Case Digest (G.R. No. 225010) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On January 15, 1999, Eliseo Soriano, the anchorman of the religious radio program “Ang Dating Daan” on DZAL in Iriga City, was charged in Criminal Case No. IR-4848 with willfully and maliciously airing a taped broadcast on July 31, 1998 that branded the leader, pastors, and members of the Jesus Miracle Crusade International Ministry (JMCIM) with epithets such as “BULAANG PROPETA,” “TARANTADO,” “GAGO,” and “PASTOR NG DEMONYO,” thereby imputing dishonor, discredit, or contempt to them. A second information for libel was filed on June 9, 2000 in Criminal Case No. IR-5273, accusing petitioner of similarly defamatory statements against Evangelist Wilde E. Almeda, head of JMCIM, in the same broadcast. Soriano pleaded not guilty in both cases and posted cash bonds. The prosecution, presenting five witnesses in total, and the defense, with one witness, underwent trial before Branch 60 of the Regional Trial Court (RTC) of Iriga City. Soriano’s demurrer to evidence was denied on January 6 Case Digest (G.R. No. 225010) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Indictments and Informations
- Eliseo Soriano, as anchorman of the radio program “Ang Dating Daan” on DZAL Iriga City, was charged in two separate Informations with libel:
- Criminal Case No. IR-4848 (filed January 15, 1999) for allegedly airing on July 31, 1998 taped statements branding the leaders, pastors, and members of the Jesus Miracle Crusade International Ministry (JMCIM) as “BULAANG PROPETA,” “TARANTADO,” “GAGO,” and “PASTOR NG DEMONYO,” imputations alleged to dishonor, discredit, and expose them to public ridicule.
- Criminal Case No. IR-5273 (filed June 9, 2000) for airing the same date and program taped statements against Evangelist Wilde E. Almeda, head of JMCIM, calling him “bulaang propeta,” “idiot,” and “apostle of demons,” to expose him to public hatred, contempt, and ridicule.
- Trial and Lower Court Rulings
- Petitioner pleaded not guilty; posted cash bonds for provisional liberty in both cases.
- Prosecution witnesses: four in IR-5273 (Eudes Cuadro, Joel Cortero, Jerry Cabanes, Liza Martinez) and one in IR-4848 (Joel Cortero). Defense witness: Marlon Igana.
- Petitioner’s demurrer to evidence was denied by the RTC on January 6, 2008.
- On June 8, 2012, the RTC rendered a consolidated judgment finding Soriano guilty in both cases, imposing fines of ₱6,000 per case (subsidiary imprisonment in case of insolvency) and no civil indemnity.
- The Court of Appeals, in its Decision dated August 17, 2015 and Resolution dated May 18, 2016, affirmed the RTC’s convictions in CA-G.R. CR No. 35052.
Issues:
- Whether the prosecution proved beyond reasonable doubt all requisites of libel, specifically:
- That petitioner’s statements caused dishonor or discredit to the complainant.
- That the statements were made with malice or ill will.
- That there was an identifiable victim in the libelous imputations.
- Whether petitioner knowingly consented to the publication of the alleged libelous statements.
- Whether upholding the conviction unduly curtails the freedom of expression and religious belief guaranteed by the Constitution.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)