Title
People vs Bustos
Case
G.R. No. L-12592
Decision Date
Mar 8, 1918
Citizens accused a justice of malfeasance; charged with libel, acquitted as statements were qualifiedly privileged, made in good faith without malice.

Case Summary (G.R. No. L-12592)

Administrative Investigation and Acquittal

The Executive Secretary referred the petition to the Judge of First Instance for investigation. The judge found two of three charges proved and recommended Punsalan’s removal. On motion for a new trial, the judge admitted additional letters asserting prosecutorial malice and acquitted Punsalan. An appeal to the Governor-General was noted, but the record is silent on further administrative action.

Criminal Information and Trial Proceedings

On October 12, 1916, the United States filed libel charges against the petitioners, alleging that their written accusations were false, defamatory, and published with malicious intent. The information selectively quoted the petition’s derogatory language but omitted references to the underlying administrative proceedings and affidavits.

Appeal and Assignments of Error

At trial before Judge Percy M. Moir, most defendants were convicted, fined ₱10 each, and assessed costs. Their post-verdict motion for a new trial (to retract an earlier objection to admission of the administrative record) was denied. On appeal, the defendants objected to:

  1. Denial of a new trial
  2. Refusal to allow withdrawal of objection to Exhibit A (administrative record)
  3. Exclusion of the underlying affidavits
  4. Failure to recognize the petition as privileged communication
  5. Shift of burden to defendants to prove truth and absence of malice
  6. Denial of acquittal

Jurisdiction Over the Administrative Record

Although defense counsel initially objected to Exhibit A, the Supreme Court deemed the administrative proceedings integral to the libel prosecution, relying on §42 of the Code of Criminal Procedure, the court’s power to call essential records, and judicial notice of official actions. Exclusion of such context would unfairly strip the petitioners of their justification defense.

Constitutional Guarantees of Free Speech, Press, Assembly, and Petition

The Court traced the evolution of these rights in the Philippines—from Rizal’s reform demands, the Malolos Constitution, U.S. constitutional precedents, President McKinley’s 1900 Instruction, the Philippine Bill of 1902, and the Jones Act of 1916—to establish that free expression and the right to petition public officials are fundamental and entrenched in the Islands’ organic law.

Qualified Privilege in Defamation Actions

Under established English and American jurisprudence, communications made in good faith on matters of public interest or duty to officials with corresponding responsibilities are “qualifiedly privileged.” Such privilege covers false statements if made without malice and with probable cause. The burden then shifts to the plaintiff to prove express malice. Honest mistakes, intemperate language, or misdirected communications do not automatically defeat the privilege so long as they arise from an honest sense of duty.

Application of Privilege to the Present Case

The petitioners acted in good faith, on probable cause, and through appropriate channels (the Executive Secretary, who held authority over Punsalan’s appointment and removal). They did not exploit the privilege for personal gain, nor was the

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