Villanueva vs People 521 Phil. 191 [Case Digest]

68 – Slander

Villanueva vs People

521 Phil. 191 [Case Digest]

 

Facts:

            On September 12, 1994 at the SB Office in the Municipal Building of Concepcion, Tarlac, in the presence of several persons and again in the afternoon on or about four thirty (4:30 PM) at the Old Session Hall of the Municipal Building in presence of the complainant and in the presence of several persons, defendant NOEL L. VILLANUEVA, in a loud voice and within hearing distance of everyone present, uttered in a serious and insulting manner at the undersigned complainant the following words: ["]Nagmamalinis ca, ena ca man malinis, garapal ca["] and "Balamu mansanas cang malutu, pero queng quilib ularan ca, tictac carinat" (You are pretending to be clean and honest yet you are not clean and honest, you are corrupt; you are like a red apple, but inside you are worm infested and extremely dirty).

Issue:

            Whether or not the accused is guilty of Grave Oral Defamation

Held:

            No. The accused is guilty only of slight oral defamation

Ratio:

            There is grave slander when it is of a serious and insulting nature. The gravity of the oral defamation depends not only (1) upon the expressions used, but also (2) on the personal relations of the accused and the offended party, and (3) the circumstances surrounding the case.

However, SC, likewise, ruled in the past that uttering defamatory words in the heat of anger, with some provocation on the part of the offended party constitutes only a light felony.

Submitted by:  G-one T. Paisones

Submitted to: Atty. Cisco Franz S. Maclang