G.R. No. 200148 , June 4, 2014
RAMON A. SYHUNLIONG, Petitioner, vs. TERESITA D. RIVERA, Respondent.

FACTS

Petitioner Ramon A. Syhunliong, President of BANFF Realty and Development Corporation, filed a complaint for libel against respondent Teresita D. Rivera, BANFF’s former Accounting Manager. The case stemmed from two text messages Rivera sent on April 6, 2006, to a company cellular phone held by her successor, Jennifer Lumapas. The messages pertained to Rivera’s request for the payment of her remaining salaries, benefits, and incentives, stating she had suffered greatly in getting her last pay and did not deserve it as she did her job, and included the phrase “God bless ras[,] [S]ana yung pagsimba niya, alam niya real meaning.” In December 2006, Rivera filed a labor complaint against Syhunliong for monetary claims. Subsequently, on April 16, 2007, Syhunliong instituted the libel complaint. An Information was filed charging Rivera with libel. Rivera filed a Motion to Quash, arguing the text messages did not constitute libel as they lacked malice and were not for public consumption, being a private communication made in defense of her interests. The Regional Trial Court (RTC) denied the motion, ruling the grounds were evidentiary and required a full trial, and that probable cause existed. The RTC also denied Rivera’s motion for reconsideration. Rivera then filed a Petition for Certiorari with the Court of Appeals (CA).

ISSUE

Whether the facts charged in the Information for libel constitute an offense, warranting the grant of the Motion to Quash.

RULING

The Court of Appeals granted Rivera’s petition and dismissed the libel information. The CA ruled that the text messages, viewed in their entirety and in context, were not libelous. They were a mere expression of Rivera’s grievance over unpaid wages, addressed privately to a company officer (Lumapas) who had a duty to address such concerns. The messages did not contain a defamatory imputation; the statement about Syhunliong’s church-going was an expression of opinion made in good faith, without malice, in the context of a labor dispute. The communication was qualifiedly privileged, as Rivera had a legitimate interest to protect (her unpaid claims), the communication was addressed to a person in authority who could act on it, and it was made in good faith. Since the facts alleged did not constitute the crime of libel, the Motion to Quash was properly granted. The CA set aside the RTC orders and directed the dismissal of Criminal Case No. Q-07-147802.