Title
Pueblo de las Islas Filipinas vs. Stanley J. Willimont
Case
R. G. No. 39196
Decision Date
Nov 27, 1933
Stanley J. Willimont was acquitted by the Supreme Court after being convicted for verbally insulting a traffic police officer, as the court found that the insult lacked the required public exposure to be considered defamation under Article 358 of the Revised Penal Code.
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Case Digest (R. G. No. 39196)

Facts:

  • Incident occurred on the morning of August 24, 1932, in Manila.
  • Appellant: Stanley J. Willimont.
  • Altercation with traffic policeman Leon Somera at Ayala Boulevard and Taft Avenue.
  • Willimont believed Somera was negligent and threatened to report him.
  • Willimont returned and insulted Somera: "What a hell you are, you are a monkey traffic cop."
  • Charged in Municipal Court of Manila for violating Article 358 of the Revised Penal Code (oral defamation).
  • Convicted and fined P10 plus costs.
  • Appealed to the Court of First Instance, which upheld the ruling.
  • Further appealed to the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court reversed the lower courts' decisions.
  • Stanley J. Willimont was acquitted.
  • ...(Unlock)

Ratio:

  • Willimont directed the words "What a hell you are, you are a monkey traffic cop" at Somera.
  • Prosecution admitted no third party was present to hear the words.
  • Article 353 of the Revised Penal Code requires publi...continue reading

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