GR L 12658; (August, 1917) (Digest)
G.R. No. L-12658; August 8, 1917
THE UNITED STATES, plaintiff-appellee, vs. MAGDALENA GRIÑO, defendant-appellant.
FACTS:
The accused, Magdalena Griño, signed and knowingly sent a letter to Pilar Trespeces, a married woman. In the letter, she accused Trespeces of having illicit relations with her (Griño’s) husband. The letter was “published” as understood under libel law. The accused admitted to sending the letter and did not show justifiable motives for her action. She raised sickness due to pregnancy as an excuse, but the primary motive was determined to be unreasoning jealousy. During arraignment, the accused waived the reading of the complaint and pleaded not guilty. The lower court convicted her and imposed a penalty of two months imprisonment and a fine of ₱250, with subsidiary imprisonment in case of insolvency.
ISSUE:
Whether the accused is guilty of libel and whether the penalty imposed by the lower court should be modified.
RULING:
Yes, the accused is guilty of libel. A written charge of unchastity or immorality against a married woman is libelous per se, as it is a base and vile means of humiliating and insulting her. All elements of libel were present: the defamatory imputation was made in writing, published, directed at a specific person, and without lawful justification. The Court rejected the accused’s assignments of error, noting that she had waived the reading of the complaint and that no justifiable motive was proven.
However, the Supreme Court modified the penalty. Considering the accused’s poor health, her pregnancy, and the limited publicity of the libel, the Court reduced the penalty to a fine of ₱250, with subsidiary imprisonment in case of insolvency, and costs. The imprisonment originally imposed was eliminated. The conviction was affirmed with the modified penalty.
Separate Opinion:
Justice Carson concurred in the conviction but believed the fine should be substantially nominal (₱5 to ₱25), given the circumstances of the accused’s pregnancy and unreasoning jealousy, and to avoid a long subsidiary imprisonment if she could not pay.
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