GR L 74907; (May, 1988) (Digest)
G.R. No. L-74907. May 23, 1988
PEDRO S. LACSA, petitioner, vs. HONORABLE INTERMEDIATE APPELLATE COURT and PEOPLE OF THE PHILIPPINES, respondents.
FACTS
Petitioner Pedro S. Lacsa, a CPA and former director of the Philippine Columbian Association (PCA), volunteered as its auditor. In that capacity, he accessed member records and concluded that private complainant Ponciano C. Marquez, the PCA President, was only an associate member, not a proprietary member as required for the presidency. On December 21, 1978, Lacsa wrote to the PCA Board, contending that the issuance of a proprietary membership certificate to Marquez was erroneous. On January 2, 1979, he sent a letter directly to Marquez, urging him to “yield the Presidency” and branding him a “de facto president.” Lacsa circulated this letter among numerous PCA members and later caused the publication of a newsletter item entitled “Doubt As To the Legitimacy Of The Incumbent President.” Consequently, Marquez filed a criminal complaint for libel.
ISSUE
Whether the petitioner is guilty of the crime of libel for his imputations against the private complainant.
RULING
The Supreme Court affirmed the conviction. The Court applied the established test for libel, stating that words calculated to induce suspicion and hold a person up to public ridicule are defamatory. The term “de facto president,” in the context of Lacsa’s letters and newsletter, clearly imputed that Marquez was unlawfully holding office, thereby impeaching his honesty and virtue. The communication was not privileged. While Lacsa claimed he was performing a moral and social duty, his actions demonstrated malice and lack of good faith. Ordinary prudence demanded that he first formally report his findings solely to the PCA Board, the proper body to address membership issues. Instead, he precipitously and publicly circulated his accusations. The Court noted that his motive was suspect, as the appellate court found he felt aggrieved after not being appointed to a preferred committee position. His claim of harassment was unsupported. Thus, all elements of libel were present: the imputation was defamatory, malicious, public, and identified the complainant. The decisions of the lower courts were upheld.