G.R. No. L-11612; June 21, 1918
THE UNITED STATES, plaintiff-appellee, vs. SIMEON CAÑETE, ET AL., defendants-appellants.

FACTS:
The appellants were charged with libel in two separate cases (consolidated for trial) for signing and presenting a written complaint to the Roman Catholic Archbishop of Manila. The complaint accused Rev. Nicanor Acebedo, the parish priest of Dagami, Leyte, of serious misconduct including maladministration, misappropriation of church funds, drunkenness, and illicit relations with Timotea Camposano. The document, signed by a large number of prominent residents of Dagami, requested an ecclesiastical investigation and the priest’s removal. The appellants, led by Simeon Cañete, delivered the complaint to the Archbishop, who referred it to the proper Bishop. The ecclesiastical authorities indicated that an investigation would require the complainants to deposit funds for costs. Unable or unwilling to pay, the appellants took no further action within the church, and the criminal prosecutions for libel ensued. The trial court convicted some of the appellants. They appealed, admitting the defamatory nature of the publication but defending on the grounds of truth and qualified privilege.

ISSUE:
Whether the written complaint addressed to the church authorities constitutes a privileged communication, thereby exempting the appellants from criminal liability for libel.

RULING:
Yes. The Supreme Court reversed the trial court’s judgment and acquitted the appellants. The Court held that the communication was protected by a qualified privilege. The right to petition for redress of grievances, anchored in the fundamental principles of the Philippine Bill and the Jones Law (which guarantee freedom of speech), extends to complaints made in good faith to the proper supervising authorities regarding the misconduct of public officials or, by analogy, religious leaders. For the privilege to apply, the complaint must be: (1) made to a functionary with authority to redress the grievance; (2) made in good faith; and (3) not actuated by actual malice. The Court found that the appellants, representing a widespread sentiment in their community, acted in good faith to secure an ecclesiastical investigation without actual malice. Their honest mistake in addressing the Archbishop instead of the immediate Bishop did not defeat the privilege. The failure of the Libel Law ( Act No. 277 ) to expressly provide for such a privilege does not abrogate the constitutional right. Since the appellants’ conduct conformed to the conditions of qualified privilege, they incurred no criminal liability.