Case Summary (G.R. No. 211839)
Procedural History
The initial complaint was filed in the Justice of the Peace Court, which later amended the charges to serious oral defamation. After Bao waived his right to preliminary investigation, the case was deemed to exceed the jurisdiction of the Justice of the Peace Court and was forwarded to the Court of First Instance for a trial on the merits.
Charges and Allegations
In the information filed by the Provincial Fiscal, Benedicto Bao was accused of uttering defamatory statements against Maximina Banguis on or about April 22, 1955, claiming that she had lost her virginity to him. These statements were alleged to expose her to public contempt and ridicule, leading to material and moral damages.
Motion to Quash and Court Findings
After the prosecution presented its case, Benedicto Bao's counsel filed a motion to quash, arguing that the evidence did not support a conviction for serious oral defamation. The trial court granted this motion, citing evidence that instead suggested the crime of intriguing against honor, which falls under the exclusive jurisdiction of the Justice of the Peace Court. Consequently, the court dismissed the case and directed the provincial fiscal to file the appropriate action in the proper court.
Appeal and Legal Principles
The prosecution appealed the dismissal, maintaining that the offense of intriguing against honor was necessarily included in the charge of serious oral defamation. However, the appellate court ruled that the dismissal constituted an acquittal, referencing the principle that such a dismissal after the prosecution rests its case prohibits further prosecution under the doctrine of double jeopardy.
Double Jeopardy Considerations
The ruling emphasized that the prosecution could not appeal without infringing upon the constitutional protection against double jeopardy, which bar
...continue readingCase Syllabus (G.R. No. 211839)
Case Overview
- This case concerns an appeal by the Government against the dismissal of a case for serious oral defamation against Benedicto Bao.
- The dismissal was ordered by the Court of First Instance of Misamis Occidental upon the defendant's motion.
Background of the Case
- On May 13, 1955, Benedicto Bao was charged with oral defamation in the Justice of the Peace Court of Aloran, Misamis Occidental, based on a complaint by Maximina Banguis.
- The initial complaint was later amended to specifically charge serious oral defamation.
- The defendant waived his right to a preliminary investigation. The Justice of the Peace Court determined it lacked jurisdiction and forwarded the case to the Court of First Instance.
Charges and Allegations
- The Provincial Fiscal filed an information stating that Benedicto Bao committed serious oral defamation on or about April 22, 1955.
- Bao allegedly stated, "Si Maximina Banguis, airing nakuha," implying that Maximina was no longer a virgin, which exposed her to public contempt, disrepute, and ridicule.
- The alleged defamatory statements were said to have caused material and moral damages amo