GR L 2254; (April, 1950) (Digest)
G.R. No. L-2254; April 20, 1950
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. VICENTE O. DEL ROSARIO and NATALIO B. BACALSO, defendants-appellees.
FACTS
The defendants published a leaflet containing defamatory statements against two individuals, Morelos and Espina. Espina filed a criminal libel case, which was assigned to one branch of the Court of First Instance of Cebu. Subsequently, Morelos filed a separate libel case based on the same publication, which was assigned to another branch presided by Judge Felix Martinez. The trial court (Judge Martinez) granted the defendants’ motion to quash the second complaint, ruling that the libelous publication, though affecting two persons, was the result of a single act of publication and therefore constituted only one complex crime under Article 48 of the Revised Penal Code.
ISSUE
Whether a single libelous publication that defames two or more persons constitutes one crime or multiple crimes.
RULING
The Supreme Court reversed the trial court’s order and held that the publication constitutes as many crimes of libel as there are persons defamed. The Court rejected the common-law rule (which focused on the act of publication as tending to breach public peace) cited by the trial court. Instead, it emphasized that under the Revised Penal Code, libel is treated as a crime against honor, prosecuted primarily at the instance of the offended party. Each offended party has an independent right to vindicate their honor, recover damages, and prove the falsity or malice of the imputation. To hold otherwise would cause injustice, deprive offended parties of their rights, and defeat the aims of the law. The case was remanded to the trial court for further proceedings.
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