Case Summary (G.R. No. 225010)
Key Dates
• July 31, 1998 – Alleged libelous broadcast aired.
• January 15, 1999 – Information in Criminal Case No. IR-4848 filed.
• June 9, 2000 – Information in Criminal Case No. IR-5273 filed.
• June 8, 2012 – RTC consolidated judgment convicting petitioner for two counts of libel.
• August 17, 2015 – CA decision affirming RTC judgment.
• May 18, 2016 – CA resolution denying reconsideration.
• November 21, 2018 – Supreme Court decision.
Applicable Law
• 1987 Philippine Constitution – Guarantee of freedom of speech and press, subject to libel provisions.
• Revised Penal Code, Articles 353 (definition and penalties for libel) and 354 (qualifiedly privileged communications).
• Rule 45, Rules of Court – Petition for review on certiorari to the Supreme Court.
Antecedent Facts
Petitioner, as anchorman of “Ang Dating Daan,” aired taped broadcasts on July 31, 1998, containing epithets—“gago,” “tarantadong pastor,” “pastor ng demonyo,” “bulaang propeta”—directed at leaders and members of JMCIM. The first information (IR-4848) alleged defamation of the group’s leader, pastors, and members, while the second (IR-5273) focused on Evangelist Wilde E. Almeda. Both informations charged that these statements were malicious, false, and intended to dishonor the complainants.
Trial Proceedings
• Arraignment – Petitioner pleaded not guilty in both cases and posted cash bonds.
• Prosecution’s Evidence – Witnesses Eudes Cuadro, Joel Cortero, Jerry Cabanes, and Liza Martinez for IR-5273; Joel Cortero as sole witness for IR-4848.
• Defense Evidence – Testimony of Marlon Igana.
• Demurrer to Evidence – Filed December 22, 2008; denied January 6, 2009.
RTC Ruling
The RTC found all elements of libel proven: defamatory imputation, malice, publication, and identification. It imposed fines of ₱6,000 for each count, with subsidiary imprisonment in case of insolvency, and denied civil damages.
CA Ruling
On appeal, the CA affirmed the RTC’s consolidated judgment in its August 17, 2015 Decision and denied reconsideration on May 18, 2016, holding that the prosecution proved malice, dishonor, and publication beyond reasonable doubt.
Issues on Appeal
Petitioner contended that the CA erred by:
- Failing to show dishonor or discredit to the complainants.
- Disregarding the absence of malice or ill will.
- Lacking an identifiable person in the alleged libelous statements.
- Convicting him despite no knowledge or consent in publication.
- Impairing freedom of expression through a chilling effect.
Supreme Court Ruling
- Libel Elements – Article 353 requires defamatory imputation, malice, publicity, and identifiability. All elements for the count against Almeda (IR-5273) were met.
- Defamatory Character and Malice – The terms used were plainly insulting, lacking any justifiable motive or qualified privilege. The Court agreed with the CA that Soriano intended to discredit and humiliate the complainants.
- Publication – Broadcast over DZAL constituted sufficient publication.
- Identificatio
Case Syllabus (G.R. No. 225010)
Antecedent Facts
- Eliseo Soriano, anchorman of radio program “Ang Dating Daan” on DZAL, Iriga City, was indicted for libel on January 15, 1999.
- Two Informations were filed:
- Criminal Case No. IR-4848 (charged July 31, 1998 broadcast defamatory to the Jesus Miracle Crusade International Ministry, JMCIM).
- Criminal Case No. IR-5273 (charged July 31, 1998 broadcast defamatory to Evangelist Wilde E. Almeda, JMCIM leader).
- The allegedly libelous broadcast contained prepared taped remarks branding JMCIM’s leader and pastors with insulting epithets to expose them to public ridicule.
Criminal Charges
- IR-4848:
- Charges of libel for airing statements branding JMCIM’s leader as “BULAANG PROFETA, TARANTADO AT GAGO,” its pastors as “PASTOR NG DEMONYO…GAGO,” and its members as “SIRA ULO.”
- Accused of causing dishonor, discredit, and contempt to JMCIM.
- IR-5273:
- Charges of libel for airing statements calling Evangelist Wilde E. Almeda “BULAANG PROFETA,” “IDIOT,” and “APOSTLE OF DEMONS,” to destroy his reputation and expose him to public hatred.
Trial Proceedings
- Petitioner pleaded not guilty and posted cash bonds for provisional liberty in both cases.
- Prosecution witnesses:
- IR-4848: Joel Cortero.
- IR-5273: Eudes Cuadro, Joel Cortero, Jerry Cabanes, Liza Martinez.
- Defense witness: Marlon Igana.
- Petitioner filed a Demurrer to Evidence on December 22, 2008; RTC denied it on January 6, 2009.
Ruling of the Regional Trial Court
- Consolidated Judgment dated June 8, 2012 convicted petitioner of two counts of libel.
- Sentenced to pay a fine of