Case Digest (G.R. No. L-15958)
Facts:
The People of the Philippines v. Leon Ramos, et al., G.R. No. L-15958. May 31, 1961, the Supreme Court En Banc, Labrador, J., writing for the Court.
This criminal appeal arose from a complaint filed by Aurora Padilla accusing Leon Ramos, Francisca de Ramos, Avelina Ramos and one “Intsik Ramos” of grave slander by deed: that the accused, conspiring together, publicly insulted her with the words “Heto ang iyo, puta ka, malandi ka,” then attacked, boxed, slapped and pulled her hair. The complaint for slander by deed was lodged in the Court of First Instance of Nueva Ecija, presided over by Judge Jose N. Leuterio.
Before that complaint reached the CFI, a separate information had already been filed by the same complainant in the Justice of the Peace Court of Penaranda, Nueva Ecija, charging the same accused with slight physical injuries arising from an assault upon Aurora Padilla; the Justice of the Peace information did not expressly allege the utterance of the insulting words. The Court of First Instance dismissed the complaint for grave slander by deed on the ground that prosecution was barred by the constitutional protection against double jeopardy, reasoning that the earlier prosecution for slight physical injuries arose from the same factual incident and that an accused should be shielded against multiple prosecutions based on a single act (citing People v. Carmen, 88 Phil. 51).
The Solicitor General, acting for The People of the Philippines as plaintiff-appellant, appealed the CFI’s dismissal to the Supreme Court....(Subscriber-Only)
Issues:
- Does the constitutional prohibition against double jeopardy bar prosecution for slander by deed when an earlier prosecution for slight physical injuries arising from the same episode has already been filed?
- If not, are slander by deed and slight physical injuries the same offense such that a conviction or prosecution for one w...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)