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ELISEO SORIANO v. PEOPLE

FACTS:

The petitioner in this case is Eliseo Soriano, who is appealing the decision of the Court of Appeals (CA) that upheld the conviction made by the Regional Trial Court (RTC). The convictions were for two counts of libel, and the charges were a result of statements made by Soriano on his radio program. These statements were considered false, injurious, and defamatory towards the Jesus Miracle Crusade, International Ministry (JMCIM) and its leader, Wilde Almeda. The RTC found Soriano guilty and imposed a fine of P6,000 for each case. The decision of the RTC was then affirmed by the CA.

In his appeal, Soriano raised several arguments. He contended that the prosecution failed to prove that his statements caused discredit or dishonor to the private complainant. Soriano also claimed that there was no malice or ill will present behind his statements and criticized the CA for its alleged failure to carefully evaluate the evidence presented.

ISSUES:

  1. Whether the statements made by the petitioner are defamatory.

  2. Whether malice is present in the statements made by the petitioner.

  3. Whether the statements made by the petitioner are considered qualifiedly privileged communications.

  4. Whether the statements made by the petitioner can be considered fair commentaries on matters of public interest.

  5. Whether the statements made by the petitioner were published.

  6. Whether the identification of the offended party is sufficient to hold the petitioner guilty of libel.

  7. Whether the petitioner's claim of religious freedom protects his statements.

  8. Whether or not Garcia's right to due process was violated by the implementation of Special Order No. 2607.

RULING:

  1. The statements made by the petitioner are defamatory as they disparage the private complainant and are calculated to induce the hearers to suppose and understand that he is guilty of certain offenses or impeach his honesty, virtue, or reputation.

  2. There is malice present in the statements made by the petitioner as there is no evidence to establish any good intention or justifiable motive for making the defamatory imputations.

  3. The statements made by the petitioner are not considered qualifiedly privileged communications as they do not fall under any of the categories enumerated in Article 354 of the Revised Penal Code.

  4. The statements made by the petitioner cannot be considered fair commentaries on matters of public interest. The words used by the petitioner did not aim to debunk purported falsities in the preachings of the offended party but rather to degrade and insult their pastor or founder. The Court of Appeals' finding of actual malice was also affirmed.

  5. There is publication in this case as the video footage of petitioner's statements was broadcasted through his radio program.

  6. The petitioner's guilt of libel stems from his statements against the offended party's pastor and not against the offended party itself or any of its pastors. The statements did not refer to any specific pastor or member of the offended party.

  7. The petitioner's claim of religious freedom does not protect his statements. The Court stated that plain and simple insults directed at another person cannot be elevated to the status of religious speech.

  8. The Supreme Court ruled that Garcia's right to due process was violated by the implementation of Special Order No. 2607.

PRINCIPLES:

  • Libel under Article 353 of the Revised Penal Code requires defamatory imputation, malice, publicity, and the victim's identifiability.

  • In determining whether a statement is defamatory, the words used are to be construed in their entirety and taken in their plain, natural, and ordinary meaning as they would naturally be understood by persons reading them.

  • Malice is presumed if no good intention and justifiable motive for making a defamatory imputation is shown.

  • Qualifiedly privileged communications are exceptions to the general rule requiring proof of actual malice in order for a defamatory imputation to be held actionable. These include private communications made in the performance of legal, moral, or social duty, as well as fair and true reports of judicial, legislative, or other official proceedings.

  • Fair commentaries on matters of public interest may still be considered actionable if actual malice is proven.

  • Publication in libel means making the defamatory matter known to someone other than the person against whom it was written.

  • Declarations made about a large class of people cannot be interpreted to refer to an identified or identifiable individual.

  • Individuals in a larger community do not have a common reputation that can give rise to an action for group libel.

  • Plain and simple insults directed at another person cannot be considered religious speech.

  • Right to Due Process: The right to due process requires that an individual be given notice and an opportunity to be heard before any deprivation of life, liberty, or property takes place.