People v. Aquino
REITERATIONFacts
The Antecedents: Corazon Aquino was charged in three separate informations with grave oral defamation for allegedly uttering the words, "You Merrera lawyers, are stealers . . . shameless . . . impolite." The prosecution theorized that three separate crimes were committed because there were three lawyers with the surname "Merrera." Procedural History: The defense moved to consolidate the informations into one, arguing that since the defamatory statement was uttered only once and against a group without individual mention, only one offense was committed. The lower court granted the motion, ordering consolidation. The prosecution appealed this order. The Petition: The prosecution appealed the order of consolidation, asserting that multiple offenses were committed due to the multiple victims. The Supreme Court reviewed the propriety of the consolidation order.
Issue(s)
Whether the utterance of a single defamatory statement against a group of individuals not separately identified constitutes one or multiple offenses. Whether the lower court erred in consolidating the three informations into one.
Ruling
The Supreme Court affirmed the order of the lower court, holding that the utterance of the defamatory statement constituted only one offense and should be the subject of only one information.
Ratio Decidendi
On whether the utterance of a single defamatory statement against a group of individuals not separately identified constitutes one or multiple offenses: The Court held that the utterance of the defamatory statement complained of in the present case should be regarded as only one offense and the subject of only one information. This is because the utterance was made but once and referred apparently to a family of lawyers designated by their common surname but not separately mentioned. The Court cited common law principles where a libel on two or more persons contained in one writing and published by a single act is considered one offense, based on the reasoning that the law punishes the publication for its tendency to affect the peace and good order of society, not solely for the injury to individual reputation. The Court also noted that decisions holding that theft of properties belonging to different owners, when committed on the same occasion, constitutes only one crime of theft support this view. On whether the lower court erred in consolidating the three informations into one: The Court found no error in the lower court's order. The consolidation was based on the principle that a single utterance, even if directed at multiple individuals not individually named, constitutes a single offense. The Court's reasoning was further bolstered by its discussion on the nature of libel and defamation. It clarified that while some forms of defamation require prosecution at the instance of the offended party, a libel imputing a vice or defect, which does not constitute a crime but tends to cause dishonor, discredit, or contempt, is sufficient for jurisdiction upon the filing of an information by the prosecuting officer. This aligns with the idea that the act of publication, when done once, is the punishable offense, regardless of the number of individuals affected, unless the law specifically mandates otherwise for jurisdictional purposes.
Main Doctrine
The utterance of a defamatory statement made but once, even if directed at a group of individuals not separately mentioned, constitutes only one offense, and the jurisdiction of the court is sufficiently conferred by the filing of a single information.