Title
Soriano vs. People
Case
G.R. No. 225010
Decision Date
Nov 21, 2018
Eliseo Soriano convicted of libel for defamatory statements against Evangelist Wilde Almeda on his radio program; acquitted in a separate case due to lack of identifiable defamed individuals.

Case Summary (G.R. No. 225010)

Petitioner

Eliseo Soriano was charged in two separate informations arising from a taped radio broadcast aired on July 31, 1998, in which he allegedly used terms such as “gago,” “tarantadong pastor,” “pastor ng demonyo,” and “bulaang propeta” in reference to Evangelist Wilde Almeda and the Jesus Miracle Crusade International Ministry.

Respondent

The People of the Philippines prosecuted the criminal libel complaints filed by pastors and the leader of JMCIM; the case was litigated through the RTC and the CA and reviewed by the Supreme Court by petition for review on certiorari under Rule 45.

Key Dates

Alleged broadcast: July 31, 1998. Informations filed: Criminal Case No. IR-4848 (indicted January 15, 1999) and Criminal Case No. IR-5273 (filed June 9, 2000). RTC consolidated judgment: June 8, 2012. CA decision affirming RTC: August 17, 2015. Supreme Court decision: November 21, 2018.

Applicable Law and Standards

Primary penal provisions: Article 353 (definition of libel) and Article 354 (presumption of malice; qualifiedly privileged communications) of the Revised Penal Code. Constitutional consideration: freedom of speech and religion under the 1987 Constitution as guiding context for claims that the speech was protected. Legal standards for libel require proof beyond reasonable doubt of (a) defamatory imputation, (b) malice, (c) publicity, and (d) identification of the victim.

Facts and Charges

Two informations alleged that petitioner, by broadcasting a prepared tape on his radio program, maliciously and publicly uttered false and defamatory statements designed to expose to public ridicule and discredit (1) the persons comprising JMCIM (IR-4848) and (2) Evangelist Wilde Almeda personally (IR-5273). The informations quoted portions of the taped broadcast containing the insulting and disparaging language.

Trial Record and Procedure

Petitioner pleaded not guilty and was released on cash bonds. The prosecution presented multiple witnesses (including Joel Cortero, Eudes Cuadro, Jerry Cabanes, and Liza Martinez) primarily for IR-5273; Joel Cortero also testified in IR-4848. The defense presented Marlon Igana. Petitioner filed a demurrer to evidence which the RTC denied. After trial, the RTC found petitioner guilty of both counts; the CA affirmed that judgment on appeal.

RTC Disposition

The RTC consolidated the cases and found petitioner guilty of libel in both cases. Pursuant to Administrative Circular No. 08-2008, the RTC imposed fines of P6,000.00 for each case in lieu of imprisonment, with subsidiary imprisonment in case of insolvency, and awarded no civil damages.

Issues Presented on Review

Petitioner contended that: (1) the prosecution failed to prove dishonor or discredit and malice; (2) no identifiable person was targeted by the alleged libel in at least one information; (3) petitioner did not have knowledge or consent regarding publication of the taped material; and (4) the conviction impermissibly chilled constitutionally protected freedom of expression and religious speech.

Supreme Court Holding (Overview)

The Supreme Court partially granted the petition. It affirmed petitioner’s conviction for libel in Criminal Case No. IR-5273 (statements directed at Evangelist Wilde Almeda) and reversed/acquitted petitioner in Criminal Case No. IR-4848 (statements alleged to be directed at the JMCIM as a group). The Court applied the 1987 Constitution in assessing free speech claims and applied the statutory elements of libel under Articles 353–354.

Legal Analysis — Defamatory Imputation

The Court reiterated the statutory definition of libel (Article 353) and the established test for defamatory imputation: whether the words, taken in their plain, natural, and ordinary meaning, tend to dishonor, discredit, or expose the subject to public ridicule. The Court found that the quoted epithets (“gago,” “tarantadong pastor,” “pastor ng demonyo,” “bulaang propeta”) are injurious and disparaging when applied to a religious leader, and therefore satisfy the defamatory element as to Almeda. The Court relied on precedent emphasizing that words calculated to impeach honesty, virtue, or to hold a person up to public ridicule are defamatory.

Legal Analysis — Malice and Qualified Privilege

Article 354 presumes malice for defamatory imputations unless a good intention and justifiable motive are shown, except in specified privileged communications or fair commentaries on matters of public interest. The Court examined petitioner’s asserted motive (to warn against misuse of religion in politics) and found no justification in the language used; the expressions employed were insulting and degrading rather than fair or temperate commentary. The Court sustained the CA’s finding of actual malice: petitioner’s language manifested an apparent intent to discredit and humiliate Almeda and his followers, which negated any qualified privilege or fair-comment defense.

Legal Analysis — Publication

The Court confirmed publication as established by the broadcast over petitioner’s radio program. In libel law, broadcasting a defamatory statement to third persons constitutes publication because the defamatory matter is made known to persons other than the author and the offended party.

Legal Analysis — Identification and Group Libel

A critical distinction underlies the Court’s differing rulings on the two informations. For libel to be actionable by an individual, the victim must be identifiable. The Court applied its prior ruling in MVRS Publications v. Islamic Da’wah Council: statements about a large, unspecified class cannot, without circumstances pointing to a particular member, be the basis of individual libel actions. The Court found that Criminal Case No. IR-4848 alleged defamation against “persons comprising the JMCIM” and did not identify specific pastors or members with sufficient particularity; thus, the group-targeted averments could not sustain an individual libel conviction and warranted acquittal on that count. By contrast, Criminal Case No. IR-5273 referenced Wilde Almeda and the Court found the statements identifiable as to him, supporting conviction on that

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