G.R. No. L-17663 - People vs. Santiago

On or about October 5, 1959, in Manila, Philippines, defendant Isauro Santiago allegedly committed acts constituting defamation.
During a political speech delivered at 392 Fraternal, Quiapo, before a crowd of approximately one hundred persons, defendant made defamatory statements against Mayor Arsenio H. Lacson.
The specific defamatory statement accused the mayor of having raped a woman at the Aroma Cafe and another City Hall employee at the Shellborne Hotel, thereby imputing a crime and besmirching his name and reputation.
The statement was made through the medium of an amplifier system, which purportedly contributed to the public nature and dissemination of the remarks.

It is alleged that the defendant’s statement was delivered with malice, lacking any justifiable motive.
The purpose of the statement was to injure the name and reputation of Mayor Lacson, effectively exposing him to public hatred, contempt, and ridicule.
The manner and context of the delivery emphasize its public nature and the malicious intent underlying the communication.

Defendant Isauro Santiago moved to quash the information on the ground that the crime charged was oral defamation, not libel.
The argument rested on the prescription issue: oral defamation was alleged to have prescribed six (6) months after its commission (i.e., by April 5, 1960), whereas the information was filed on August 11, 1960.
The Court of First Instance of Manila granted the motion to quash the information due to the lapse of the prescribed period, ordering costs de officio.
The People of the Philippines, through the prosecution, subsequently appealed this decision.

Article 358 (Slander): Punishes oral defamation with penalties such as arresto mayor or prision correctional, depending on the severity.
Article 355 (Libel by means of writings or similar means): Specifies penalties for libel committed by writing, printing, and similar permanent mediums, including a range of fines and imprisonment.
Article 353 (Definition of Libel): Defines libel as the public and malicious imputation of a crime, a vice, or defect.

A central point of contention was whether the use of an "amplifier system" could be analogized to a medium like radio, which is characterized by its permanent nature in transmitting messages.

The prosecution argued that the amplifier system used bore similarity to the "radio" mentioned in Article 355, thereby elevating the offense to libel.
The defendant countered that, unlike radio—which transmits via electromagnetic waves without conducting wires—the amplifier system involves conducting wires and does not ensure the permanence associated with libel.
Case precedents were cited to illustrate the distinction between permanent publications (such as manuscripts read on radio) and ad hoc oral remarks.

Whether the defamatory statements made by the defendant, as transmitted via an amplifier system during a public political speech, constitute the crime of oral defamation under Article 358 of the Revised Penal Code or the crime of libel under Article 355 in relation to Article 353.

Does the medium of an amplifier system qualify as "writing, printing, lithography, engraving, radio, phonograph, painting, theatrical exhibition, cinematographic exhibition, or any similar means" that confer permanence, thereby warranting the classification of the offense as libel?
Should the element of permanence, which is a decisive factor in differentiating libel from oral defamation, be attributed to the defendant's method of dissemination?
What is the impact of the prescription period on the categorization of the offense, considering that the alleged defamatory act occurred more than six months prior to the filing of the information?