Case Digest (G.R. No. L-32815)
Facts:
People of the Philippines v. Hon. Amador E. Gomez and Vicente Aceveda, G.R. No. L-32815, June 25, 1980, Supreme Court First Division, De Castro, J., writing for the Court (Teehankee, Chairman, Makasiar, Fernandez and Guerrero, JJ., concurring; Melencio-Herrera, J., took no part).The prosecution charged Vicente Aceveda with libel in Criminal Case No. 18204 before the Court of First Instance of Rizal for a letter dated July 12, 1968 that Aceveda allegedly distributed and posted on the bulletin board of his employer, Muller & Phipps (Manila) Ltd., and circulated in unsealed copies. The information quoted the letter at length and alleged that Aceveda acted "with malicious intent of impeaching the honesty, virtue, integrity and reputation" of complainant Edgardo M. Biasbas, naming him and accusing him of misrepresentation, inefficiency and other derogatory conduct.
On December 18, 1968, Aceveda filed a motion to quash the information on two grounds: (1) the facts alleged do not constitute an offense, and (2) the letter was a privileged communication under Article 354 of the Revised Penal Code. The prosecution did not file a written opposition despite being ordered to do so by the trial court. On April 15, 1969, Presiding Judge Amador E. Gomez issued an order granting the motion and dismissing the information as "well founded and meritorious," cancelling the bail bond. The order did not state the court's reasons or indicate which ground (or both) supported dismissal.
The Solicitor General, representing the People, appealed the dismissal to the Supreme Court on August 29, 1969. The Court reviewed whether the dismissal by motion to quash was proper, whether the statements char...(Subscriber-Only)
Issues:
- Did the trial court properly grant the motion to quash and dismiss the information for libel?
- Do the facts alleged in the information constitute the crime of libel?
- Is the asserted privileged character of the letter a proper ground for dismissal by a motion to quash?
- Does the prosecution's failure to file a written opposition to the motion to quash constitute lack ...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)