Case Digest (G.R. No. 200148)
Facts:
In Ramon A. Syhunliong vs. Teresita D. Rivera (G.R. No. 200148, June 4, 2014), petitioner Ramon A. Syhunliong, president of BANFF Realty and Development Corporation, filed a criminal complaint for libel against his former Accounting Manager, Teresita D. Rivera. Rivera had been employed at BANFF since September 2002, tendered her resignation effective February 3, 2006, and remained until March to turn over documents. In early April 2006, after Jennifer Lumapas, her successor, informed her that Syhunliong withheld her final salaries and incentives, Rivera sent two text messages from BANFF’s official phone expressing her “sufferings” over delayed payment and stating, “God bless ras … sana yung pagsimba niya, alam niya real meaning.” Pending resolution of Rivera’s labor complaint before the NLRC, Syhunliong filed an information for libel on June 21, 2007 under Article 353 of the Revised Penal Code. Rivera moved to quash, arguing absence of a defamatory imputation, malice, and that hCase Digest (G.R. No. 200148)
Facts:
- Parties and Employment
- Ramon A. Syhunliong (petitioner) is President of BANFF Realty and Development Corporation and has interests in construction, restaurant, and hospital businesses. Teresita D. Rivera (respondent) was BANFF’s Accounting Manager from September 2002 with a monthly salary of ₱30,000.
- Rivera tendered her resignation effective February 3, 2006, but continued working until March 2006 to turn over documents to her successor, Jennifer Lumapas.
- Delay in Release of Pay and Text Messages
- In April 2006, Rivera requested from Lumapas the payment of her remaining salaries, benefits, and incentives. Lumapas advised that Rivera’s incentive pay was on hold by Syhunliong and her salary check remained unsigned.
- On April 6, 2006, Rivera sent two text messages to BANFF’s company phone (held by Lumapas), complaining of her “sufferings” in collecting her last pay, invoking God’s blessing, and urging Syhunliong to understand “the real meaning” of church attendance.
- Labor Case and Libel Information
- December 2006: Rivera filed a labor complaint with the NLRC for underpaid salaries, 13th–16th month pay, incentives, gratuities, and tax refund totaling ₱698,150.48.
- April/June 2007: Syhunliong filed an information for libel against Rivera, alleging the April 6, 2006 text messages were malicious publications imputing a defect in his character. Rivera moved to quash the information on jurisdictional and substantive grounds.
- RTC and CA Proceedings
- December 4, 2008 and June 18, 2009: The RTC of Quezon City, Branch 84, denied Rivera’s Motion to Quash and her motion for reconsideration, finding probable cause and holding that privileged-communication and malice issues are for trial.
- July 11, 2011 Decision and January 6, 2012 Resolution: The Court of Appeals granted Rivera’s petition for certiorari, dismissed the libel information for lack of defamatory imputation and as qualified privileged communication, and denied Syhunliong’s motion for reconsideration.
Issues:
- Procedural Issues
- Whether the denial of a Motion to Quash may be assailed via certiorari.
- Whether Rivera’s voluntary arraignment before her Motion to Quash was resolved precludes her challenge.
- Substantive Issues
- Whether the Court of Appeals may review the RTC and Prosecutor’s finding of probable cause.
- Whether the facts charged in the information constitute the crime of libel.
- Whether the text messages are qualified privileged communications and thus subject only to defense at trial, not to Motion to Quash.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)