Case Digest (G.R. No. L-17663)
Facts:
The People of the Philippines v. Isauro Santiago, G.R. No. L-17663, May 30, 1962, the Supreme Court, Concepcion, J., writing for the Court.The information charged defendant Isauro Santiago with libel for statements allegedly uttered on October 5, 1959, during a political speech at 392 Fraternal, Quiapo, Manila, delivered through "the medium of an amplifier system" before about one hundred persons. The alleged utterances called Mayor Arsenio H. Lacson "Arsenio Hayop Lacson, pinakawalang hiyang Alkalde" and accused him of having raped a woman at the Aroma Cafe and another City Hall employee at the Shellborne Hotel. The information framed the offense under Article 355 (libel) read with Article 353 (definition of libel) of the Revised Penal Code.
Defendant moved to quash the information on the ground that the charged conduct was not libel but oral defamation under Article 358 of the Revised Penal Code, which prescribes six months' prescription, and thus the offense had prescribed because the information was filed on August 11, 1960. The Court of First Instance of Manila granted the motion and quashed the information, imposing costs de officio. The prosecution appealed to the Supreme Court, arguing that publication through an "amplifier system" falls within Article 355'...(Subscriber-Only)
Issues:
- Are the alleged statements delivered through an "amplifier system" libel under Article 355 (in relation to Article 353) or oral defamation under Article 358 of the Revised Penal Code?
- If the statements constitute oral defamation, had the crime prescribed before the f...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)