Facts:

Petitioner Fernando Sazon and private complainant Abdon Reyes were both residents of PML Homes in Parang, Marikina, Metro Manila, and members of the PML-Parang Bagong Lipunan Community Association, Inc. (PML-BLCA), which published a monthly newsletter called the PML-Homemaker. In December 1983, Sazon was elected as a director and subsequently as president of the homeowners' association, while Reyes lost in the election. Following his defeat, Reyes protested the election results, claiming that Sazon lacked authority to call for the election, that there was no quorum, and that proper notice was not given to homeowners.

In response to Reyes's protest, the Estate Management Office of the Home Financing Corporation (EMO-HFC) ordered a referendum to be conducted. Reyes then circulated a letter urging homeowners not to recognize Sazon and the newly elected board. Subsequently, a leaflet titled "Supalpal si Sazon" was distributed among homeowners, and derogatory phrases about Sazon appeared on the walls of the subdivision.

In retaliation, Sazon published an article in the PML-Homemaker on February 10, 1984, which contained derogatory remarks about Reyes, including terms like "mandurugas" (swindler) and accusations of deceit. Reyes filed a complaint for libel against Sazon, leading to an Information being filed in court on May 25, 1984. The trial court found Sazon guilty of libel and sentenced him to imprisonment and a fine.

Sazon appealed the decision to the Court of Appeals, which affirmed the trial court's ruling. He then filed a petition for review, arguing that the article was a privileged communication, that the words used were not defamatory, that no damage to Reyes's reputation occurred, and that any penalty should be limited to a fine.

Legal Issues:

  1. Whether the article published by Sazon was libelous.
  2. Whether the article constituted a privileged communication.
  3. Whether the words used were defamatory and malicious.
  4. Whether the penalty imposed was appropriate.

Arguments:

  • Petitioner (Sazon):

    • Argued that the article was a privileged communication as it was written in the performance of a social duty.
    • Claimed that the words used were non-actionable epithets and did not defame Reyes.
    • Contended that the prosecution failed to prove malice and that the article did not cause damage to Reyes's reputation.
    • Suggested that if found guilty, the penalty should be limited to a fine without imprisonment.

  • Respondent (Reyes):

    • Asserted that the article was clearly defamatory, containing malicious imputations against his character.
    • Argued that the words used were calculated to induce public contempt and ridicule.
    • Maintained that the presumption of malice applied, and Sazon failed to demonstrate any good intention or justifiable motive for his statements.

Court's Decision and Legal Reasoning:

The court affirmed the decision of the Court of Appeals, ruling that the article published by Sazon was indeed libelous. It reiterated the definition of libel under Article 353 of the Revised Penal Code, which requires that the imputation must be defamatory, malicious, public, and identifiable. The court found that the words used by Sazon were clearly defamatory, as they exposed Reyes to public contempt and ridicule.

The court rejected Sazon's claim of privileged communication, stating that the article did not address any official duty or function of Reyes as a public relations consultant. It emphasized that the article attacked Reyes's private character rather than his public role, thus failing to qualify for the exceptions under Article 354 of the Revised Penal Code.

Furthermore, the court noted that malice is presumed in cases of defamatory imputation, and Sazon did not provide sufficient evidence to rebut this presumption. The court concluded that the derogatory language used indicated a clear intent to malign Reyes, thus establishing malice in fact.

The penalty was modified to a fine of Three Thousand Pesos (₱3,000.00) with subsidiary imprisonment in case of insolvency, rather than imprisonment and a fine.

Significant Legal Principles Established:

  1. The definition of libel under the Revised Penal Code and the requisites for an imputation to be considered libelous.
  2. The presumption of malice in defamatory statements and the burden on the defendant to prove good intention.
  3. The distinction between privileged communication related to public duties and private character attacks, clarifying the scope of protection under Article 354.