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NOEL VILLANUEVA v. PEOPLE

FACTS:

The case involves a verbal altercation between petitioner Noel Villanueva, a member of the Municipal Council, and private complainant Yolanda Castro, the Municipal Vice Mayor of Concepcion, Tarlac. Two separate criminal complaints were filed against the petitioner for Grave Oral Defamation and Slander by Deed. The Grave Oral Defamation charge stemmed from the petitioner's alleged utterance of insulting words towards the complainant in the municipal building on two separate occasions. The Slander by Deed charge was based on the petitioner's act of extending his middle finger towards the complainant's face during the altercation.

The defense presented witnesses who claimed that the accused had requested the complainant's approval for his application for monetized leave, but the complainant had refused to sign it. This led to a verbal squabble between the accused and the complainant, during which the complainant allegedly threw a bottle of coke at the accused.

After trial, the Municipal Circuit Trial Court (MCTC) found the accused guilty of Grave Oral Defamation and Serious Slander by Deed. The MCTC held that the accused's statements and actions were an affront to the complainant and sentenced him to imprisonment and ordered him to pay damages. The decision was affirmed by the Regional Trial Court (RTC), with some modifications to the penalties and damages. The Court of Appeals affirmed the ruling of the trial court, but deleted the award of exemplary damages. The accused filed a petition for review, arguing for his absolution.

The petitioner lodged a petition for review with the Court of Appeals, raising multiple issues related to his conviction for grave oral defamation and serious slander by deed. The petitioner claimed that the Court of Appeals erred in ruling on only one issue and not addressing the other five issues, thereby violating his right to be heard and due process. The petitioner further argued that the Court of Appeals failed to reverse the decision of the Regional Trial Court despite acknowledging that it was the complainant who provoked the incident. The petitioner also contended that the lower courts gave weight only to the testimonies of the prosecution witnesses and disregarded the testimonies of the accused-petitioner and his witnesses. Finally, the petitioner argued that his guilt had not been proven beyond reasonable doubt and should result in his acquittal.

The Court referred to Article 358 of the Revised Penal Code, which provides for the punishment of oral defamation or slander. The Court explained that slander is libel committed through spoken words and that oral defamation or slander refers to the speaking of base and defamatory words that prejudice another in their reputation, office, trade, business, or means of livelihood. The Court further explained that the gravity of the oral defamation depends on the expressions used, personal relations of the accused and the offended party, and the circumstances surrounding the case. The Court emphasized that the social standing and position of the offended party are also considered in determining the gravity of the slander.

ISSUES:

  1. Whether the offense committed by the petitioner is grave or light oral defamation.

  2. Whether the award of exemplary damages and moral damages is warranted.

  3. Whether the petitioner is guilty of slight oral defamation.

  4. Whether the petitioner's act of poking a dirty finger at the complainant constitutes grave slander by deed.

  5. Whether the petitioner is guilty of serious slander by deed.

  6. Whether the penalty of a fine is appropriate.

  7. Whether the petitioner and the complainant should be censured for their inappropriate behavior as high-ranking public officials.

  8. Whether the Court of Appeals erred in increasing the award of moral damages.

  9. Whether the complainant's claim for damages and attorney's fees should be granted.

RULING:

  1. The offense committed by the petitioner is light oral defamation. The gravity of the oral defamation depends on the expressions used, the personal relations of the accused and the offended party, and the circumstances surrounding the case. In this case, the Court of Appeals found that the scathing words were uttered by the petitioner in the heat of anger triggered by the fact that the complainant refused, without valid justification, to approve the monetization of accrued leave credits of the petitioner. While the petitioner, as a public official, is expected to be an exemplar to society, the Court cannot ignore the fact that the scathing words were spoken in the heat of anger with some provocation on the part of the offended party. Therefore, the offense committed is only light oral defamation.

  2. The award of exemplary damages and moral damages is not warranted. Exemplary damages are designed to suppress wanton acts of the offender and cannot be invoked as a matter of right. In this case, the Court of Appeals should have struck out the award of exemplary damages. Additionally, the trial court erred in awarding moral damages without proof of suffering. Thus, the award of exemplary damages and moral damages should be removed.

  3. The petitioner is guilty only of slight oral defamation. Although the abusive remarks may ordinarily be considered as serious defamation, under the circumstances of the case, where there was provocation on the complainant's part and the utterances were made in the heat of anger, the petitioner is liable only for slight oral defamation.

  4. The petitioner is guilty only of slight slander by deed. The complainant's unjust refusal to sign the petitioner's application for monetization and her act of throwing a coke bottle at him constituted a perceived provocation that triggered the act of poking a dirty finger.

  5. The petitioner is found guilty of serious slander by deed. The act of banging a chair in front of the complainant and choking her constitutes grave slander by deed.

  6. The penalty of a fine is appropriate. Although imprisonment is also a possible penalty for serious slander by deed, the court opted to impose a fine instead.

  7. The petitioner and the complainant deserve to be censured for their behavior and were directed to conduct themselves in a more composed manner.

  8. The Court of Appeals erred in increasing the award of moral damages.

  9. The complainant's claim for damages and attorney's fees must be denied.

PRINCIPLES:

  • Slander is libel committed by oral means.

  • Grave slander is of a serious and insulting nature.

  • The gravity of oral defamation depends on the expressions used, the personal relations of the accused and the offended party, and the circumstances surrounding the case.

  • Defamatory words will fall under grave or light oral defamation depending on their sense, grammatical significance, accepted ordinary meaning, and the special circumstances of the case.

  • Exemplary damages cannot be recovered as a matter of right and are designed to suppress wanton acts of the offender.

  • Moral damages cannot be awarded without proof of suffering.

  • Uttering defamatory words in the heat of anger, with some provocation on the part of the offended party, constitutes only a light felony.

  • Slander by deed is a crime against honor committed by performing any act that casts dishonor, discredit, or contempt upon another person. The seriousness of the act depends on the social standing of the offended party, the circumstances, and the occasion.

  • Slander by deed is libel committed by actions rather than words, such as slapping someone or spitting on their face in public view, casting dishonor, discredit, and contempt upon the person.

  • Serious slander by deed is defined and penalized under Article 359 of the Revised Penal Code.

  • The penalty for serious slander by deed may be imprisonment or a fine.

  • A perceived provocation can be a mitigating factor in imposing a penalty for serious slander by deed.

  • The act of pointing a dirty finger at someone can constitute simple slander by deed, which is of a lesser magnitude than serious slander by deed.

  • The penalty for simple slander by deed can be a fine or imprisonment from one day to 30 days.

  • Conduct unbecoming of a person in a position of respect can be a relevant factor in determining the appropriate penalty for slander by deed.

  • Holding an esteemed position does not give license to act capriciously with impunity.

  • To earn respect, one must act respectably.

  • Occasional gestures and words of disapproval or dislike can be expected in the context of warring political camps.

  • Each party must bear their own loss, especially when they are found to have engaged in inappropriate behavior.