Case Summary (G.R. No. 32836-37)
Background and Administrative Charges
Atty. Vivencio Ruiz, who served as the legal counsel for Exequiel Victorio from 1953 until 1963, became embroiled in an administrative case precipitated by Exequiel and his wife, who accused him alongside Judge Alfredo Guiang. This administrative charge sought disbarment and was assigned to Judge Avancena for investigation. The incident, including Atty. Castillo's move to disqualify Judge Avancena, set the stage for the subsequent oral defamation charge.
Incident Leading to Criminal Charges
On January 9, 1964, after the hearing in Judge Avancena's sala, Daniel and Exequiel Victorio were heard making defamatory statements against Atty. Ruiz in the presence of bystanders, including a policeman, Emiliano Manuzon. The statements included vulgar language directed at Atty. Ruiz, characterizing him as arrogant, unfit, greedy, and a thief, which became the basis for their criminal prosecution for serious oral defamation.
Legal Proceedings and Charges
The petitioners were charged with serious oral defamation on February 8, 1964, in the City Court of Cabanatuan City. The information charged them with willfully uttering defamatory words to dishonor Atty. Ruiz. Upon arraignment, both petitioners pleaded not guilty, and the joint trial followed, leading to their conviction on April 10, 1968.
Trial Court's Conviction and Penalty
The City Court found both petitioners guilty of grave oral defamation, sentencing each to six months and one day of imprisonment. The petitioners' motion for reconsideration was denied, and they subsequently appealed to the Court of Appeals.
Court of Appeals' Decision
The Court of Appeals affirmed the trial court’s decision but modified the penalty to an indeterminate sentence ranging from one month and one day of arresto mayor to one year and one day of prision correccional. The appellate court’s resolution denying the petitioners’ motion for reconsideration became part of the petition filed with the Supreme Court.
Supreme Court's Review and Findings
The Supreme Court, upon reviewing the facts, noted that the sole issue rested on whether the uttered words constituted grave or merely slight oral defamation. The Court found that the words hurled were defamatory in nature and intrinsically serious, especially given the context—attacking Atty. Ruiz’s professional standing as a lawyer.
Determination of Serious Oral Defamation
The Court reaffirmed definitions distinguishing between grave and slight oral defamation, emphasizing that words implying serious criminality, such as estafa, inherently qualify as grave oral defamation. The totality of the petitioners’ comments against Atty. Ruiz was deemed serious enough to warrant this categorization.
Rejection of Petitioners' Argument
Contrary to the petitioners' position, which leaned on previous rulings that anger could mitigate def
...continue readingCase Syllabus (G.R. No. 32836-37)
Case Overview
- This case involves a petition for review by certiorari by petitioners Daniel Victorio and Exequiel Victorio against the decision of the Court of Appeals dated July 27, 1970, affirming their conviction for grave oral defamation.
- The case number is G.R. Nos. L-32836-37, decided by the Third Division on May 31, 1989.
- The Court of Appeals modified the sentence imposed by the lower court.
Background Facts
- Atty. Vivencio Ruiz, a well-respected lawyer, served as counsel for Exequiel Victorio from 1953 to 1963 before Exequiel hired Atty. L. Castillo.
- An administrative case was filed by the Victorio family against Judge Alfredo Guiang, which led to further complications in the legal proceedings.
- The incident that sparked the charge of oral defamation occurred on January 9, 1964, during a hearing presided over by Judge Ramon Avancena.
Incident Description
- During a heated moment in the courtroom, Atty. Castillo presented a motion to disqualify Judge Avancena, leading to a confrontation where Atty. Ruiz sought to have him cited for contempt.
- After the hearing, while walking down the corridor, both petitioners were overheard making derogatory remarks about Atty. Ruiz, calling him names such as "suwapang" (greedy) and "estapador" (swindler).
Charges and Proceedings
- On February 8, 1964, both petitioners were charged with seri