Title
De Leon vs. People
Case
G.R. No. 212623
Decision Date
Jan 11, 2016
Enrique De Leon convicted of Slight Oral Defamation for public slander against SPO3 Leonardo, reduced from Grave due to emotional context and prior provocation.

Case Summary (G.R. No. 212623)

Applicable Law and Constitutional Basis

Constitutional standard: Section 14, Article VIII of the 1987 Constitution (decision must state clearly and distinctly the facts and law upon which it is based). Rules of Court: Section 1, Rule 36 (requirements for written judgments). Substantive criminal law: provisions on oral defamation (slander) under the Revised Penal Code, distinguishing grave oral defamation from slight oral defamation; Article 358 (penalty for slight oral defamation) referenced for sentencing.

Charge and Information

De Leon was charged by information with Grave Oral Defamation for allegedly uttering publicly at or about April 17, 2006 words to SPO3 Leonardo such as “WALANGHIYA KANG MANGONGOTONG NA PULIS KA, ANG YABANG YABANG MO NOON. PATAY KA SA AKIN MAMAYA,” and other expressions of similar import, thereby bringing the complainant into public contempt, discredit and ridicule.

Procedural Posture

De Leon pleaded not guilty before the MeTC. A mediation attempt under Supreme Court Circular No. 20-2002 failed and trial proceeded. The MeTC convicted De Leon for Grave Oral Defamation and imposed imprisonment and moral damages. De Leon appealed to the RTC, which affirmed the MeTC. The CA affirmed with modification of the minimum imprisonment and otherwise maintained conviction. De Leon filed a petition for review to the Supreme Court raising, inter alia, that the MeTC decision failed to clearly state facts and law and that guilt was not proven beyond reasonable doubt.

Prosecution’s Case and Evidence

The prosecution presented SPO3 Leonardo, Carlito Principe, and Jennifer Malupeng. Their testimony described (1) a prior animus and administrative complaints filed by De Leon and his son against SPO3 Leonardo (PLEB cases), (2) the occurrence on April 17, 2006 when, while waiting outside the PLEB, De Leon allegedly approached and publicly uttered the quoted slanderous words in the presence of others, and (3) immediate reporting of the incident by SPO3 Leonardo (police blotter entry and filing of complaint at the OCP the same day).

Defense Case and Evidence

Defense witnesses (including petitioner and his wife) recounted an earlier gun-pointing incident attributed to SPO3 Leonardo on February 27, 2006, providing context for animosity and emotional reaction. They claimed De Leon’s utterance was provoked, that the utterance occurred in the heat of emotion shortly after the alleged gun-pointing incident, and that De Leon filed counter-charges only after receiving a subpoena—raising an inference of reactive behavior rather than malicious imputation. The defense disputed the presence of some prosecution witnesses at the PLEB at the relevant time.

MeTC Findings and Rationale

The MeTC found De Leon guilty of Grave Oral Defamation beyond reasonable doubt. It relied on SPO3 Leonardo’s police blotter as prima facie evidence, gave significant probative weight to Principe’s testimony, and considered De Leon’s counter-complaint timing as indicative of afterthought and self-serving conduct. The MeTC concluded the utterances were spontaneous and damaging to the complainant’s reputation in public.

RTC and CA Review Emphasis

The RTC, acting in an appellate capacity, deferred to the MeTC’s credibility assessments and affirmed the conviction, finding the MeTC’s findings sufficiently elucidated. The CA likewise upheld the conviction but modified the minimum imprisonment by one day; it agreed that the contested words—“walanghiya,” “mayabang,” and “mangongotong”—were seriously insulting and that no sufficient provocation or heat of passion justified downgrading to slight defamation under the factual circumstances presented.

Supreme Court’s Analysis on Requirement for Decisions

The Supreme Court emphasized the constitutional and procedural mandate that courts must state clearly and distinctly the facts and law on which decisions are based (Section 14, Article VIII; Rule 36, Sec. 1). The Court acknowledged the necessity of concise decisions but held that even succinct rulings must set forth, at minimum, the factual and legal basis enabling review. Applying this standard, the Court found no breach: the MeTC adequately narrated the parties’ versions, explained credibility assessments, and stated legal conclusions, thereby satisfying the constitutional mandate.

Supreme Court’s Treatment of Witness Credibility and Allegations of Judicial Bias

The Court reiterated the settled rule that evaluations of witness credibility by trial courts are accorded great respect and finality, absent compelling reason to overturn. The Court upheld the probative value attributed by the MeTC to Principe and SPO3 Leonardo, noting absence of ill motive and the trial judge’s personal observation of demeanor. Regarding the petitioner’s allegation of bias by the trial judge, the Court applied the presumption of judicial regularity and required clear and convincing evidence to rebut it; petitioner presented none, so the claim of partiality failed.

Legal Elements of Oral Defamation and Distinction Between Grave and Slight

The Court restated the elements of oral defamation: imputation of a crime, vice or defect (real or imaginary), made orally, publicly, maliciously, directed to a person, and tending to cause dishonor, discredit or contempt. Grave oral defamation occurs when the imputation is serious and insulting; slight oral defamation when it is less serious. The Court stressed that whether the offense is grave or slight depends on (1) expressions used, (2) personal relations between the parties, and (3) special circumstances surrounding the incident, including provocation and heat of passion.

Application of Law to Facts: Downgrading to Slight Oral Defamation

Although the Court agreed the words were defamatory, it concluded that under the specific factual setting the offense constituted only slight oral defamation. The Court identified several controlling factors: (1) prior personal relationship (acquaintances and former jogging buddies), (2) proximity in time to the alleged gun-pointing incident (emotional wound likely fresh), and (3) lack of evident intent to deeply injure or humiliate—the utterances were a spontaneous emotional outburst rather than a calculated effort to destroy reputation. The Court therefore found mitigating circumstances favoring downgrading from grave to slight.

Public Officer Consideration and Relevance to Defamation

The Court considered the principle that public officers should tolerate criticism, but clarified that tolerance doctrine applies only when defamatory statements are connected to the officer’s official duties. Here the utterances arose from a private matter—the alleged personal loan dispute and alleged gun-pointin

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