Title
Pueblo de las Islas Filipinas vs. Stanley J. Willimont
Case
R. G. No. 39196
Decision Date
Nov 27, 1933
Appellant acquitted of oral defamation as defamatory words lacked publicity; no third party present to hear the statement.

Case Summary (G.R. No. 241034)

Incident Overview

On the morning of August 24, 1932, Stanley J. Willimont engaged in a verbal altercation with Policeman Leon Somera over what he perceived as the latter's negligence in traffic duty. Following the initial confrontation, Willimont threatened to report Somera to his superior. After a brief period, he returned to the scene and verbally insulted the policeman, using the phrase, "What a hell you are, you are a monkey traffic cop." This led to Willimont being charged in the Municipal Court of Manila for violating Article 358 of the Revised Penal Code, which addresses oral defamation.

Municipal and First Instance Court Proceedings

After being found guilty, Willimont was sentenced to pay a fine of P10, along with court costs. He subsequently appealed the decision to the Court of First Instance, which upheld the Municipal Court's ruling, affirming Willimont's conviction.

Legal Arguments and Interpretation

Willimont's primary argument on appeal emphasized that Article 358 of the Revised Penal Code was not applicable to his case. He contended that, according to Article 353 of the same code, both oral and written defamation require public dissemination in order to be punishable. He pointed out that, at the time the derogatory statements were made, only he and the policeman were present, thereby lacking the element of public exposure necessary for a valid defamation claim under the law.

Court's Conclusion

Upon reviewing the case, the court concurred with Willimont's argument. It determined th

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