People v. Cortez
REITERATIONFacts
The Antecedents: A complaint for grave slander was filed against Nelly P. Cortez by Julita Santos, alleging that on November 14, 1963, in Manila, Cortez uttered slanderous words against Santos, a married woman of good reputation, such as "Matanda kang walang hiya, anak mo na lamang nagpapaasawa ka pa, kaya ikaw ay hiniwalayan ng asawa mo dahil sa gawain mo, ang sabi ng asawa ko ay nagpapaasawa ka sa kanya, iyon pumunta ka roon sa Kalunya mo" and other similar expressions, intending to bring her into public disgrace, contempt, and ridicule. Procedural History: On January 30, 1964, during the arraignment, the defendant, Nelly P. Cortez, pleaded not guilty to the charge. The hearing was initially set for February 6, 1964, but was postponed to March 3, 1964, upon request of her counsel de oficio to allow for preparation. On March 3, 1964, the trial court rendered a decision stating that the accused voluntarily and spontaneously entered a plea of guilty, despite being informed of the consequences. Consequently, the court found Cortez guilty of grave slander and sentenced her to four (4) months and one (1) day of arresto mayor, with accessory penalties, and to pay costs, appreciating the voluntary plea of guilty as a mitigating circumstance. The accused filed a notice of appeal to the Court of Appeals, which certified the case to the Supreme Court as it involved only questions of law. The Appeal: In her brief before the Supreme Court, the appellant contended that she did not plead guilty and that no plea of guilty was entered of record as required by the Rules. She argued that a missing page from the trial court's record, allegedly containing the stenographic recording of the March 3, 1964 proceedings, prevented her from proving her claim. She stressed that the only plea of record was "not guilty" entered on January 30, 1964. With the conformity of the Solicitor General, she asked for the remand of the case for trial. However, the Supreme Court noted that in her earlier pleadings filed in the Court of Appeals, specifically a motion of April 30, 1964, with an annexed affidavit, and a supplemental motion of May 10, 1964, the appellant admitted to having pleaded guilty but argued that the court should have allowed her to present evidence to determine the graveness of the offense and the penalty. In her affidavit, she stated she appealed not for reversal but for modification of the penalty, which she found harsh. She also admitted declining counsel de oficio and being "deadset to plead guilty," having been induced by the de oficio lawyer's assurance of a small fine.
Issue(s)
Whether the appellant's plea of guilty, as stated in the trial court's decision, is valid despite the alleged absence of a stenographic record of the arraignment on March 3, 1964. Whether the penalty imposed by the trial court for grave slander is correct.
Ruling
The Supreme Court affirmed the appealed judgment. The Court found sufficient evidence on record to establish that the appellant had indeed pleaded guilty. The penalty imposed was also found to be correct under the Revised Penal Code.
Ratio Decidendi
On Issue 1: The Supreme Court held that the appellant's plea of guilty was valid. Despite the appellant's claim that a missing page from the trial court's record prevented her from proving she did not plead guilty, the Court found other evidence on record that clearly established her plea. Specifically, the appellant's own pleadings and affidavit filed in the Court of Appeals admitted that she had pleaded guilty. In these pleadings, she sought not to reverse the conviction but to modify the penalty, indicating her acceptance of guilt. The Court also noted her statement that she was "deadset to plead guilty" and was induced by the de oficio lawyer's assurance of a minimal fine. The presumption that official duty has been regularly performed further supported the trial court's finding. Even if the plea was not formally entered in the record, the failure to do so does not affect the validity of the proceeding, as per Section 1, Rule 118 of the Rules of Court. On Issue 2: The Supreme Court found the penalty imposed by the trial court to be correct. The slanderous words quoted in the complaint were clearly of an insulting nature. Article 358 of the Revised Penal Code provides that the penalty for slander of a serious and insulting nature is arresto mayor in its maximum period to prision correccional in its minimum period. The trial court imposed a penalty of four (4) months and one (1) day of arresto mayor, which falls within the prescribed range. Therefore, the penalty was correctly imposed.
Main Doctrine
The Supreme Court affirmed the conviction for grave slander, holding that a plea of guilty, even if not explicitly recorded in the stenographic notes of the arraignment, is valid if supported by other evidence on record. The Court found that the appellant's subsequent actions and pleadings in the Court of Appeals clearly admitted to having entered a plea of guilty, thereby validating the trial court's decision. Furthermore, the Court reiterated that the penalty imposed for grave slander, when the words are of an insulting nature, is correctly determined under Article 358 of the Revised Penal Code.