People v. Del Rosario
REITERATIONFacts
The Antecedents: A leaflet was published in Visaya, translated into English, containing defamatory imputations against two individuals, Morelos and Espina. Espina instituted a criminal action for libel against the defendants, which was assigned to one branch of the Court of First Instance of Cebu. Subsequently, Morelos also commenced a case against the same defendants for the same leaflet, assigned to another branch of the same court. Procedural History: The case commenced by Morelos was dismissed by the Court of First Instance of Cebu on a motion to quash. The trial court ruled that although two persons claimed to be aggrieved, the defamatory writing was the result of a single act of publication, thus constituting a single, complex crime of libel. The Petition: The People of the Philippines appealed the dismissal order, questioning the trial court's ruling that a libelous publication affecting more than one person constitutes only one crime.
Issue(s)
Whether a libelous publication affecting more than one person constitutes one crime or more than one crime. Whether the trial court erred in dismissing the complaint for libel on the ground that the publication, despite affecting two individuals, was a single act and thus a single offense.
Ruling
The Supreme Court reversed the order of dismissal and remanded the case to the court of origin for further proceedings. The Court held that a libelous publication affecting more than one person constitutes as many offenses of libel as there are persons defamed, and each offended party must file a separate complaint.
Ratio Decidendi
On the issue of whether a libelous publication affecting more than one person constitutes one crime or more than one crime: The Court held that the present Philippine law on libel conforms to the modern tendency where the criminality of a defamatory statement is based on its tendency to injure the person defamed, regardless of its effect upon the public. This is evidenced by the requirement that criminal actions for defamation, unless the imputation constitutes a crime that can be prosecuted de oficio, must be brought at the instance of and upon complaint expressly filed by the offended party or parties. The requirement for prosecution upon the complaint of the offended party amply illustrates the intendment and purpose to make injury to the honor and reputation of the persons libeled the dominant factor in the offense. Therefore, there are as many offenses of libel as there are persons libeled, and the computation of the number is not the publication but the writing or composing of the libel. The inclusion of several persons in a libel cannot, in the nature of things, be the product of one and the same act. On the issue of whether the trial court erred in dismissing the complaint for libel: The Court found that the trial court erred in ruling that the defamatory writing was the result of a single act and thus a single, complex crime. The common-law rule, which focuses on the publication as the gist of the offense and considers the effect on public peace and order, was distinguished from the modern tendency adopted in Philippine law, which emphasizes the injury to the honor and reputation of the individual. The fusion of calumny, insult, and libel into one definition (defamation) under the Revised Penal Code, and the adoption of the procedural rules for insult and calumny, support the view that each person defamed gives rise to an independent offense. The theory that only one prosecution may be instituted even though several persons are affected would lead to injustice to the offended parties, defeat some of the law's aims, and cause great inconvenience, such as depriving offended parties of their right to vindicate their honor and reputation or to recover damages in the criminal proceeding. The Court cited Spanish Supreme Court decisions supporting the principle that separate actions arise when distinct persons are defamed, even if contained in the same publication.
Main Doctrine
A publication containing defamatory imputations against more than one person constitutes as many offenses of libel as there are persons defamed, and each offended party must file a separate complaint for the prosecution of the offense against them.