Case Summary (G.R. No. L-23135)
Criminal Charges and Initial Proceedings
On September 4, 1978, a special counsel from the Office of the City Fiscal filed an information against Venida Peralta in the City Court of Cagayan de Oro, alleging that she committed oral defamation against Lydia Flores. The specific remarks attributed to Peralta were deemed defamatory and were said to have caused substantial public disdain and contempt towards Flores, thereby falling under Article 358 of the Revised Penal Code.
Dismissal of Criminal Case
The proceedings began with the arraignment on November 3, 1978, where the accused pleaded not guilty. However, on February 2, 1981, Peralta filed a motion to quash the information, arguing that the alleged crime constituted an imputation of a crime that could not be prosecuted without a complaint from the offended party. On February 10, 1981, Judge Orcullo dismissed the case, contending that oral defamation is a private crime that requires the offended party to initiate prosecution.
Solicitor General's Argument
Subsequent to the dismissal, the City Fiscal filed a motion for reconsideration, which was denied. The Solicitor General later contended that the remarks made by Peralta not only implied adultery but specifically described actions consistent with the offense of prostitution, which is a public crime and does not require a complaint from the offended party. The Solicitor General emphasized that the nature of the comments made by Peralta indicated a broader implication relating to public morals rather than mere private offense.
Legal Interpretation of Defamatory Statements
The court's decision also considered whether the derogatory remarks indeed implied both adultery and prostitution. The distinction was crucial because prostitution is classified as a public crime that can be prosecuted ex officio. By interpreting the remarks in context, the court determined that the words used clearly imputed the act of prostitution, securing the jurisdiction of the lower court to try the
...continue readingCase Syllabus (G.R. No. L-23135)
Case Overview
- This case involves a petition for certiorari filed by the City Fiscal and Assistant City Fiscal of Cagayan de Oro City.
- The petition seeks to challenge the order issued by Hon. Antonio A. Orcullo, the acting city judge, which dismissed Criminal Case No. 40117.
- The respondents in this case are the Hon. Antonio A. Orcullo and Venida Peralta, also known as Edat Peralta.
Background of the Case
- On September 4, 1978, a special counsel filed an information against Venida Peralta, accusing her of oral defamation.
- The specific act of defamation occurred on August 17, 1978, where Peralta allegedly made derogatory remarks about Lydia Flores, claiming she was a "hostess" and had a paramour.
- The remarks were made publicly, causing undue shame, ridicule, disrepute, and contempt to Flores, thus constituting a violation of Article 358 of the Revised Penal Code.
Initial Proceedings
- The arraignment of Criminal Case No. 40117 took place on November 3, 1978, where the accused pleaded not guilty.
- On February 2, 1981, Peralta filed a motion to quash the charges, arguing that the crime alleged was one that could not be prosecuted without a complaint from the offended party.
- Subsequently, on February 10, 1981, Judge Orcullo dismissed the case, stating that the offense was a private crime requiring the offended party's complaint.