Title
Orillo vs. People
Case
G.R. No. 206905
Decision Date
Jan 30, 2023
Petitioners convicted of libel for posting defamatory documents about a PAFSEJODA official; alibi and denial rejected; penalty modified to a fine.

Case Summary (G.R. No. L-4497)

Trial Court Proceedings and Conviction

The Pasig City RTC found the prosecution proved guilt beyond reasonable doubt as to Orillo, Francisco, and Danieles. It convicted them of libel under Article 353, imposed minimum and medium prision correccional terms, and awarded P200,000 in moral damages, P20,000 acceptance and termination fees, and P2,000 per court appearance. Jean Jardeleza was acquitted; proceedings against Nepacina were archived.

Defense of Alibi and Denial

Orillo claimed physical impossibility of participation, asserting he was en route to Bicol for a baptism and town fiesta, supported by baptismal certificates and photographs. Danieles denied playing an active role, stating he was merely a spectator who observed others’ commotion and that documents were kept in the PAFSEJODA office. Neither presented corroborative evidence.

Court of Appeals Review

The CA held that Alibi and denial were not convincingly established. Orillo’s evidence did not irrefutably preclude his presence between 8:00 and 9:00 a.m. Danieles’s bare denial lacked corroboration and could not override positive eyewitness testimony. The CA also found that publication was proven by witnesses’ accounts of third parties reading the posts and by photographs, which it deemed admissible.

Issues on Alibi and Publication before the Supreme Court

Petitioners argued:

  1. The alibi and denial defenses were wrongly disregarded.
  2. The prosecution failed to present the photographer, rendering the photographs inadmissible.
  3. Absence of malice on account of timing (posting one month after the election) and lack of justifiable motive.

Standard of Review on Questions of Fact

Under Rule 45, the Supreme Court defers to the factual findings of the CA when supported by substantial evidence. Petitioners failed to invoke recognized exceptions (e.g., manifestly mistaken inference or grave abuse of discretion) justifying a re-examination of facts. The SC accordingly upheld the CA’s findings on alibi, denial, and participation.

Elements of Libel under Article 353 RPC

To constitute libel:
(a) A discreditable imputation, here the accusation of carnapping.
(b) Publication to a third party—posts on a public bulletin board read by others.
(c) Identification of the defamed person—Cabatian was clearly named.
(d) Malice—implied by the malicious intent to injure reputation in absence of privilege or justifiable motive.

Publication and Admissibility of Photographic Evidence

Publication was established by witness testimony that third parties viewed and read the posts. Photographs of the postings were properly admitted: under established jurisprudence, accuracy of photographs can be proven by competent witnesses familiar with the scene, not solely by the photographer.

Malice and Privileged Communications

Because Cabatian is a private person, malice is presumed in every defamatory imputation unless good intention and justifiable motive are shown. No privilege (absolute or qualified) applied to petitioners’ act of posting another party’s judicial pleadings. The timing—posting a month after the election—and selective publication of only the complainant’s documents without any rebuttal evidence further evidenced malice.

Distinction Between Private Persons and Public Officers

Cabatian’s private‐person status triggers a presumption of malice under Art

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