G.R. No. L-1409

FACTS:
The defendant-appellant, William Crozier, was the proprietor of “The Manila American,” a newspaper published in Manila. On February 18, 1903, the paper published an editorial concerning General George W. Davis’s review of the court-martial acquittal of Major Glenn. The editorial accused General Davis of appending “unnecessary and unjust remarks” to the court’s findings to ingratiate himself with the White House for his own ambition, and implied he approved of atrocities against American soldiers and Filipino civilians. Based on this article, Crozier was charged with criminal libel under Act No. 277 of the Philippine Commission. During trial, evidence showed that Crozier later published a retraction, admitting the article was “unwarranted and unjust” and reflected without just reason upon General Davis’s motives and integrity.

ISSUE:
Whether the appellant, William Crozier, is guilty of the crime of libel as defined under Act No. 277 .

RULING:
Yes, the appellant is guilty of libel. The Court found that the published editorial was a malicious defamation that tended to impeach the honesty, virtue, and reputation of General Davis and expose him to public hatred, contempt, or ridicule, thus falling within the definition of libel under Section 1 of Act No. 277 . The libelous matter was false, as admitted by the appellant’s own retraction. No evidence was presented to show that the publication was made with good motives or for justifiable ends; therefore, under Section 3 of the Act, the publication was presumed malicious. The defense’s claim that the prosecution failed to prove the existence of General Davis was dismissed, as the appellant’s own retraction established the identity of the person defamed. The sentence of the trial court was affirmed.