Sazon vs CA 255 SCRA 692 [Case Digest]

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Sazon vs CA

255 SCRA 692

 

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Facts:

Private complainant and the petitioner ran in the election held by PML-Parang Bagong Lipunan Community Association, Inc. (PML-BLCA), an association of homeowners of PML Homes. The petitioner was elected as a director and president of the homeowners' association. Unable to accept defeat, the private complainant contested the said election. Private complainant also wrote his co-homeowners explaining to them his election protest and urging them not to recognize the petitioner and the other members who won in the election. A phrase "Sazon (petitioner), nasaan ang pondo ng simbahan?" was seen boldly written on the walls near the entrance gate of the subdivision. Thinking that only private complainant was responsible, petitioner Sazon wrote in an issue of PML-Homemakers, in which he is the editor, an article against the complainant using words such as "mandurugas," "mag-ingat sa panlilinlang," "matagal na tayong niloloko," "may kasamang pagyayabang," "angating pobreng super kulit," "patuloy na kabulastugan," "mastermind sa paninirang puri," etc. to describe him.

Issue:

Whether the questioned article written by the petitioner is libelous

Held:

            Yes.

Ratio:

The test to determine the defamatory character of words was satisfied in the case at bench because the words and phrases "mandurugas," "mag-ingat sa panlilinlang," "matagal na tayong niloloko," "may kasamang pagyayabang," "ang ating pobreng super kulit." "patuloy na kabulastugan," "mastermind sa paninirang puri," etc are indisputably defamatory for they impute upon the private complainant a condition that is dishonorable and shameful, since they tend to describe him as a swindler and/or a deceiver.

Submitted by: G-one T. Paisones

Submitted to: Atty. Cisco Franz S. Maclang