GR 206015; (June, 2021) (Digest)
G.R. No. 206015 , June 30, 2021
Claudio Daquer, Jr., Petitioner, vs. People of the Philippines, Respondent.
FACTS
Petitioner Claudio Daquer, Jr., a news editor/writer, was charged with two counts of libel under Articles 353 to 355 of the Revised Penal Code for articles he wrote and were published in the newspaper Palawan Mirror. The first article, dated April 4, 2003 and titled “KUTO NA NAIS MAGING KALABAW SA CITY HALL,” depicted private complainant Anrie A. Grande, a Sports Development Office III-Program Manager of the City Government of Puerto Princesa, in a derogatory manner, using terms like “kuto” (louse) and implying he was “stupid” and a “bully.” The second article, dated April 11, 2003 and titled “Unsolicited advice para sa ‘media pracs’,” further portrayed Grande as a “great pretender,” a “snake,” and one who boasted of controlling the local media. The Informations alleged these writings were made with malicious intent to impeach Grande’s honesty, virtue, and reputation, exposing him to public hatred and ridicule. Daquer pleaded not guilty. The Regional Trial Court found him guilty of two counts of libel and imposed a fine of P6,000.00 for each count. The Court of Appeals affirmed this decision. Daquer filed a Petition for Review on Certiorari.
ISSUE
Whether the Court of Appeals erred in affirming the conviction of Claudio Daquer, Jr. for libel, specifically concerning the requirement of proving “actual malice” given that the private complainant is a public officer.
RULING
The Supreme Court GRANTED the petition. The Court REVERSED and SET ASIDE the Court of Appeals Decision and Resolution. Claudio Daquer, Jr. was ACQUITTED of the crimes charged.
The Court ruled that in criminal libel cases where the complainant is a public figure, particularly a public officer, the prosecution must prove “actual malice” that the defendant made the statement with knowledge that it was false or with reckless disregard of whether it was false or not. This standard, rooted in the democratic principles of accountability and freedom of expression, places the burden of proving actual malice on the prosecution, not on the defense to disprove it. The Court found that the prosecution failed to discharge this burden. The articles, while harsh and critical, concerned Grande’s conduct and fitness for his public office as a sports development official, involving matters of public interest. The prosecution did not present evidence to show that Daquer published the statements knowing they were false or with reckless disregard for the truth. Mere derogatory remarks or insults, without proof of actual malice, are insufficient to sustain a conviction for libel when directed at a public officer regarding their official conduct. The constitutional guarantee of freedom of speech and the press requires that such comments on public officials be afforded protection unless actual malice is proven.