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**Facts:**
Petitioner Dolores Magno and respondent Cerelito T. Alejandro were neighbors in Pucay Village, Marcos Highway, Baguio City. The conflict arose when Magno closed a passage used by the Alejandros to access the highway due to unsavory allegations made by Alejandro against the Magno family.
On March 2, 1991, Cerelito Alejandro observed Dolores Magno writing defamatory statements on her garage wall, accusing him of being a maniac and a dog thief. Feeling targeted, Cerelito reported the incident to the local police and filed an affidavit-complaint.
Subsequently, on March 9, 1991, Cerelito’s son, Rodelito, saw Magno repeating the defamatory writing on a different part of the same wall. Rodelito reported this to his father, who then filed another complaint with the Baguio City Police.
Further escalating the situation, Dolores Magno delivered a 3-page libelous letter addressed to Cerelito and Fe Alejandro via Evelyn Arcartado, Cerelito’s sister, on March 15, 1991. This letter contained further derogatory statements about Cerelito.
The Baguio City Prosecutor found probable cause for libel and filed four separate informations against Dolores Magno. During the proceedings, Dolores entered a plea of “Not Guilty.” After a joint trial, the Regional Trial Court (RTC) of Baguio convicted her of libel in Criminal Cases No. 8804-R and 8806-R but acquitted her in Criminal Cases Nos. 8803-R and 8805-R.
Dolores appealed to the Court of Appeals (CA), which affirmed the RTC’s decision on March 12, 1998, and denied her motion for reconsideration on May 20, 1998. Subsequently, Dolores filed a petition for review with the Supreme Court.
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**Issues:**
1. **Credibility of Witness (Rodelito Alejandro):** Was Rodelito’s testimony credible given his actions after witnessing the defamatory writing?
2. **Elements of Libel (Publication and Authorship):** Were the elements of authorship and publication satisfied for the acts committed on March 9 and March 15, 1991?
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**Court’s Decision:**
1. **Credibility of Witness:**
– The Supreme Court found no reason to doubt Rodelito’s testimony that he saw Dolores writing the defamatory statement. The Court noted that the assessment of witness credibility lies within the trial court’s domain, as it directly observed the demeanor and conduct of witnesses.
– The CA’s observation that Rodelito’s behavior of buying bread before reporting to his father did not undermine his credibility was upheld. The minor inconsistencies between Rodelito and Cerelito’s testimonies about the latter’s whereabouts did not affect the core truth of Rodelito’s observations.
2. **Elements of Libel:**
– **Publication:** The Court held that handing an unsealed defamatory letter to Evelyn Arcartado constituted publication because there was a reasonable probability of the letter being read by a third party. Evelyn read the letter only after securing Cerelito’s permission, which did not vitiate the publication element as Fe Alejandro, the wife, constituted a third person for publication purposes.
– **Authorship:** Dolores was identified as the author of the libelous letters handed to Evelyn. The letters were consistent with her previous libelous writings, corroborating her authorship.
Given these findings, the Supreme Court affirmed the CA’s decision, finding all elements of libel duly established.
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**Doctrine:**
– **Credibility of Witnesses:** The trial court’s evaluation of witness credibility is given substantial weight and respect due to its opportunity to observe witnesses’ demeanor and conduct.
– **Publication of Libel:** Publication is accomplished once the defamatory material is made known to someone other than the person defamed. Handing an unsealed letter which contains defamatory statements to a third party satisfies the element of publication.
– **Libel Elements:** To be liable for libel, the elements include an imputation of a discreditable act, publication of this imputation, identification of the person defamed, and existence of malice.
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**Class Notes:**
– **Libel Elements (Article 353, Revised Penal Code):**
1. Discreditable act or condition.
2. Publication.
3. Identity of the person defamed.
4. Malice.
– **Credibility of Witnesses (People vs. Escote):** In case of factual discrepancies, the trial court’s determination is of significant weight.
– **Doctrine of Publication (People vs. Silvela):** Sending an unsealed libelous letter to the offended party constitutes publication. Communication must be to a person other than the one defamed.
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**Historical Background:**
This case highlights the relevance of defamation laws in maintaining social harmony among neighbors. In the context of early 1990s Philippines, public reputation held immense importance, making the laws on libel crucial in addressing grievances related to public defamation. The technological constraints of the time also meant most defamatory communications were in physical form, hence the significance of the ruling on the publication of written material.
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