Case Digest (G.R. No. 120715)
Facts:
Fernando Sazon y Ramos v. Hon. Court of Appeals and People of the Philippines, G.R. No. 120715, March 29, 1996, Supreme Court En Banc, Hermosisima, Jr., J., writing for the Court.Petitioner Fernando Sazon and private complainant Abdon Reyes were residents of PML Homes, members of the homeowners association PML-Parang Bagong Lipunan Community Association, Inc. (PML-BLCA). The association published a monthly newsletter, the PML-Homemaker, of which petitioner was the editor. On December 11, 1983, the association held elections in which Sazon won a seat on the board and was elected president by the board; Reyes lost.
After the election Reyes filed a written protest with the Estate Management Office of the Home Financing Corporation (EMO-HFC) on January 16, 1984, alleging procedural defects in the election (including lack of authority to call the election, absence of quorum, and insufficient notice). Reyes also circulated a letter to co-homeowners on January 18, 1984, urging them not to recognize the new board. EMO-HFC ordered a referendum supervised by it; Reyes notified homeowners of the meeting with EMO-HFC representatives.
Shortly thereafter homeowners found a leaflet titled "PML Scoop" bearing the headline "Supalpal si Sazon" and graffiti reading "Sazon, nasaan ang pondo ng simbahan?" on subdivision walls; there was no proof who authored those items. Believing Reyes responsible, petitioner published a February 10, 1984 article in the PML-Homemaker accusing Reyes of deceit and other misconduct, employing words and phrases such as "mandurugas," "patuloy na kabulastugan," "mastermind sa paninirang puri," and urging vigilance against him. Reyes filed a libel complaint; an Information was filed on May 25, 1984 in the Regional Trial Court, Branch 161, Pasig City (Criminal Case No. 58939).
On March 18, 1992 the trial court convicted Sazon of libel and sentenced him to imprisonment (minimum four months and one day arresto mayor to maximum two years, four months and one day prision correccional) and fined P200 pursuant to the Revised Penal Code provisions invoked; costs were imposed. Petitioner appealed to the Court of Appeals (Special Third Division), which on June 19, 1995 dismissed the appeal and affirmed the trial court's conviction. Petitioner then filed a petition for review on certiorari under Rule 45 of the Rules of Court seeking reversal of the Court of Appeals' decision, principally arguing (1) that the article was a privi...(Subscriber-Only)
Issues:
- Was the questioned article in the PML-Homemaker a privileged communication that would negate malice and render the publication non-actionable?
- Were the words used in the article defamatory such that they satisfied the requisites of libel under the Revised Penal Code?
- If conviction is warranted, is the sentence imposed appropriate or should ...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)