Malit v. People
REITERATIONFacts
The Antecedents: Petitioner, Atty. Alfredo P. Malit, was the counsel for Miss Ruth Fernandez in an administrative case against Dr. Macaspac. During the cross-examination of Dr. Macaspac, petitioner asked if she knew the person who "made" a certain exhibit. Dr. Macaspac evaded the question, claiming she did not understand the word "made." Petitioner clarified it meant "prepared," but Dr. Macaspac still evaded. Petitioner then remarked, "I doubt how did you become a Doctor." Consequently, Dr. Macaspac filed a complaint for slander against Atty. Malit. Procedural History: An information for unjust vexation was filed against petitioner. Petitioner filed a motion to quash, arguing that the facts charged did not constitute an offense and that the utterances were privileged communication made in the course of judicial proceedings. The respondent Judge denied the motion to quash and the subsequent motion for reconsideration. The Petition: Petitioner filed a petition for certiorari and prohibition to review the orders of the respondent Judge denying his motion to quash and motion for reconsideration.
Issue(s)
Whether the respondent Judge committed a grave abuse of discretion in denying the motion to quash the information for unjust vexation. Whether the statement made by the petitioner during the cross-examination of Dr. Macaspac constitutes a privileged communication, thereby exempting him from liability.
Ruling
The Court granted the petition, reversed and set aside the orders of the respondent Judge, and ordered the respondent to desist from proceeding with the trial of Criminal Case No. 126521. The Court held that the statement made by the petitioner was an absolutely privileged communication.
Ratio Decidendi
On the issue of whether the respondent Judge committed a grave abuse of discretion: The Court held that while certiorari generally does not lie to question an interlocutory order, it may be exercised when there is a grave abuse of discretion or when the lower court acted capriciously and whimsically. In this case, the denial of the motion to quash, which raised the issue of privileged communication, was deemed an error equivalent to lack of jurisdiction, thus warranting certiorari. The Court found that the respondent Judge's refusal to consider the defense of privileged communication at the motion to quash stage constituted a grave abuse of discretion. On the issue of whether the statement constitutes a privileged communication: The Court sustained the petitioner's contention that the statement "I doubt how did you become a doctor" was an absolutely privileged communication. The Court reiterated the well-settled rule that parties, counsel, and witnesses are exempted from liability for defamatory words uttered or published in the course of judicial proceedings, provided the statements are pertinent or relevant to the case. The Court noted that the statement was made in response to the witness's evasion of a question during cross-examination, indicating a degree of relevancy to the inquiry. The Court emphasized that the degree of relevancy required is liberal, and the matter must be palpably wanting in relation to the subject matter to lose its privilege. The privilege is granted in aid of the administration of justice, allowing individuals to speak freely without fear of prosecution.
Main Doctrine
Utterances made in the course of judicial or administrative proceedings are absolutely privileged if they are pertinent or relevant to the case, and counsel, parties, or witnesses therein are exempt from liability for such statements.