Case Digest (G.R. No. 200148)
Facts:
Ramon A. Syhunliong v. Teresita D. Rivera, G.R. No. 200148, June 04, 2014, the Supreme Court First Division, Reyes, J., writing for the Court.Ramon A. Syhunliong (petitioner) is the private complainant and president of BANFF Realty and Development Corporation; Teresita D. Rivera (respondent) is a former accounting manager of BANFF. Rivera resigned effective February 3, 2006 but continued until March 2006 to effect turnover to her successor, Jennifer Lumapas. After attempts to collect unpaid salaries and benefits, Rivera sent two brief text messages on April 6, 2006 to BANFF’s company cellular phone held by Lumapas complaining about delay in payment and stating, among other things, “God bless ras. Sana yung pagsimba niya, alam niya real meaning.” Rivera subsequently filed a labor complaint before the NLRC for unpaid salaries and benefits.
Syhunliong filed criminal charges for libel against Rivera; the information is dated June 21, 2007 (the record contains conflicting references as to the complaint-filing date, but the information filed in RTC bears that date). Rivera moved to quash the information, arguing the messages expressed legitimate grievance and lacked malice and public imputations necessary for libel; she also asserted privilege and, later before this Court, prescription. Rivera pleaded not guilty at arraignment on October 11, 2007.
The Regional Trial Court (Quezon City, Branch 84) denied Rivera’s motion to quash in an Order dated December 4, 2008 and denied reconsideration on June 18, 2009, concluding the issues raised were evidentiary and that probable cause had been found during preliminary investigation. Rivera filed a petition for certiorari before the Court of Appeals (CA). The CA (Penned by Associate Justice Mario L. Guarina III) granted Rivera’s petition and ordered dismissal of the libel information in a Decision dated July 11, 2011, holding the text message was not defamatory and, additionally, constituted a qualified privileged communication under Article 354 of the Revised Penal Code; the CA denied Syhunliong’s motion for reconsideration in a Resolution dated January 6, 2012.
Syhunliong filed the present petition for review before the Supreme Court seeking to set aside the CA’s decision, raising procedural and substantive issues (including whether the denial of a motion to quash is properly assailable by certiorari, whether Rivera’...(Pro-only)
Issues:
- May the denial of a motion to quash an information be validly assailed by certiorari before the Court of Appeals?
- Does an accused waive a motion to quash the information by voluntarily submitting to arraignment and pleading not guilty?
- May the Court of Appeals review the trial court’s and prosecutor’s finding of probable cause?
- Do the facts charged in the information and the content of the text messages constitute the crime of libel?
- Were the text messages qualified ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)