Case Digest (G.R. No. 225010)
Facts:
Eliseo Soriano v. People of the Philippines, G.R. No. 225010, November 21, 2018, the Supreme Court First Division, Tijam, J., writing for the Court.
Petitioner Eliseo Soriano (petitioner) was indicted for libel in two Informations arising from a taped radio broadcast of his program "Ang Dating Daan" aired on July 31, 1998. In Criminal Case No. IR-4848 (Information filed January 15, 1999) the accusation alleged that petitioner publicly branded the leader and members of the Jesus Miracle Crusade, International Ministry (JMCIM) with insulting epithets (e.g., "bulaang propeta," "tarantado," "gago") and thereby caused dishonor, discredit and ridicule to the group. In Criminal Case No. IR-5273 (Information filed June 9, 2000) the accused statements were charged as directed at Evangelist Wilde E. Almeda, head of JMCIM, imputing that he was an "idiot," "bulaang propeta," and an "apostle of demons," thereby attacking his honesty, integrity and reputation.
Petitioner pleaded not guilty in both cases and posted cash bonds. During trial the prosecution presented several witnesses (Eudes Cuadro, Joel Cortero, Jerry Cabanes, Liza Martinez in IR-5273; Joel Cortero in IR-4848). The defense presented one witness, Marlon Igana. Petitioner moved a Demurrer to Evidence on December 22, 2008, which the Regional Trial Court (RTC) denied by Resolution dated January 6, 2008.
The RTC of Iriga City, Branch 60, after trial rendered a Consolidated Judgment dated June 8, 2012 finding petitioner guilty of libel in both cases and sentencing him to pay a fine of P6,000.00 for each case pursuant to Administrative Circular No. 08-2008 with subsidiary imprisonment in case of insolvency; no civil damages were awarded. Petitioner appealed to the Court of Appeals (CA).
The CA, in CA‑G.R. CR No. 35052, affirmed the RTC in a Decision dated August 17, 2015 and issued a Resolution dated May 18, 2016; the...(Subscriber-Only)
Issues:
- Did the prosecution prove the elements of libel beyond reasonable doubt — specifically, were the statements defamatory and did they cause dishonor or discredit to the complainants?
- Was there actual malice in petitioner’s statements so as to sustain a libel conviction?
- Were the alleged defamatory statements sufficiently published to and identifiable as imputations against a specific person or persons?
- Did petitioner lack knowledge or consent in the publication of the alleged defamatory statement?
- Do petitioner’s statements enjoy constitutional protection as religious expression, such that con...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)