GODOFREDO V. ARQUIZA, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.
FACTS
Petitioner Godofredo V. Arquiza was charged with libel under Article 353 of the Revised Penal Code. The Information alleged that on or about September 11, 2012, in Quezon City, Arquiza, acting with malice, filed a “Petition to Deny Due Course or Cancel the Certificate of Nomination of Party List Nominees” before the COMELEC against Francisco G. Datol, Jr., a nominee of the Senior Citizen Party-List. The petition contained the statements: “14. As indications of his criminal bent, Datol, Jr had a string of criminal cases showing his propensity and predisposition to commit illegal and unlawful acts.” and “55. Moreover, Datol, Jr. is a fugitive from justice and cannot be allowed to participate in any election as provided under the Omnibus Election Code.” Datol claimed these statements were malicious and defamatory, imputing a crime, vice, or defect upon him, and were made public by filing the petition and sending copies to several other persons, causing him damage and prejudice. Upon arraignment, petitioner pleaded not guilty. The Regional Trial Court convicted Arquiza of libel, a decision affirmed by the Court of Appeals.
ISSUE
Whether the petitioner’s defamatory statements made in a petition filed before the Commission on Elections (COMELEC) are covered by absolute privilege or immunity from suit for libel.
RULING
The Supreme Court GRANTED the petition. The statements made by the petitioner in his COMELEC petition are absolutely privileged and cannot be the basis for a libel suit. Absolute immunity from suit applies to defamatory statements made not only in judicial proceedings but also in quasi-judicial proceedings, which includes steps necessarily preliminary thereto. This privilege applies provided that: (1) the quasi-judicial proceedings afford procedural protections similar to those in judicial proceedings; (2) the statement is relevant to the proceedings; and (3) the statement is communicated by the author only to those who have a duty to perform with respect to the document and to those legally required to be served a copy thereof. The COMELEC, in resolving petitions to deny due course or cancel certificates of nomination, exercises quasi-judicial functions. Its proceedings under COMELEC Resolution No. 9366 provide adversarial and adjudicatory procedural protections akin to a judicial proceeding, such as the filing of a verified petition, service of summons, opportunity to answer, conduct of hearings, presentation of evidence, and the issuance of a final order or decision. The petitioner’s statements were relevant to the qualification of Datol as a party-list nominee. Furthermore, the filing of the petition with the COMELEC and its service to necessary parties are communications made only to those with a duty in relation to the proceedings. Therefore, the petitioner enjoys absolute immunity, and the libel case against him must be dismissed.
