GR 212623; (January, 2016) (Digest)
G.R. No. 212623, January 11, 2016
Enrique G. De Leon vs. People of the Philippines and SPO3 Pedrito L. Leonardo
FACTS
Petitioner Enrique De Leon was charged with Grave Oral Defamation for allegedly uttering defamatory words against SPO3 Pedrito Leonardo. The prosecution alleged that on April 17, 2006, at the Manila City Hall, De Leon publicly told Leonardo, “WALANGHIYA KANG MANGONGOTONG NA PULIS KA, ANG YABANG YABANG MO NOON. PATAY KA SA AKIN MAMAYA,” in the presence of several persons. This stemmed from a prior administrative complaint for grave misconduct filed by De Leon and his son against Leonardo. The defense presented a contrary version, claiming it was Leonardo who uttered threats against De Leon at the same venue. The Metropolitan Trial Court convicted De Leon of Grave Oral Defamation, a ruling affirmed by the Regional Trial Court and the Court of Appeals.
ISSUE
Whether the Court of Appeals erred in affirming petitioner De Leon’s conviction for Grave Oral Defamation.
RULING
The Supreme Court PARTIALLY GRANTED the petition, modifying the conviction from Grave to Slight Oral Defamation. The Court upheld the factual findings of the lower courts that De Leon indeed uttered the defamatory words. However, it reclassified the crime based on the requisite proof of the gravity of the offense. For oral defamation to be considered grave, the prosecution must establish that the defamatory words were uttered with serious insult or in a contemptuous manner, considering the social standing of the offended party. The Court found that the words, while insulting, did not per se constitute a serious insult that would automatically classify the defamation as grave. The prosecution failed to present clear and convincing evidence of the specific circumstances—such as the tone, voice, and attitude of the accused—that would elevate the defamation to a grave nature. Consequently, in the absence of such proof, the crime is deemed to be of the lesser form. The penalty was accordingly reduced to a fine. The dissent argued for acquittal, citing reasonable doubt due to the conflicting testimonies and the failure to prove malice beyond reasonable doubt.