G.R. No. L-20754 - People vs. Sario

Several informations for the crime of oral defamation were filed before the Court of First Instance of Quezon (Guniaca branch).
The informations charged four defendants: Carmen Sario, Dulce Sario, Asuncion Requiron, and Francisco Sario, each being accused in different criminal cases (identified by multiple case numbers, later consolidated into respective G. R. Nos.).
The alleged offense in every information involved utterances directed to complainant Ester Pena.

The accused are charged with having made oral imputation that Ester Pena was a “mangkukulam” (witch, one who practices witchcraft) or had associations with witchcraft.
Specific allegations include:

Carmen Sario allegedly declared Ester Pena to be a “mangkukulam” and further imputed that she was responsible for witchcraft causing the death of three persons (as seen in G. R. Nos. L-20754 and L-20759).
Dulce Sario was accused in two separate informations (G. R. Nos. L-20755 and L-20758) of calling Ester Pena a witch and attributing hereditary or learned characteristics of witchcraft to her and her descendants.
Asuncion Requiron was charged with uttering statements that directly associated Ester Pena with the practice of witchcraft (G. R. No. L-20756).
Francisco Sario was similarly charged of an utterance that implicated Ester Pena in witchcraft-related actions (G. R. No. L-20757).

Prior to arraignment, the accused filed a joint motion to quash, arguing that the allegations in the informations did not constitute any offense punishable by law.
The lower court granted the motion to quash, prompting the prosecution to appeal the decision to the Court of Appeals, which subsequently certified the cases to the Supreme Court.
The central focus became whether the facts alleged in each information constituted a punishable offense under the Revised Penal Code.

The case revolves around the interpretation of defamatory imputation under Article 353 of the Revised Penal Code.
The terms “mangkukulam” and “aswang” were central to the case:

“Mangkukulam” is defined in the context as a witch, or one who practices witchcraft, implying association with sorcery or dark arts.
“Aswang” is understood as a term referring to an injurious and evil character with supernatural connotations, often used as a label of contempt and discredit.

Whether the facts alleged in each of the six informations constitute a punishable offense under the Revised Penal Code.

Does the oral utterance of defamatory statements, which accuses a person of being a witch or engaging in witchcraft, satisfy the elements of oral defamation and libelous imputation as provided by law?
Is it proper to apply defamatory imputations under Article 353 of the Revised Penal Code even if the accused asserts that, in modern society, belief in witches and witchcraft has diminished?
Whether the argument that oral statements would not be considered “libel” if they were not written holds merit, in view of existing legal principles regarding oral defamation (slander).