G.R. No. 1109 , May 15, 1903
THE UNITED STATES, complainant-appellee, vs. JOSE M. LERMA, defendant-appellant.

FACTS:
The defendant, Jose M. Lerma, was convicted of libel for publishing a defamatory writing against J. H. Goldman, the provincial governor. The libelous matter was contained in a petition, signed by Lerma and enclosed in a sealed envelope, addressed to the justice of the peace of Pilar, Bataan. At the time, several criminal prosecutions were pending against Lerma before that justice. The petition alleged that the accusations against him were fabricated and false, and specifically stated that Governor Goldman, “availing himself of the office which he holds as a provincial authority, has extorted affidavits from certain persons whom he has caused to sign incorrect documents.” The petition was presented during the preliminary investigation of one of the cases. The defense claimed the communication was privileged.

ISSUE:
Whether the defendant’s written communication to the justice of the peace constitutes a privileged communication, thereby relieving him from criminal liability for libel.

RULING:
Yes. The Supreme Court reversed the conviction and acquitted the defendant.
The Court held that the writing was a privileged communication under Section 9 of Act No. 277 (the Libel Law). The document was a private communication made in good faith, in the performance of a duty (legal or social), with the fair and reasonable purpose of protecting the interests of the person making it. It was addressed solely to the judicial officer conducting a proceeding in which the defendant was a party, for the purpose of exculpating himself from pending criminal charges. The Court found no evidence that the defendant intended the communication for any other purpose, such as publicly slandering the governor. Consequently, the defendant is not guilty of libel as the writing falls within the protective scope of a privileged communication.