Case Digest (G.R. No. 13540)
Facts:
United States v. Salvador A. Eguia and Sebastian Lozano, G.R. No. 13540. October 24, 1918, the Supreme Court, Malcolm, J., writing for the Court.The United States, acting through the Fiscal of the City of Manila, filed an information charging Salvador A. Eguia and Sebastian Lozano with conspiring to threaten Maria S. Tuason with publication of certain letters in the weekly newspaper The Independent unless she paid P4,000 — a prosecution under section 10 of the Libel Law (Act No. 277). The information alleged the defendants threatened publication and promised to prevent the publication in return for money.
Both defendants demurred to the information on grounds that (1) the facts did not constitute a crime, (2) the information failed to set out the alleged libelous letters, and (3) the information was duplicitous because it charged both a threat to publish and an offer to prevent publication. The trial court overruled the demurrers, granted the defendants’ requests for separate trials but rendered a single judgment convicting both. The trial court sentenced Eguia to four months imprisonment and P500 fine, and Lozano to two months imprisonment and P400 fine, each to pay one-half the costs.
On appeal to the Supreme Court the principal questions were the sufficiency of the information, the sufficiency of the evidence to establish guilt under section 10 of Act No. 277, and the adequacy of the penalties imposed. The factual record at trial showed that Mrs. Tuason had entrusted a post‑office box key to Eguia while he boarded at her house; amorous letters addressed to a Dr. Harmer were taken or otherwise obtained and then used as the basis for a blackmail scheme. An intermediary, Villaba, and Mrs. Tuason cooperated with the police to set a rendezvous; Lozano appeared with the letters, accepted marked money, and was arrested; letters, a toy pistol, and a negative of a letter were found on him. ...(Subscriber-Only)
Issues:
- Is the information charging a threat to publish a libel or an offer to prevent publication under section 10 of Act No. 277 sufficient when it does not set out the libelous matter in haec verba?
- Did the evidence prove the defendants guilty beyond reasonable doubt of the offense described in section 10 of Act No. 277?
- Were the penalties imposed by the trial court adequate, or sh...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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