Here’s a digest of the case:

FACTS:
The article complained of in the lower court was unquestionably libelous. The defendant-appellant, JOSE CRAME, argued on appeal that there was no proof he published the article. He also contended that Exhibit A, a copy of the newspaper where the article appeared, was not sufficiently identified, despite him being the alleged editor and publisher. However, a typesetter for the newspaper provided direct testimony that the defendant handed him the article, written in the defendant’s own handwriting, to be set up in type.

ISSUE:
Was there sufficient proof that JOSE CRAME published the libelous article within the meaning of the law?

RULING:
Yes. The Supreme Court ruled that the direct evidence from the typesetter, stating that the defendant handed him the article (in the defendant’s handwriting) for typesetting, constituted sufficient publication under section 5 of Act No. 277 . The Court found the appellant’s argument regarding the identification of Exhibit A to be of no importance given this direct testimony. The judgment of the court below was affirmed.