Facts:

• On March 28, 1955, Ernesto A. Bernabe, special counsel for Pasay City, filed a complaint against Lydia Padilla.
• The complaint alleged a violation of Article 364 of the Revised Penal Code for spreading defamatory rumors about Fausta Bravo.
• Padilla was accused of claiming that Bravo was having an affair with a man named Sangalang.
• Padilla filed a motion to quash the information, arguing:
  • The special counsel lacked authority to file the information.
  • The information charged more than one offense.
• The special counsel opposed Padilla's motion.
• On April 25, 1955, the Municipal Court dismissed the information, stating it was not initiated by a complaint from the offended party as required by Article 360, paragraph 4.
• The Court of First Instance upheld the dismissal upon appeal, prompting the special counsel to appeal to a higher court.

Issue:

• (Unlock)

Ruling:

• The Supreme Court affirmed the lower court's order dismissing the information against Lydia Padilla.
• The Court concluded that the special counsel lacked the authority to file the information.
• The allegatio...(Unlock)

Ratio:

• The Supreme Court noted that the information did not solely allege a violation of Article 364 related to defamation through intrigue.
• It included serious allegations of adultery against Fausta Bravo, which falls under a different legal framework.
• Article 360, paragraph 4 of the Revised Penal Code requires that a criminal action for d...continue reading