GR 211120; (February, 2017) (Digest)
G.R. No. 211120 , February 13, 2017
MEDEL ARNALDO B. BELEN, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.
FACTS
Petitioner Medel Arnaldo B. Belen, a lawyer, filed an estafa complaint against his uncle. The complaint was dismissed by Assistant City Prosecutor Ma. Victoria Sufiega-Lagman. Aggrieved, petitioner filed an Omnibus Motion for Reconsideration and Disqualification, which contained strong language criticizing the prosecutor’s resolution. He described her reasoning as “moronic,” stated she exhibited bias for “20,000 reasons,” and called her “stupid” and “intellectually infirm.” Copies were furnished to the respondent and the Department of Justice.
The Omnibus Motion was filed with the Office of the City Prosecutor. ACP Sufiega-Lagman learned of its contents from the respondent’s son and a staff member, obtained a copy, and subsequently filed a libel complaint against the petitioner. After preliminary investigation by a designated State Prosecutor, an Information for libel was filed against Belen. The Regional Trial Court convicted him, and the Court of Appeals affirmed the conviction.
ISSUE
Whether the petitioner is guilty of the crime of libel.
RULING
Yes, the petitioner is guilty of libel. The Supreme Court affirmed the lower courts’ findings. The elements of libel are present: the allegation was defamatory, malicious, given publicity, and the victim was identifiable. The statements in the Omnibus Motion, such as labeling the prosecutor “stupid” and “moronic,” were unequivocally defamatory. Malice is conclusively presumed when a defamatory statement is made, and the petitioner failed to prove the existence of any of the privileged communications under Article 354 of the Revised Penal Code that would negate malice.
The Court rejected the petitioner’s claim of qualifiedly privileged communication. While motions for reconsideration are generally privileged, this privilege is lost if the language used is unnecessarily abusive or insulting. The petitioner’s choice of words exceeded the bounds of fair criticism and legal discourse; they were personal, scurrilous attacks on the prosecutor’s intelligence and integrity, not a critique of her legal reasoning. The manner of publication was also established, as the motion was furnished to parties outside the official proceedings. However, modifying the penalty, the Court imposed only a fine of P6,000.00, considering the petitioner’s lack of prior conviction and that the defamatory statements arose from a legal proceeding where he felt aggrieved.