Facts:

On March 28, 1955, Ernesto A. Bernabe, who served as the special counsel for Pasay City, filed a complaint against Lydia Padilla for allegedly violating Article 364 of the Revised Penal Code. The information stated that between February 2 and 3, 1955, in Pasay City, Padilla purportedly spread defamatory rumors about Fausta Bravo, a married woman. Specifically, it was alleged that Padilla claimed Bravo was having an affair with a man named Sangalang, who was not her husband. In response to the charges, Padilla filed a motion to quash the information, arguing two main points: first, that the special counsel lacked the authority to file the information, and second, that the information charged more than one offense. The special counsel opposed this motion. On April 25, 1955, the Municipal Court dismissed the information, stating that the case was not initiated by a complaint from the offended party, as required by...

Facts:

1. Parties Involved:

   • Plaintiff and Appellant: The People of the Philippines.
   • Defendant and Appellee: Lydia Padilla.

2. Charges and Allegations:

   • On March 28, 1955, Ernesto A. Bernabe, special counsel of Pasay City, filed an information against Lydia Padilla for violating Article 364 of the Revised Penal Code.
   • The information alleged that on or about February 2 and 3, 1955, in Pasay City, Lydia Padilla willfully and unlawfully spread rumors that Fausta Bravo, a married woman, was a paramour of Sangalang, a man not her husband, with the intent to blemish her honor and reputation.

3. Procedural History:

   • The accused filed a motion to quash the information on two grounds:
     1. The special counsel lacked authority to file the information.
     2. The information charged more than one offense.
   • The trial court dismissed the information on April 25, 1955, ruling that the case was not initiated by a complaint filed by the offended party, as required under paragraph 4, Article 360 of the Revised Penal Code.
   • The Court of First Instance sustained the dismissal, prompting the special counsel to appeal to the Supreme Court.

4. Key Legal Issue:

   • Whether the information filed by the special counsel was valid, considering the requirements under Article 360 of the Revised Penal Code.

Issue:

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Ruling:

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Ratio:

1. Jurisdictional Requirement:

   • For defamation cases involving the imputation of a crime that cannot be prosecuted de oficio (e.g., adultery), the offended party must file the complaint. This is a jurisdictional requirement under Article 360, paragraph 4, of the Revised Penal Code.

2. Nature of the Allegations:

   • The information alleged that Lydia Padilla spread rumors accusing Fausta Bravo of adultery. This imputation of adultery falls under a crime that cannot be prosecuted de oficio.

3. Legal Consequences:

   • Since the offended party did not file the complaint, the information filed by the special counsel was invalid, and the trial court lacked jurisdiction to proceed with the case.

4. Affirmation of the Trial Court's Decision:

   • The Supreme Court upheld the trial court's dismissal of the information, emphasizing the importance of complying with procedural requirements to confer jurisdiction.