Case Summary (G.R. No. 25350)
Facts of the Case
The case arises from an Information charging Digna Ramos with Grave Oral Defamation for uttering the words "ukininam, puta, awan ad-adal mo," which translate to “vulva of your mother, prostitute, illiterate” against Patrocinia Dumaua. On September 17, 2003, Dumaua was allegedly watering her plants when five schoolchildren threw dried leaves into her yard. Noticing this, Dumaua called their attention, prompting the children to run to Sto. NiAo Elementary School where Ramos works. Ramos then allegedly threw dried banana leaves into Dumaua’s yard while uttering remarks. A verbal altercation ensued between Ramos and Dumaua, during which the defamatory words were spoken. Witnesses Orlando Baltazar and Babileo Dumaua corroborated the occurrence of the verbal quarrel at its height.
Defense of Petitioner
Ramos denied the use of the defamatory language. She claimed she was merely passing through a pathway near Dumaua’s property when Dumaua angrily accused her of causing garbage in her yard and threatened her not to use the pathway. Ramos responded by demanding proof of Dumaua’s authority to restrict access. Ramos then proceeded to file a grave coercion complaint against Dumaua. Her testimony was supported by her husband, who recounted intervening in a heated altercation where Dumaua was allegedly armed with stones.
Decisions of Lower Courts
- MCTC Decision (May 15, 2009): Convicted Ramos for Grave Oral Defamation beyond reasonable doubt, sentencing her to prision correccional and awarding moral damages of P20,000.
- RTC Decision (September 4, 2014): Affirmed the MCTC ruling, giving credence to the testimonies of Dumaua and her witnesses and rejecting Ramos’s denial as unsubstantiated.
- CA Decision (March 29, 2016): Affirmed with modification Ramos’s conviction, adjusting her prison term to a lower range under the Indeterminate Sentence Law. The CA agreed that the words used were defamatory and serious in nature. Ramos’s motion for reconsideration was denied (August 10, 2016).
Issue Before the Supreme Court
Whether the Court of Appeals correctly upheld petitioner Ramos's conviction for Grave Oral Defamation under Article 358 of the Revised Penal Code.
Legal Analysis and Court’s Ruling
The Supreme Court partly granted the petition. It reiterated the appellate court's broad mandate to review not only questions of law but also errors of fact when the factual findings are contrary to evidence or based on misapprehension of facts. Article 358 of the RPC penalizes oral defamation, distinguishing between grave (seriously insulting) and slight offenses based on the nature of the language and circumstances.
The Court outlined the elements of oral defamation as: imputation of crime or vice, oral utterance, public communication, malice, directed at a person, and tending to dishonor or discredit. Grave oral defamation entails serious and insulting imputation, considering the context, the relationship between parties, and provocations.
The Court found that although Ramos uttered the defamatory words, Dumaua’s claim that Ramos initiated the altercation by instructing schoolchildren to throw leaves, and Ramos’s own alleged throwing of leaves, were not adequately proven. Witnesses did not support Dumaua’s version concerning the initial acts. Instead, the Court gave weight to Ramos's account that she was provoked by Dumaua’s threats, thereby deeming Ramos's utterances as uttered in the heat of anger with some provocation.
Accordingly, the Court held Ramos guilty only of Slight Oral Defamation, punishable by arresto menor or a fine. It imposed the minimum fine of P200, with subsidiary imprisonment in case of insolvency, reversing the previous heavier penalty.
Civil Liability
Considering the reduced degree of offense, the Court ordered the reduction of moral damages awarded to Dumaua from P20,000 to P5,000, with legal interest at six percent per annum from the date of finality of the decision until fully paid.
Final Disposition
The Supreme Court modified the Court of Appeals' judgment by convicting Digna Ramos only of Slight Oral Defamation under Article 358 of the RPC. It sentenced her to pay a fine of P200, with subsidiary imprisonment in case of non-payment, moral damages
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Case Syllabus (G.R. No. 25350)
Case Background and Initial Charges
- The case involves petitioner Digna Ramos being charged with the crime of Grave Oral Defamation under Article 358 of the Revised Penal Code (RPC).
- The Information filed before the Municipal Circuit Trial Court (MCTC) of Piat-Sto. Nino, Cagayan Province, alleges that on September 17, 2003, Ramos uttered defamatory remarks against complainant Patrocinia R. Dumaua, cursing her using words that translate to "vulva of your mother, prostitute, illiterate."
- The defamatory remarks were allegedly made after an incident involving schoolchildren and dried leaves thrown into Dumaua's yard, which started a verbal altercation between Ramos and Dumaua.
- Witnesses corroborated the occurrence of the verbal tirade, with the key phrase uttered by Ramos recognized as highly insulting and damaging to Dumaua’s honor.
Facts and Testimonies
- Complainant Dumaua testified that the incident began when she observed schoolchildren throwing dried leaves into her yard; these children fled, and Ramos, a public school teacher, allegedly continued this act while making derogatory comments.
- A quarrel ensued during which Ramos supposedly uttered serious defamatory words, witnessed by two others who confirmed the intensity of the verbal altercation.
- Ramos denied making the defamatory remarks and instead narrated encountering Dumaua’s anger and threats while passing through a pathway near Dumaua’s house.
- Ramos’ husband corroborated her account, describing Dumaua as the aggressor who was about to attack Ramos with stones.
- The testimonies presented a factual dispute about who instigated the incident and whether the defamatory words were uttered.
Proceedings and Lower Court Decisions
- The MCTC found Ramos guilty beyond reasonable doubt of Grave Oral Defamation, sentencing her to a minimum of one year and one day to a maximum of one year and eight months of prision correccional and ordering Ramos to pay moral damages of P20,000 plus costs.
- Ramos’ motions for new trial and reconsideration were denied.
- The Regional Trial Court (RTC) of Tuao, Cagayan affirmed the MCTC decision, emphasizing the positive and consistent testimonies against Ramos and rejecting her denial as unsubstantiated and self-serving.
- Ramos appealed to the Court of Appeals (CA), which affirmed with modification the conviction by reducing the minimum sentence to four months of arresto mayor.
Court of Appeals Ruling and Rationale
- The CA upheld the factual findings that Ramos uttered the defamatory phrase "ukininam, puta, awan ad-adal mo," confirming the serious and insulting nature of the words.
- The CA reasoned that such utterances deeply impugn the victim’s character and honor, thus constituting Grave Oral Defamation.
- Ramos’ bare denials were deemed insufficient against the clear positive testimonies, validating the