Title
Ramos vs. People
Case
G.R. No. 226454
Decision Date
Nov 20, 2017
A verbal altercation between neighbors escalated into defamatory remarks, leading to a conviction downgraded to Slight Oral Defamation due to provocation and heat of anger.

Case Summary (G.R. No. 189206)

Petitioner

Digna Ramos was accused of orally uttering scurrilous and insulting words against Patrocinia Dumaua during an altercation, and was charged with Grave Oral Defamation under Article 358 of the Revised Penal Code.

Respondent / Private Complainant

The People of the Philippines prosecuted the offense at the instance of private complainant Patrocinia R. Dumaua, who alleged that Ramos hurled the words “ukininam, puta, awan ad-adal mo” (translated in the record as “vulva of your mother, prostitute, illiterate”) at her during a public quarrel.

Key Dates and Procedural Posture

Incident date: about 4:20 p.m., 17 September 2003. MCTC conviction: Decision dated 15 May 2009. RTC affirmation: Decision dated 4 September 2014. CA decision: 29 March 2016 (modifying the penalty). CA resolution denying reconsideration: 10 August 2016. Supreme Court decision on the petition: 20 November 2017. The case proceeded through trial conviction, appeal to the RTC, petition for review to the CA, and certiorari review to the Supreme Court.

Applicable Law and Precedents (1987 Constitution applicable)

Primary penal provision: Article 358, Revised Penal Code (oral defamation/slander). Civil relief: Article 2219(7) of the Civil Code (moral damages for defamation). Sentencing framework: Indeterminate Sentence Law. Statutory amendment noted: Section 94 of Republic Act No. 10951 (adjusting fines) but inapplicable retroactively to crimes committed before its enactment. Controlling jurisprudence cited in the decision includes De Leon v. People (defining elements and gravity of oral defamation), People v. Dahil, People v. Comboy, Miro v. Vda. de Erederos, and other authorities on standards of appellate review and when factual findings may be revisited.

Facts as Found in the Record

The prosecution’s version: while Dumaua was watering plants, five schoolchildren allegedly picked up dried leaves and threw them into Dumaua’s yard. When Dumaua called their attention, they ran toward Sto. Niño Elementary School. Ramos allegedly arrived, picked up dried banana leaves and threw them into the complainant’s yard and thereafter engaged in a quarrel with Dumaua, during which she uttered the allegedly defamatory words. Corroboration: witnesses inside Dumaua’s house testified that a commotion and a heated verbal exchange were ongoing; they observed the quarrel’s height but did not corroborate the antecedent acts of throwing leaves. Ramos’s defense: she denied making the specific insults and maintained she was merely passing along a public pathway when Dumaua angrily blamed her for the alleged garbage and threatened her; she asserted provocation and later went to the police to file a complaint for grave coercion. Ramos’s husband testified that he intervened as Dumaua allegedly armed herself with stones.

Charge and Accusatory Allegations

The Information charged Ramos with Grave Oral Defamation, alleging that she wilfully and maliciously uttered the phrases “ukininam, puta, awan ad-adal mo” to Dumaua in a public place, imputing insulting and dishonorable attributes and thereby violating Article 358 of the Revised Penal Code.

MCTC and RTC Findings

The MCTC convicted Ramos of Grave Oral Defamation and sentenced her to prision correccional (with the minimum and maximum specified in the judgment) and awarded P20,000.00 as moral damages. The RTC affirmed the MCTC decision in toto, finding that the prosecution established beyond reasonable doubt that Ramos uttered the offensive words, and that Ramos’s denials were unsubstantiated and self-serving.

Court of Appeals Ruling

The CA affirmed the findings of the courts below but modified the penalty range in accordance with the Indeterminate Sentence Law, setting the minimum at arresto mayor and the maximum at prision correccional. The CA accepted the positive testimony of complainant and corroborative witnesses as establishing that Ramos uttered the offending words and characterized those words as defamatory and of a serious and insulting nature.

Issue Presented to the Supreme Court

Whether the CA correctly upheld Ramos’s conviction for the crime of Grave (Serious) Oral Defamation under Article 358 of the Revised Penal Code.

Supreme Court’s Standard of Review and Jurisdictional Observations

The Supreme Court reiterated that an appeal in criminal cases confers full jurisdiction on the appellate court to examine the records and revise the appealed judgment, including correcting errors whether assigned or unassigned. It distinguished the limits of Rule 45 certiorari review (generally confined to questions of law) but noted established exceptions that permit re-examination of factual findings when the judgment is based on misapprehension of facts or when the factual findings are contrary to the evidence on record.

Elements and Legal Characterization of Oral Defamation

Relying on De Leon v. People, the decision restated the elements of oral defamation: (1) imputation of a crime, vice, defect, act, omission, status or circumstance; (2) oral utterance; (3) made publicly; (4) maliciously; (5) directed to a natural or juridical person; and (6) tending to cause dishonor, discredit, contempt or blacken memory. The Court explained that whether defamation is grave or slight depends on the expressions used, the personal relations between the parties, and special circumstances such as provocation and the heat of anger — the latter potentially mitigating the offense to slight oral defamation.

Application of Law to the Facts — Credibility and Provocation

The Supreme Court accepted that Ramos uttered the words attributed to her, but it closely examined the factual matrix regarding who provoked the quarrel. The Court found the prosecution had not proved that Ramos initiated the incident by directing children to throw leaves or by throwing dried banana leaves into Dumaua’s yard; the corroborative witnesses only testified to events at the height of the quarrel and did not support the allegation that Ramos started the disturbance. Given those evidentiary gaps, the Court gave credence to Ramos’s account that she was passing along a pathway and that Dumaua provoked the exchange. Because the insults were uttered in the heat of anger and with some provocation from the offended party, the Court concluded that the elements justifie

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