Facts:

• Victor Galeza was accused of criminal libel for writing two letters to the provincial treasurer of Sorsogon.
• The letters accused Bonifacio Baeza, the municipal treasurer of Irocin, of official misconduct.
• The first letter, dated June 16, 1914, alleged a shortage of P1,996 in municipal funds from 1908 to 1909, claiming misappropriation by Baeza and other employees.
• The provincial treasurer sent a deputy to investigate, who found uncollected market rentals amounting to P1,886.33 for the last three quarters of 1908 and all of 1909.
• Galeza's second letter, dated July 26, 1914, reiterated his accusations and provided additional details, urging further investigation.
• The provincial treasurer conducted a second investigation, corroborating the deputy's findings and some of Galeza's additional claims.
• Despite these findings, the lower court found Galeza guilty of libel, concluding that his charges were made maliciously and without sufficient grounds.
• Galeza appealed the decision.

Issue:

• (Unlock)

Ruling:

• The Supreme Court ruled that the communication made by Victor Galeza to the provincial treasurer was qualifiedly privileged.
• The Supreme Court found that the charges ...(Unlock)

Ratio:

• The Supreme Court held that it is the right and duty of a citizen to report any misconduct by public officials to those charged with their supervision.
• Such communications are considered qualifiedly privileged, meaning the author is not guilty of libel unless it is shown that the charges were made maliciously and without reasonable grounds.
• The Court noted that Galeza's letters were addressed to the provincial treasurer, an official with jurisdiction to investigate the charges, and thus there was no undue publication.
• The Court found that the information Galeza had obtained was sufficient to ...continue reading