney of Cagayan de Oro, through the Solicitor-General, appealed the dismissal, claiming the lower court misinterpreted the law.

Issue:

• (Unlock)

Ruling:

• The Supreme Court ruled in favor of the plaintiff-appellant, overturning the lower court's dismissal.
• The Court determined that the complainant had the legal standing to file the c...(Unlock)

Ratio:

• The Supreme Court highlighted that the lower court misinterpreted the City Charter and the Revised Penal Code.
• The Court clarified that while the City Attorney is responsible for investigating and preparing complaints, this does not prevent the offended party from filing a defamation complaint.
• Article 360 of the Revised Penal Code allows for criminal actions for defama...continue reading