Teodoro v. CA

G.R. No. 103174 (July 11, 1996)

Amado B. Teodoro was convicted of grave slander by deed against Carolina Tanco-Young.

Facts:

Petitioner Amado B. Teodoro served as the vice-president and corporate secretary of DBT-Marbay Construction, Inc., while the complainant, Carolina Tanco-Young, held the position of treasurer. The two were involved in a corporate dispute during a meeting on August 17, 1984, which escalated into a verbal altercation. The conflict arose over a controversial document that Teodoro insisted should be signed by the chairman, Agustin Tanco, while Tanco-Young questioned the legitimacy of the document, claiming no prior meeting had occurred to authorize it.

During the heated exchange, Tanco-Young allegedly called Teodoro a "falsifier," which provoked him to slap her. The incident occurred in the presence of other board members, including Tanco-Young's father, who attempted to intervene but was restrained by his daughter due to his heart condition. Initially, the Metropolitan Trial Court (MeTC) found Teodoro guilty of simple slander by deed and imposed a fine of P110.00. Teodoro appealed this decision, but later filed a motion to withdraw his appeal, which the Regional Trial Court (RTC) denied, leading to a trial de novo.

The RTC ultimately found Teodoro guilty of grave slander by deed, taking into account the serious nature of the offense, particularly because Tanco-Young was seven months pregnant at the time of the incident. The RTC sentenced him to three months of arresto mayor and required him to pay costs. Teodoro's subsequent appeal to the Court of Appeals was dismissed, prompting him to file a petition for review.

Legal Issues:

  1. Whether the RTC abused its discretion in denying Teodoro's motion to withdraw his appeal from the MeTC's decision.
  2. Whether Teodoro's payment of the fine imposed by the MeTC rendered that decision final and executory, thus placing him in double jeopardy when the RTC imposed a higher penalty.

Arguments:

  • Petitioner’s Arguments: Teodoro contended that he had an absolute right to withdraw his appeal and that his payment of the fine made the MeTC's decision final. He argued that the appeal did not vacate the MeTC's decision but merely stayed its execution, and thus, by paying the fine, he had satisfied the judgment.

  • Respondents’ Arguments: The prosecution argued that the RTC acted within its discretion in denying the withdrawal of the appeal, as allowing it would permit an error of the MeTC to go uncorrected. They maintained that the nature of the slander was grave, given the circumstances of the incident and the status of the complainant.

Court’s Decision and Legal Reasoning:

The Court of Appeals upheld the RTC's decision, stating that the withdrawal of an appeal is not a matter of right but lies within the court's discretion. The appellate court noted that Teodoro's motion to withdraw was filed after the prosecution had submitted its memorandum, indicating that he was attempting to evade a potentially adverse ruling.

The court emphasized that the MeTC's decision was not final due to the pending appeal, and thus, Teodoro was not subjected to double jeopardy when the RTC imposed a higher penalty. The RTC correctly classified the offense as grave slander by deed, considering the emotional and physical state of Tanco-Young at the time of the incident, which warranted a more severe penalty.

The court also referenced the legal principle that the seriousness of slander by deed is determined by the social standing of the offended party and the circumstances surrounding the act. Given that Tanco-Young was a pregnant woman and a respected businesswoman, the RTC's decision to impose a higher penalty was justified.

Significant Legal Principles Established:

  1. The withdrawal of an appeal in criminal cases is at the discretion of the court and is not an absolute right of the appellant.
  2. Payment of a fine does not render a decision final if an appeal is still pending, thus preventing double jeopardy.
  3. The classification of slander by deed as serious or grave depends on the context of the act, including the social standing of the offended party and the circumstances of the incident.