People v. Santiago
REITERATIONFacts
The Antecedents: The information alleged that the accused, Isauro Santiago, committed libel by making defamatory statements against Mayor Arsenio H. Lacson during a political speech using an amplifier system. The statements imputed grave offenses to Mayor Lacson. Procedural History: The accused filed a motion to quash the information, arguing that the crime charged was oral defamation, not libel, and that oral defamation had already prescribed. The Court of First Instance granted the motion and quashed the information. The Petition: The prosecution appealed the quashing of the information, maintaining that the use of an amplifier system constituted a means similar to radio, thus falling under the definition of libel.
Issue(s)
Whether the defamatory statements made through an amplifier system constitute libel under Article 355 of the Revised Penal Code or oral defamation under Article 358. Whether the crime charged had prescribed.
Ruling
The Supreme Court affirmed the order of the Court of First Instance, quashing the information. The Court ruled that the crime charged was oral defamation, not libel, and that it had prescribed.
Ratio Decidendi
On the classification of the crime: The Court held that the defamatory statements made through an "amplifier system" do not fall under the definition of libel as provided in Article 355 of the Revised Penal Code. The Court distinguished "radio" from an "amplifier system," noting that radio involves the transmission and reception of electromagnetic waves without conducting wires, whereas an amplifier system uses conducting wires. Furthermore, the Court emphasized that the means enumerated in Article 355, such as writing, printing, and radio, share a common characteristic of having a permanent nature as a means of publication. This permanence explains the graver penalty for libel compared to oral defamation. An amplifier system, by its nature, amplifies spoken words which are transient, thus lacking the permanent quality inherent in the means listed for libel. Therefore, the statements made via an amplifier system, if defamatory, constitute oral defamation (slander) under Article 358 of the Revised Penal Code. On prescription: The Court noted that oral defamation, as defined in Article 358, prescribes six (6) months after its commission, pursuant to Articles 90 and 91 of the Revised Penal Code. The alleged defamatory statements were made on October 5, 1959. The information was filed on August 11, 1960. Since the prescriptive period for oral defamation is six months, it would have prescribed on April 5, 1960, which was over four months before the information was filed. Consequently, the motion to quash based on prescription was correctly granted.
Main Doctrine
The use of an amplifier system for defamatory statements does not constitute libel under Article 355 of the Revised Penal Code, as it is not a means 'similar' to those enumerated therein, which all possess a permanent nature, unlike the transient nature of spoken words amplified. Such statements, if defamatory, fall under oral defamation (slander) under Article 358, which has a shorter prescriptive period.