G.R. No. 226454 - Ramos vs. People

An Information was filed before the Municipal Circuit Trial Court of Piat-Santo Niño, Cagayan, charging Digna Ramos with Grave Oral Defamation under Article 358 of the Revised Penal Code.
The complaint alleged that on September 17, 2003, around 4:20 PM, Ramos uttered the words "UKININAM, PUTA, AWAN AD-ADAL MO" (translated as "vulva of your mother, prostitute, illiterate") against Patrocinia R. Dumaua, thus defaming her honor and reputation.

Dumaua was watering her plants when she saw five schoolchildren throw dried leaves into her yard.
After calling their attention, the children ran towards Sto. Niño Elementary School, where Ramos worked.
Ramos allegedly came, threw dried banana leaves into Dumaua's yard, and made a provocative statement.
A quarrel followed during which Ramos allegedly uttered the defamatory words.
Orlando Baltazar and Babileo Dumaua corroborated witnessing the verbal altercation at its peak, along with onlookers.

Ramos denied uttering the defamatory remarks.
She stated she was merely passing a pathway near Dumaua’s house on the incident date.
Dumaua reportedly got angry, blamed Ramos for garbage in her yard, and threatened to bar her from using the pathway.
Ramos asked for proof of property rights, which Dumaua could not produce.
Subsequently, Ramos reported the incident and filed a grave coercion case against Dumaua at the police station.
Her husband testified that he saw Dumaua armed with stones, ready to attack Ramos, and intervened to pull Ramos away.

The Municipal Circuit Trial Court (MCTC) found Ramos guilty beyond reasonable doubt of Grave Oral Defamation and sentenced her to one year and one day to one year and eight months of prision correccional, plus moral damages of P20,000.00 and costs.
Ramos filed motions for new trial and reconsideration which were denied.

The RTC affirmed the MCTC decision entirely, holding that the prosecution proved Ramos uttered serious defamatory words.
Ramos’s denial was deemed unsubstantiated and self-serving.

The CA affirmed the conviction but modified the penalty to four months of arresto mayor minimum, up to one year and eight months of prision correccional maximum, consistent with the Indeterminate Sentence Law.
The CA ruled that the words were serious, insulting, and defamatory.
Ramos’s motion for reconsideration was denied.

Ramos filed a petition for review on certiorari before the Supreme Court contesting the CA’s affirmance.

Whether the Court of Appeals erred in upholding Ramos’s conviction for the crime of Grave Oral Defamation under Article 358 of the Revised Penal Code.