Case Summary (G.R. No. 35366)
Factual Background
The Provincial Fiscal filed two separate informations for libel, asserting that Guevarra published a single article intended to malign the integrity of the two individuals. Guevarra demurred, claiming duplicity in the informations since only one article had been published. The court overruled the demurrer and proceeded to a joint trial for both cases. During the prosecution's attempt to present evidence, the fiscal aimed to introduce several exhibits—copies of the "Ing Magumasid" that included the alleged libelous article and its translations—however, these were objected to by the defense and subsequently excluded by the respondent judge.
Core Legal Issues
The legal issues presented focus on the admissibility of evidence in a libel case and the validity of an information charging libel without including the original defamatory statement. The petitioner contended that the excluded exhibits constituted the best evidence of the allegations outlined in the informations. In contrast, the respondents argued that because the libelous articles were not quoted in the informations, the evidence could not be admitted without amending the original informations, which they claimed would violate the defendant's rights.
Analysis of Legal Standards
One significant principle discussed is the requisite for an libel information to detail the defamatory words. It has been established in prior cases, such as United States v. Eguia and Lozano, that an information must generally set forth the specific defamatory words. However, exceptions exist, particularly when the defamatory remarks are rendered in a non-official language. The court noted that since the libel was published in the Pampango dialect, the inclusion of a Spanish translation in the information suffices to meet this requirement. This ruling underscores the necessity for flexibility in legal standards when dealing with languages differing from the official tongues.
Admission of Evidence
Regarding the admissibility of the exhibits, the court assessed traditional rules governing the relevance and necessity of providing best evidence in cases of libel. The copies of "Ing Magumasid" where the libelous article appeared, along with their translations, were deemed the best evidence to substantiate the claims made in the informations. The ruling highlighted that
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Case Overview
- The case revolves around a petition for a writ of mandamus filed by the Provincial Fiscal of Pampanga against Hermogenes Reyes, a judge of the First Instance of Pampanga, and Andres Guevarra, a defendant in two libel cases.
- The petition seeks to compel the respondent judge to admit four specific exhibits as evidence in the libel cases Nos. 4501 and 4502.
Background of the Case
- The Provincial Fiscal of Pampanga filed two separate informations for libel against Andres Guevarra.
- The allegations state that Guevarra published a libelous article in the weekly paper "Ing Magumasid" on July 13, 1930, aimed at tarnishing the reputation of Clemente Dayrit and Mariano Nepomuceno.
- Guevarra demurred, claiming duplicity since only one libelous article was published.
- The court overruled the demurrer and proceeded with a joint trial for both criminal cases.
Attempt to Present Evidence
- The Provincial Fiscal attempted to introduce Exhibits A, B, C, and D, which included copies of the publication containing the libelous article and its Spanish translation.
- The defense objected to the admission of these exhibits, leading to the court sustaining the objection.
- The respondents, in their answer to the petition for ma