Case Summary (G.R. No. L-11575)

Defamation and Imputation of Crime

• Under Article 360, paragraph 4 of the Revised Penal Code, a criminal action for defamation based on the imputation of a crime that cannot be prosecuted de oficio requires a complaint from the offended party.
• The crime of adultery is classified as one that cannot be prosecuted de oficio, as specified in Article 344 of the Revised Penal Code.

Background of the Case

• On March 28, 1955, Ernesto A. Bernabe, acting as special counsel for Pasay City, accused Lydia Padilla of defamation under Article 364 of the Revised Penal Code.
• The accusation claimed that Padilla spread defamatory rumors about Fausta Bravo, alleging that Bravo was having an affair with a man named Sangalang, who was not her husband.

Motion to Quash

• Lydia Padilla filed a motion to quash the information on two grounds:
  1. The special counsel lacked the authority to file the information.
  2. The information charged more than one offense.
• The special counsel opposed the motion, but the Municipal Court dismissed the information on April 25, 1955, citing the lack of a complaint from the offended party.

Appeal and Court Rulings

• The Court of First Instance upheld the Municipal Court's dismissal, leading the special counsel to appeal the decision.
• The information filed by the special counsel, while citing Article 364, described actions that constituted a more serious offense—specifically, the crime of adultery.

Nature of the Allegations

• The allegations made against Fausta Bravo were not merely defamatory but directly accused her of committing adultery, which is a serious charge under the law.
• The court noted that the information's content clearly indicated that it was charging Bravo with adultery, thus falling under ...continue reading