G.R. No. 248616 , January 12, 2021
Galileo A. Maglasang, Petitioner, vs. People of the Philippines, Respondent.

FACTS

Petitioner Galileo A. Maglasang was charged with libel under Article 353 of the Revised Penal Code. The charge stemmed from a letter-complaint he wrote and sent to Commodore Ferdinand M. Velasco, Commander of the Coast Guard District Northern Mindanao, dated March 30, 2014. In the letter, written in his capacity as President of the Misamis Institute of Technology, Inc. (MIT), Galileo alleged that CHED Region Office X had turned over Special Orders (S.O.’s) and Certifications, Authentication, and Verification (CAV’s) to Capt. Rene A. Maglasang (his brother) and Engr. Nelia Cocos, who in turn sold these documents to unsuspecting students and graduates of MIT. He stated that Rene and Engr. Cocos had nothing to do with MIT and did not have custody of the relevant academic records. The private complainants, Rene and Engr. Cocos, learned of the letter and felt insulted and maligned, leading them to file a complaint. During trial, the prosecution presented Rene and Ensign Ronnie Rey de la Vega Pabico of the Philippine Coast Guard (PCG). P/Ens Pabico testified about the existence of the letter in their office and presented a photocopy, as the original was unavailable. Galileo did not present evidence but argued in his memorandum that the original letter was not presented and its loss was not proven, warranting dismissal. The Regional Trial Court (RTC) found Galileo guilty beyond reasonable doubt and imposed a fine of P4,000.00. The Court of Appeals (CA) affirmed the RTC’s decision, holding that the photocopy was admissible and all elements of libel were present.

ISSUE

Whether the Court of Appeals erred in affirming Galileo’s conviction for libel, specifically regarding the admissibility of the photocopy of the letter as evidence and the presence of all elements of the crime.

RULING

The Supreme Court REVERSED and SET ASIDE the Decision and Resolution of the Court of Appeals and ACQUITTED Galileo A. Maglasang. The Court held that the prosecution failed to prove the corpus delicti of libel. The letter, being a private document, required proof of its due execution and authenticity before a copy could be admitted as secondary evidence. The prosecution did not establish that the original was lost or destroyed. P/Ens Pabico’s testimony revealed he was not the custodian of the document, had no personal knowledge of its receipt, and the photocopy he presented was obtained via email from a secretary who was no longer connected with the PCG. The original was never produced, and no testimony from the author (Galileo) or the recipient (Commo Velasco) was offered to authenticate it. Consequently, the photocopy was inadmissible as evidence. Without the letter, there was no proof of its alleged libelous content or its publication. Therefore, Galileo’s guilt was not proven beyond reasonable doubt.