Case Summary (G.R. No. 212623)
Key Dates
February 27, 2006 – Alleged gun-pointing incident involving SPO3 Leonardo.
April 17, 2006 – First hearing before People’s Law Enforcement Board (PLEB) and alleged defamation.
April 15, 2011 – Metropolitan Trial Court (MeTC) Decision convicting De Leon of grave oral defamation.
September 28, 2012 – Regional Trial Court (RTC) Decision affirming MeTC.
May 20, 2014 – Court of Appeals (CA) Resolution affirming RTC with penalty modification.
January 11, 2016 – Supreme Court Decision partially granting petition.
Applicable Law
1987 Philippine Constitution, Article VIII, Section 14 (clear and distinct statement of facts and law).
Rule 36, Section 1 of the Rules of Court (requirements for written decisions).
Revised Penal Code, Article 358 (slight oral defamation) and applicable provisions on grave oral defamation.
Procedural History
MeTC (Branch 6, Manila) convicted De Leon of grave oral defamation. De Leon appealed to the RTC, which affirmed. The CA denied further relief except for penalty adjustment. De Leon filed a petition for review on certiorari with the Supreme Court.
Facts as Found by the Prosecution
De Leon and his son had filed administrative charges against SPO3 Leonardo. On April 17, 2006, while waiting for the PLEB hearing, De Leon allegedly approached Leonardo and publicly uttered: “Walanghiya kang mangongotong na pulis ka, ang yabang yabang mo noon. Patay ka sa akin mamaya.” Leonardo immediately filed criminal charges.
Facts as Offered by the Defense
Defense witnesses recounted an earlier February 27, 2006 incident in which SPO3 Leonardo reportedly pointed a gun at De Leon. De Leon’s counter-charges were said to have been prompted only after receiving a subpoena. Defense denied any deliberate intent to defame and portrayed the April 17 utterance as an emotional outburst.
MeTC Decision
The MeTC found the prosecution credible, treating the police blotter as prima facie evidence. It credited SPO3 Leonardo’s prompt reporting and Principe’s testimony, dismissed defense evidence as self-serving, and convicted De Leon of grave oral defamation, imposing arresto mayor to prision correccional and P10,000 moral damages.
RTC and CA Rulings
The RTC affirmed the MeTC decision, emphasizing deference to trial-court credibility determinations. The CA likewise upheld the conviction but modified the minimum imprisonment to four months (minus one day) to one year, one month and eleven days, denying other relief.
Issues on Certiorari
- Whether the MeTC decision failed to clearly and distinctly state the facts and law as required by the Constitution and Rules of Court.
- Whether petitioner’s guilt was proven beyond reasonable doubt.
Supreme Court’s Analysis on Decision Clarity
Under the 1987 Constitution and Rule 36, decisions must disclose factual and legal bases. The Supreme Court found the MeTC decision adequately recited both parties’ versions, discussed witness credibility, and explained legal conclusions—satisfying due-process requirements.
Credibility of Witnesses and Bias Allegations
The Court refused to disturb findings on witness credibility, noting no ill motive for Principe and satisfactory demeanor observations by the trial judge. Allegations of Judge Soriaso’s bias were unsupported; absent clear evidence of prejudice, judicial decisions enjoy a presumption of regularity.
Legal Classification of Oral Defamation
Oral defamation consists of publicly uttered words imputing a crime, vice, or defect, maliciously causing dishonor. It is
...continue readingCase Syllabus (G.R. No. 212623)
Facts of the Case
- On February 27, 2006, SPO3 Pedrito L. Leonardo allegedly approached Enrique De Leon and his son at Tutuban Station with firearm drawn, uttered expletives (“Putang ina mo, tapos ka na Ricky Boy”), and failed to fire.
- De Leon and his son filed administrative charges for grave misconduct against SPO3 Leonardo before the People’s Law Enforcement Board (PLEB), dockets 06-02-060 and 06-02-061.
- The first PLEB hearing was set on April 17, 2006; while waiting outside the hearing room at Manila City Hall, De Leon allegedly shouted defamatory remarks at SPO3 Leonardo in public.
Procedural History
- MeTC Branch 6, Manila convicted De Leon of Grave Oral Defamation on April 15, 2011, sentencing him to an indeterminate penalty (4 months and 1 day arresto mayor to 1 year, 1 month, 11 days prision correccional) and awarded ₱10,000 moral damages.
- RTC Branch 27, Manila affirmed the MeTC decision on September 28, 2012; denied reconsideration on November 27, 2012.
- CA Second Division, in CA-G.R. CR No. 35390, affirmed the RTC decision on November 14, 2013, modifying the minimum sentence by deducting one day.
- Supreme Court granted petition for review on certiorari, raising issues on sufficiency of findings and proof beyond reasonable doubt.
Version of the Prosecution
- SPO3 Leonardo testified that on April 17, 2006 at about 1:30 p.m., De Leon publicly yelled:
“Walanghiya kang mangongotong na pulis ka, ang yabang-yabang mo noon. Patay ka sa akin mamaya.” - Leonardo felt embarrassed before several onlookers; opted not to arrest De Leon immediately to avoid spectacle.
- He documented the incident at the PNP Special Operations Group blotter and filed a complaint at the City Prosecutor’s Office the same day.
- Witnesses Carlito Principe and Jennifer Malupeng corroborated Leonardo’s account and the lack of provocation at the time of utterance.
Version of the Defense
- Fernando Manalo, Ruperto Molera, Concepcion De Leon, and petitioner testified to a prior gun-pointing incident by SPO3 Leonardo on February 27, 2006.
- Defense claimed SPO3 Leonardo first provoked De Leon with expletives, threats, and gun discharge attempt.
- De Leon denied apologizing after the April 17 encounter and maintained he only filed charges at Camp Crame after receiving the subpoena from the OCP.
- He also alleged he observed the officer deposit his service firearm during the PLEB hearing.
Ruling of the MeTC
- Found De Leon guilty beyond reasonable doubt of Grave Oral Defamation.
- Treated SPO3 Leonardo’s blotter entry as prima facie evidence; underscor