People v. Chu
REITERATIONFacts
The Antecedents: The accused, Hong Din Chu, was charged with grave oral defamation for allegedly uttering remarks against Mercedes Japco Ong, stating, "Your daughter is a prostitute and she is a prostitute because you too are a prostitute." The information was filed by an assistant city fiscal of Manila. Procedural History: The accused pleaded not guilty. The trial court dismissed the case upon motion of the accused, ruling that since the alleged imputation was of adultery (a private offense), the case should have been initiated by the offended party. The court cited Section 4 of Rule 110 of the Revised Rules of Court. The Petition: The prosecution appealed the dismissal, arguing that the imputed offense was prostitution, a public crime, and thus the information filed by the fiscal was sufficient to confer jurisdiction.
Issue(s)
Whether the imputation of being a "prostitute" to a married woman constitutes an imputation of a private crime (adultery) requiring the offended party's signature, or a public crime (prostitution) that can be prosecuted de oficio.
Ruling
The Supreme Court set aside the order of dismissal and remanded the case to the trial court for further proceedings.
Ratio Decidendi
On Issue 1: The Supreme Court held that the actual recital of facts in the Information determines the offense, and in this case, the specific imputation was prostitution. While the utterance might incidentally imply adultery because the offended party is married, the legal distinction between the two is significant. Prostitution, under Article 202 of the Revised Penal Code, is a crime against public morals involving habitual sexual intercourse for money or profit, whereas adultery, under Article 333, is a private offense against chastity. The Court emphasized that calling a married woman a prostitute is to charge her with moral degeneracy exceeding that of adultery, as it involves financial gain. Under Article 360 of the Revised Penal Code and Section 4, Rule 110 of the Revised Rules of Court, only specific crimes like adultery, concubinage, and seduction require a signed complaint from the offended party. Since prostitution is a public crime and not among those listed as requiring a private complaint, the Information signed by the Assistant City Fiscal was sufficient to confer jurisdiction. Consequently, the trial court erred in dismissing the case for lack of jurisdiction based on the absence of the complainant's signature.
Main Doctrine
A criminal action for defamation consisting in the imputation of a public crime, such as prostitution, can be filed by the fiscal without the signature of the offended party, thereby conferring jurisdiction upon the trial court.