G.R. No. L-62449 - People vs. Sesbreno

The City Fiscal's Office of Cebu City filed an Information on March 4, 1981, charging Atty. Raul H. Sesbreno with libel.
The alleged libelous statements were contained in a pleading titled "PLAINTIFF’S REPLY TO DEFENDANTS OPPOSITION DATED MARCH 9th dated March 11, 1980" filed in Civil Case No. R-18181 entitled "HEIRS OF ROBERTO CENIZA, ET AL. V. DANIELA CENIZA UROT," pending before Branch IV of the Court of First Instance of Cebu, 14th Judicial District.

On March 5, 1981, Atty. Sesbreno filed a Motion to Quash the Information, arguing that the allegedly libelous statements were contained in a court pleading and were thus protected under the doctrine of absolutely privileged communications.
The court a quo granted the motion, quashing the information and dismissing the case for lack of cause of action.
The Court of Appeals later certified the case to the Supreme Court for a pure question of law.

During the initial formal hearing of Civil Case No. R-18181 on February 7, 1980, Atty. Ramon B. Ceniza, counsel for the defendant, filed an Urgent Motion to Transfer Hearing, which was initially denied receipt by Atty. Sesbreno, counsel for the plaintiff.
Based on Atty. Sesbreno’s representation, the court granted the postponement but ordered Atty. Ceniza to reimburse Atty. Sesbreno’s clients for expenses incurred.
Atty. Ceniza filed a motion for reconsideration showing evidence of receipt of the notice by Atty. Sesbreno’s office. The court granted reconsideration and ordered Atty. Sesbreno to show cause for possible contempt due to misrepresentation.
Atty. Sesbreno filed a motion for reconsideration with a counter-motion for contempt against Atty. Ceniza for reneging on reimbursement and for using dilatory tactics.
Atty. Ceniza responded with an Opposition, charging Atty. Sesbreno with misrepresentation, prevarication, and telling "a barefaced and documented lie."
Atty. Sesbreno then filed the "REPLY," which was the subject of the libel accusation.

Whether the alleged defamatory statements made by Atty. Sesbreno in his court pleading are protected under the doctrine of absolutely privileged communications.
The scope and limitations of the doctrine of privileged communications in judicial proceedings, particularly as applied to statements made in pleadings.
The propriety of the language used by lawyers in pleadings and the ethical standards expected of members of the Bar.