Case Summary (G.R. No. 78555)
Background of the Case
On March 12, 1984, Bulaong commenced a legal action for the recovery of a sum of money, which was assigned docket number Civil Case No. RTC-67-1, against Vicente Vistan, Leonardo Buenaventura, and Conrado Sta. Maria in the Regional Trial Court of Zambales. Subsequently, Vistan brought forth a complaint against Bulaong alleging rescission of contract with damages. The cases were consolidated and remained pending trial. Additionally, on November 21, 1984, Bulaong filed a criminal complaint for estafa against Vistan and Buenaventura in the Office of the City Fiscal of Pasay.
Filing of Libel Complaint
On January 21, 1985, both Bulaong and his counsel, de Guzman, submitted a reply-affidavit to the City Fiscal, which included statements considered libelous by Vistan and Buenaventura. The latter subsequently filed a libel complaint against Bulaong and de Guzman. Following an investigation, an information for libel was filed against the petitioners on October 11, 1985, which was later amended on July 1, 1986. The information characterized the statements made in the reply-affidavit as deliberate and malicious attempts to damage the reputations of Vistan and Buenaventura.
Motion to Quash
In response, the petitioners moved to quash the libel information on the grounds that the charges did not constitute an offense and that the filing was beyond the fiscal's authority. They argued that the reply-affidavit was necessary for the estafa case and represented absolutely privileged communication. However, this motion was opposed by the assistant city fiscal.
Trial Court’s Orders
On August 19, 1986, the Regional Trial Court of Pasay City denied the motion to quash, maintaining that the statements in Bulaong's reply-affidavit were irrelevant to the ongoing estafa case and therefore constituted malicious imputations. The court stressed that the prosecution had the right to demonstrate the alleged malice inherent in the accused's statements. The petitioners' motion for reconsideration of this order was also denied on October 17, 1986.
Court of Appeals Decision
Dissatisfied, the petitioners escalated the issue to the Court of Appeals through a petition for certiorari, prohibition, mandamus with a request for preliminary injunction. On April 13, 1987, the appellate court dismissed the petition for lack of merit. The petitioners contended that the denial of their motion to quash was a violation of their right to absolute privilege and claimed a breach of the equal protection clause.
Supreme Court Ruling
The Supreme Court found the petition to be without merit. It emphasized that the appropriate procedure following the denial of a motion to quash was to proceed to trial, allowing the petitioners the opportunity to assert their defenses thereafter. Citing precedents,
...continue readingCase Syllabus (G.R. No. 78555)
Case Overview
- The case involves a petition for review on certiorari by petitioners Romulo S. Bulaong and Gil P. De Guzman against the decision of the Court of Appeals.
- The decision dismissed their special civil action for certiorari, prohibition, and mandamus regarding an information for libel filed against them.
Antecedent Facts
- On March 12, 1984, Bulaong initiated a civil action for sum of money (Civil Case No. RTC-67-1) against Vicente Vistan, Leonardo Buenaventura, and Conrado Sta. Maria in the Regional Trial Court of Zambales.
- Vicente Vistan subsequently filed a complaint for rescission of contract and damages against Bulaong, leading to the consolidation of the cases pending trial.
- On November 21, 1984, Bulaong filed a criminal complaint for estafa against Vistan and Buenaventura with the Office of the City Fiscal of Pasay.
- Following the submission of a reply-affidavit by Bulaong containing allegedly libelous statements, Vistan and Buenaventura filed a libel complaint against Bulaong and his counsel De Guzman.
Criminal Proceedings
- The City Fiscal conducted an investigation and filed an information for libel against the petitioners on October 11, 1985, which was later amended on July 1, 1986.
- T