G.R. No. L-11067; March 6, 1917
THE UNITED STATES, plaintiff-appellant, vs. VICENTE SOTTO, defendant-appellee.

FACTS:
The defendant, Vicente Sotto, was the director, editor, manager, and printer of the weekly paper “The Independent.” He was charged with libel under Act No. 277. The information alleged that from May 1 to May 22, 1915, in Manila, Sotto published a defamatory article (the first publication) on page 23 of the May 1, 1915 issue. This article, written under the pseudonym “VICTI,” attacked unnamed labor leaders of the “Congreso Obrero de Filipinas,” accusing them generally of malversation of funds, causing the bankruptcy of “Tagumpay,” being responsible for the “Katubusan scandals,” the disappearance of a promissory note from the office of Attorney Diokno, misappropriation of funds in “El Ideal,” and causing the failure of the seamen and street-car employees’ strikes. The information further alleged that this libel was amplified by a cartoon (the second publication) on page 1 of the May 22, 1915 issue. The cartoon depicted caricatures labeled as Lope K. Santos, Jose Turiano Santiago, and Hermenegildo Cruz, with banners attaching specific accusations from the article to each individual, thereby identifying them as the targets of the first publication. A demurrer was filed in the Court of First Instance on the grounds that (a) more than one offense was charged, and (b) the facts charged did not constitute a public offense. The trial court sustained the demurrer on the first ground and dismissed the information. The government appealed.

ISSUE:
Whether the information charges more than one offense of libel by joining two separate publications (the article and the cartoon).

RULING:
No. The Supreme Court reversed the judgment and overruled the demurrer. The Court held that the two publications could properly be joined in one information to charge a single offense of libel. The first publication made general accusations without naming specific individuals. The second publication (the cartoon) served to identify the persons referred to in the first publication and to specify which accusation applied to each individual. Together, they completed the libelous matter. The Court explained that a libel may be published in parts, and different publications constituting a libel may be joined in one indictment if they refer to the same subject matter and are necessary or convenient to complete each othersuch as to avoid ambiguity, identify the persons defamed, or show the character of the acts charged. This joinder is permissible even if each publication could separately constitute a libel. In this case, the prosecutor properly combined the publications to present a complete charge. The accused could therefore be convicted of only one crime under the information. The case was remanded to the trial court for further proceedings.

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