Case Digest (G.R. No. 113539)
Facts:
In Rodolfo R. Vasquez v. Court of Appeals, Regional Trial Court of Manila, Branch 40, and the People of the Philippines (G.R. No. 118971, September 15, 1999), petitioner Rodolfo R. Vasquez, a Tondo Foreshore Area resident and spokesperson for 38 families, publicly accused their Barangay Chairman Jaime Olmedo of landgrabbing government lots through collusion with National Housing Authority (NHA) officials, as well as involvement in illegal gambling and theft of fighting cocks. On April 22, 1986, a newspaper article in Ang Tinig ng Masa reported Vasquez’s statements following interviews at the NHA compound. Olmedo filed a libel complaint before the Manila RTC, alleging malicious intent and false imputations. After a trial in 1992, the RTC convicted Vasquez of libel under Article 353 of the Revised Penal Code and fined him ₱1,000. The Court of Appeals affirmed. Vasquez then petitioned for review on certiorari before the Supreme Court.Issues:
- Did the prosecution prove that Vasq
Case Digest (G.R. No. 113539)
Facts:
- Parties and Context
- Petitioner Rodolfo R. Vasquez, resident and spokesperson of 38 families in Tondo Foreshore Area, complained of alleged misconduct by Barangay Chairman Jaime Olmedo.
- Complainants met with NHA officials in April 1986 and were interviewed by reporters at the NHA compound.
- Publication of Allegations
- On April 22, 1986, Ang Tinig ng Masa published an article attributing to Vasquez statements that Olmedo, in conspiracy with NHA officials, grabbed government lots (totaling some 487.87 m²) and engaged in illegal gambling, theft of chickens, and attempted murder.
- Article quoted Vasquez as saying the lands were government-owned, titles irregularly issued, and past complaints— including an attempt on his life—were dismissed.
- Criminal Complaint and Trial
- Olmedo filed libel charges in the RTC of Manila; information quoted portions of the article and alleged false, malicious imputations harming his reputation.
- At trial, prosecution witnesses were Olmedo and Neighbor Florentina Calayag; defense witnesses included residents of Tondo and Vasquez himself.
- On May 28, 1992, RTC convicted Vasquez of libel, imposing a ₱1,000 fine; the CA affirmed on February 1, 1995.
- Supreme Court Review
- Vasquez petitioned for review, arguing wrongful attribution as source, lack of malice, and successful proof of truth.
- Supreme Court granted review, finding no dispute on facts and focusing on legal issues of libel, truth defense, and public‐official exception.
Issues:
- Whether the Court of Appeals erred in identifying Vasquez as the sole source of the published statements.
- Whether the CA erred in holding Vasquez responsible for imputations against Olmedo.
- Whether malice was properly presumed and never rebutted.
- Whether the trial courts failed to appreciate Vasquez’s defense of truth.
- Whether all elements of libel under Art. 353, RPC, were proven beyond reasonable doubt.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)