Libel, A353 Revised Penal Code

Libel is the malicious imputation of a crime, vice, or defect.

1. Concept

Libel – refers to “a public and malicious imputation of a crime, or of a vice or defect, real or imaginary, or any act, omission, condition, status or circumstance tending to cause dishonor, discredit or contempt of a natural or juridical person, or to blacken the memory of one who is dead.” (Nova Communications, Inc. v. Canoy, G.R. No. 193276, June 26, 2019, Per Carandang, J.)

Libel – is an offense of injuring a person’s character or reputation through false and malicious statements. (Ibid.)

a. Legal basis

Article 353. Definition of libel. – A libel is public and malicious imputation of a crime, or of a vice or defect, real or imaginary, or any act, omission, condition, status, or circumstance tending to cause the dishonor, discredit, or contempt of a natural or juridical person, or to blacken the memory of one who is dead.

Art. 355. Libel by means of writings or similar means. – A libel committed by means of writing, printing, lithography, engraving, radio, phonograph, painting, theatrical exhibition, cinematographic exhibition, or any similar means, shall be punished by prisión correccional in its minimum and medium periods or a fine ranging from Forty thousand pesos (P40,000) to One million two hundred thousand pesos (P1,200,000), or both, in addition to the civil action which may be brought by the offended party.

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2. Mode of commission

The following is the mode of committing the offense:

• Libel by means of writings or similar means

a. Mode 1: Malicious imputation

Elements of the offense:

1) Imputation must be defamatory;

2) Imputation must be malicious;

3) Imputation must be given publicity; and

4) The victim must be identifiable. (Manila Bulletin Publishing Corporation v. Domingo, G.R. No. 170341, July 5, 2017, Per Martires, J.)

1) Element 1: Defamatory

In determining whether a statement is defamatory, the words used are to be construed in their entirety and should be taken in their plain, natural, and ordinary meaning as they would naturally be understood by persons reading them, unless it appears that they were used and understood in another sense. (Manila Bulletin Publishing Corporation v. Domingo, G.R. No. 170341, July 5, 2017, Per Martires, J.)

An allegation is considered defamatory if it ascribes to a person the commission of a crime, the possession of a vice or defect, real or imaginary, or any act, omission, condition, status or circumstance which tends to dishonor or discredit or put him in contempt, or which tends to blacken the memory of one who is dead. In determining whether a statement is defamatory, the words used are to be construed in their entirety and should be taken in their plain, natural, and ordinary meaning as they would naturally be understood by persons reading them, unless it appears that they were used and understood in another sense. Moreover, a charge is sufficient if the words are calculated to induce the hearers to suppose and understand that the person or persons against whom they were uttered were guilty of certain offenses or are sufficient to impeach the honesty, virtue or reputation or to hold the person or persons up to public ridicule. (Ibid.)

a) Veritable mental asylum patient, madman, lunatic

Beyond question, the words imputed to Atty. Canoy as a veritable mental asylum patient, a madman and a lunatic, in its plain and ordinary meaning, are conditions or circumstances tending to dishonor or discredit him. As such, these are defamatory or libelous per se. (Nova Communications, Inc. v. Canoy, supra.)

2) Element 2: Malice

Malice connotes ill will or spite and speaks not in response to duty but merely to injure the reputation of the person defamed, and implies an intention to do ulterior and unjustifiable harm. Malice is bad faith or bad motive. It is the essence of the crime of libel. (Manila Bulletin Publishing Corporation v. Domingo, supra.)

a) Presumption of malice

Article 354. Requirement for publicity. – Every defamatory imputation is presumed to be malicious, even if it be true, if no good intention and justifiable motive for making it is shown, except in the following cases:

1. A private communication made by any person to another in the performance of any legal, moral or social duty; and

2. A fair and true report, made in good faith, without any comments or remarks, of any judicial, legislative or other official proceedings which are not of confidential nature, or of any statement, report or speech delivered in said proceedings, or of any other act performed by public officers in the exercise of their functions.

General rule: Under Article 354 of the RPC, it is provided that every defamatory imputation is presumed to be with malice, even if the same is true, unless it is shown that it was made with good intention and justifiable motive… (Nova Communications, Inc. v. Canoy, supra.)

Exceptions: … except in the following circumstances:

1) A private communication made by any person to another in the performance of any legal, moral or social duty; and

2) A fair and true report, made in good faith, without any comments or remarks, of any judicial, legislative or other official proceedings which are not of confidential nature, or of any statement, report or speech delivered in said proceedings, or of any other act performed by public officers in the exercise of their functions;

3) Matters of public interest. (Nova Communications, Inc. v. Canoy, supra.)

a) Exception 1: Privileged communication

A privileged communication may be classified as either absolutely privileged or qualifiedly privileged. The absolutely privileged communication are not actionable even if the same was made with malice, such as the statements made by members of Congress in the discharge of their duties for any speech or debate during their session or in any committee thereof,29 official communications made by public officers in the performance of their duties, allegations or statements made by the parties or their counsel in their pleadings or during the hearing, as well as the answers of the witnesses to questions propounded to them. (Nova Communications, Inc. v. Canoy, supra.)

The qualifiedly privileged communications are those which contain defamatory imputations but which are not actionable unless found to have been made without good intention or justifiable motive, and to which “private communications” and “fair and true report without any comments or remarks” belong. (Ibid.)

Since the qualifiedly privileged communications are the exceptions to the general rule, these require proof of actual malice in order that a defamatory imputation may be held actionable. But when malice in fact is proven, assertions and proofs that the libelous articles are qualifiedly privileged communications are futile, since being qualifiedly privileged communications merely prevents the presumption of malice from attaching to a defamatory imputation. (Manila Bulletin Publishing Corporation v. Domingo, supra.)

b) Exception 2: Fair and true report

Fair and true report is an exemption provided that there is good faith.

Manila Bulletin Publishing Corporation v. Domingo, G.R. No. 170341, July 5, 2017, Per Martires, J.:

• a) The 20 December 1990 article

• The Court cannot sustain the findings of the R TC and the CA that this article was libelous. Viewed in its entirety, the article withholds the finding that it impeaches the virtue, credit, and reputation of Domingo. The article was but a fair and true report by Batuigas based on the documents received by him and thus exempts him from criminal liability under Art. 354(2) of the RPC…

• Noteworthy, the first sentence on the 20 December 1990 article76 warns the successor of JoeCon of the brewing problem that he will inherit at the DTI Region VIII office. The immediately following sentences relate that in a letter to Batuigas, the Waray employees of Region VIII made known their disgust on how DTI Region VIII was being run and handled. According to the Waray employees, the complaints as to the “mismanagement, low morale, improper decorum, gross inefficiency, nepotism” in the office had already been made known to the DTI Makati office, the CSC and the Ombudsman, only that “[w]ala raw nangyari sa reklamo nila.” The letter further provided that the Waray employees turned instead to Batuigas knowing that his column produces results, i.e., “Kaya kami lumapit sa inyo Gg. Batuigas dahil nagbibigay ng resulta ang kolum ninyo.”

• As culled by Batuigas from the letter, the succeeding sentences in the article merely enumerated the specifics of the complaints against several employees and officials of the DTI Region VIII, among whom was Domingo, that had been brought to the attention of DTI, CSC, and the Office of the Ombudsman, from which the Waray employees claimed nothing happened.

• The article cannot be considered as defamatory because Batuigas had not ascribed to Domingo the commission of a crime, the possession of a vice or defect, or any act or omission condition, status or circumstance which tends to dishonor or discredit the latter. The article was merely a factual report which, to stress, were based on the letter of the Waray employees reiterating their earlier complaints against Domingo and other co-workers at the DTI Region VIII. “Where the words imputed [are] not defamatory in character, a libel charge will not prosper. Malice is necessarily rendered immaterial.”

• Parenthetically, it was through the evidence, consisting of public documents, presented by Domingo during the hearing of these cases that it was confirmed that there were indeed complaints filed against him and the other DTI officials before the CSC and the Office of the Ombudsman relative to “mismanagement, low morale, improper decorum, gross inefficiency, nepotism.” Although, based on these pieces of evidence, the complaints against Domingo had already been dismissed by the CSC and the Office of the Ombudsman, the fact remains that there were actual complaints against him, among others, the particulars of which were those plainly enumerated in the article. True, it was embarrassing that these complaints were disclosed to the public; but equally factual was that these were matters clearly supported by public records.

• The CA, however. moored on these statements its resolution that the 20 December 1990 article was libelous, viz:

These national employees should be commended for bringing into the open this garbage that has piled [up] in their own backyard.

To JoeCon’s successor, the chopping board is ready.

All you need is a Muslim kris!

Palakulin mo, Pare ko!

• The CA held that because of the comments or remarks made by Batuigas, the article would not fall under the exceptions of Art. 354 of the RPC. The CA ruled that the test of the defamatory character was whether or not the words were calculated to induce suspicion, a manner more effective to destroy reputation than false charges directly made, and that the meaning of the writer was even immaterial.

• A plain reading of the statements found by the CA as libelous cannot support a ruling that these were disparaging to Domingo or calculated to induce suspicion upon his person. In the statement “[t]hese national employees should be commended for bringing into the open this garbage that has piled [up] in their own backyard,” Batuigas was merely commending the DTI employees who brought into the open their complaints which had already been made known to the CSC and the Office of the Ombudsman. It was a fair remark directed to the DTI employees and made no reference to Domingo or imputed to him any defamatory allegation.

• On the last three sentences, Batuigas explained that this was only a figure of speech. The statements were obviously addressed to the new DTI Secretary suggesting that he use a chopping board and a Muslim kris to solve the mounting problems at the DTI office. A plain, natural, and ordinary appreciation of the statements fails to validate the finding that these ascribed something deprecating against Domingo. The sentences merely meant that heads should roll at the DTI office but palpably absent were the identities of those persons. Corollary thereto, the article could not have qualified as libelous because it is the well-entrenched rule that statements are not libelous unless they refer to an ascertained or ascertainable person.

c) Exception 3: Matters of public interest

To be sure, the enumeration under Art. 354 is not an exclusive list of qualifiedly privileged communications since fair commentaries on matters of public interest are likewise privileged. The rule on privileged communications had its genesis not in the nation’s penal code but in the Bill of Rights of the Constitution guaranteeing freedom of speech and of the press. As early as 1918, in United States v. Cañete, this Court ruled that publications which are privileged for reasons of public policy are protected by the constitutional guaranty of freedom of speech. This constitutional right cannot be abolished by the mere failure of the legislature to give it express recognition in the statute punishing libels. (Borjal v. CA, G.R. No. 126466 January 14, 1999, Per Bellosillo, J.)

To reiterate, fair commentaries on matters of public interest are privileged and constitute a valid defense in an action for libel or slander. The doctrine of fair comment means that while in general every discreditable imputation publicly made is deemed false, because every man is presumed innocent until his guilt is judicially proved, and every false imputation is deemed malicious, nevertheless, when the discreditable imputation is directed against a public person in his public capacity, it is not necessarily actionable. In order that such discreditable imputation to a public official may be actionable, it must either be a false allegation of fact or a comment based on a false supposition. If the comment is an expression of opinion, based on established facts, then it is immaterial that the opinion happens to be mistaken, as long as it might reasonably be inferred from the facts. (Ibid)

The conduct, moral fitness, and ability of a public official to discharge his duties are undoubtedly matters of public interest for he is, after all, legally required to be at all times accountable to the people and is expected to discharge his duties with utmost responsibility, integrity, competence, and loyalty; and to act with patriotism and justice, lead modest lives, and uphold public interest over personal interest. (Manila Bulletin Publishing Corporation v. Domingo, supra.)

The United States v. Bustos, G.R. No. L-12592, March 8, 1918, Per Malcolm, J.:

• The interest of society and the maintenance of good government demand a full discussion of public affairs. Complete liberty to comment on the conduct of public men is a scalpel in the case of free speech. The sharp incision of its probe relieves the abscesses of officialdom. Men in public life may suffer under a hostile and an unjust accusation; the wound can be assuaged with the balm of a clear conscience. A public officer must not be too thin-skinned with reference to comment upon his official acts. Only thus can the intelligence and dignity of the individual be exalted. Of course, criticism does not authorize defamation. Nevertheless, as the individual is less than the State, so must expected criticism be born[e] for the common good. Rising superior to any official or set of officials, to the Chief Executive, to the Legislature, to the Judiciary-to any or all the agencies of Government-public opinion should be the constant source of liberty and democracy.

Manila Bulletin Publishing Corporation v. Domingo, G.R. No. 170341, July 5, 2017, Per Martires, J.:

• True, the complaints had already been dismissed by the government offices tasked to resolve these, and of which fact Batuigas had not been informed when he wrote the 20 December 1990 and 4 January 1991 articles; but it must be pointed out that even assuming that the contents of the articles were false, mere error, inaccuracy or even falsity alone does not prove actual malice.

• In order to constitute malice, ill will must be personal. Domingo testified that he did not personally know Batuigas or had met him before. When Domingo was asked as to the motive of Batuigas in writing the articles putting his (Domingo’s) name in a bad light, he explained that the employees he had dismissed during the reorganization could have caused the writing of the articles. Domingo further stated that, likewise, he suspected a group of loggers in the region he had been very vocal against for the past ten years.

• When cross-examined, Domingo reiterated his earlier testimony that he had no dealings with Batuigas, or had not personally met or spoken with him. When further probed, Domingo said that Batuigas could have been (used as) a tool by people who were interested in going after his neck because he had stepped on them in the discharge of his duties. When asked to confirm whether Batuigas had a personal grudge against him, Domingo said: “I do not think he harbors ill will against me.”

• The absence of personal ill will of Batuigas against Domingo disavows actual malice and buttresses the finding that Batuigas was prompted by a legitimate or plausible motive in writing the articles. It was pointed out that Batuigas characterized his writing akin to an expose where he revealed anomalies and shenanigans in the government in the hope that corruption might be minimized. Moreover, Batuigas had no reason to doubt that R. de Paz, the sender of the letter containing the complaints against Domingo, did not exist considering that the letter was signed by one claiming to be R. de Paz.

• Art. 354 of the RPC provides that good intention and justifiable motives are defenses for a defamatory imputation even if it be true. Batuigas was able to firmly establish his defenses of good faith and good motive when he testified that, after he received several letters of complaint against Domingo, he came up with the said columns because he found the complaints on the shenanigans by Domingo at the DTI to be of public interest. Batuigas’ defense was reinforced by the records bereft of any showing that the prosecution offered evidence to support a conclusion that Batuigas had written the articles with the sole purpose of injuring the reputation of Domingo.

• In his 16 January 1991 article titled “The other side of DTI 8 issue,” Batuigas acknowledged that he might have been used by the detractors of Domingo due to their failure to establish a prima facie case against the Regional Director. In the same article, Batuigas quoted portions of the separate letters sent to him by Zaldy Lim and Lions International Deputy Vice-Governor Prudencio J. Gesta, who both denied the allegations against Domingo. Additionally, Batuigas had written the 16 January 1991 article before Domingo could file criminal and civil cases against him and the Manila Bulletin. These truths evidently refuted malice or ill will by Batuigas against Domingo.

• The failure of Batuigas to counter-check the status of the complaints against Domingo was indeed unfortunate, but such failure cannot be considered as enough reason to hold him liable. While substantiation of the facts supplied is an important reporting standard, still, a reporter may rely on information given by a lone source although it reflects only one side of the story provided the reporter does not entertain a high degree of awareness of its probable falsity. Domingo, who had the burden of proving actual malice, was not able to present proof that Batuigas had entertained awareness as to the probable falsehood of the complaints against him (Domingo). Indeed, on the basis of the documents in Batuigas’ possession, which were actually complaints against Domingo, Batuigas wrote his comments on Domingo’s “lousy performance” and “mismanagement.” …

• For sure, the words “lousy performance” and “mismanagement” had caused hurt or embarrassment to Domingo and even to his family and friends, but it must be emphasized that hurt or embarrassment even if real, is not automatically equivalent to defamation; words which are merely insulting are not actionable as libel or slander per se, and mere words of general abuse however opprobrious, ill-natured, or vexatious, whether written or spoken, do not constitute bases for an action for defamation in the absence of an allegation for special damages. If a writer in the course of temperate and legitimate criticism falls into error as to some detail, or draws an incorrect inference from the facts before him, and thus goes beyond the limits of strict truth, such inaccuracies will not cause judgment to go against him, if the jury are satisfied, after reading the whole publication, that it was written honestly, fairly, and with regard to what truth and justice require. Domingo must remember that one of the costs associated with participation in public affairs is an attendant loss of privacy.

• It may be well for us to keep in mind that the rule on privileged communications in defamation cases developed because “public policy, the welfare of society and the orderly administration of justice” have demanded protection for public opinion. “While the doctrine of privileged communication can be abused, and its abuse can lead to great hardships, to allow libel suits to prosper strictly on this account will give rise to even greater hardships. The doctrine itself rests on public policy which looks to the free and unfettered administration of justice. It is as a rule applied liberally.”

Nova Communications, Inc. v. Canoy, G.R. No. 193276, June 26, 2019, Per Carandang, J.

• In 1990, Col. [A.] Noble (Col. Noble), a Philippine Military Academy graduate and former Presidential Security Guard of the late President Corazon Aquino led a rebellion in Mindanao. Atty. Canoy was suspected to be one of Col. Noble’s supporters because of his involvement with the Independent Mindanao Movement which espoused the view of an independent Mindanao.

• On October 1990, a series of articles were written by Locsin, Jr. and Molina that were printed in the Philippine Free Press issue of October 13, 1990 published by LR Publications and Philippine Daily Globe issues of October 7, 1990, October 9, 1990 and October 11, 1990 published by Nova Communications.

[Notice: While this is a civil case for libel, it is included here for purposes of discussions relating to the principles on libel.]

• [Supreme Court]

• Indubitably, the defamatory words imputed to Atty. Canoy cannot be considered as “private communication” made by one person to another in the performance of any legal, moral or social duty. Neither is it a fair and true report without any comments or remarks.

• In this case, the defamatory words imputed to Atty. Canoy cannot be said to be fair commentaries on matters of public interest. To be sure, informing the public as to the rebellion of Col. Noble is a matter of public interest. However, calling Atty. Canoy as a veritable mental asylum patient, a madman and a lunatic is not in furtherance of the public interest. The defamatory words are irrelevant to the alleged participation of Atty. Canoy in the rebellion staged by Col. Noble.

• Locsin, Jr., alleged that he only made those utterances to show his strong opposition to the political beliefs of Atty. Canoy to remove Mindanao from the government based on the alleged intelligence reports identifying Atty. Canoy as part of the civilian component of Col. Noble’s rebellion.

• As found by both the RTC and the CA, the said intelligence reports are neither proved nor established by the petitioners. As such, the intelligence reports are unconfirmed. As such, the said defamatory remarks cannot be considered as an expression of opinion based on established facts nor can it reasonably inferred from established facts. Nevertheless, even if the supposed intelligence reports were verified and Atty. Canoy supported Col. Noble’s rebellion, the defamatory remarks are not related to the alleged participation of Atty. Canoy in the rebellion, but directed as to his mental condition. Further no evidence was presented to support that Atty. Canoy was indeed a mental asylum patient or a lunatic. As such, the petitioners made those defamatory remarks without any regard as to the truth or falsity of the same.

• As alleged by the petitioners, the subject articles were centered in the rebellion of Col. Noble, and Atty. Canoy was merely mentioned incidentally. This allegation does not help the position of the petitioners. Rather, it even weakens their cause, as it further established the existence of malice in causing dishonor, discredit or put in contempt the person of Atty. Canoy.

• Examination of the defamatory remarks reveals that the same pertain to Atty. Canoy’s mental capacity and not to his alleged participation with Col. Noble’s rebellion, and neither does it pertain to Atty. Canoy’s duties and responsibilities as a radio broadcaster. While Atty. Canoy is a public figure, the subject articles comment on the mental condition of the latter, thus, the defamatory utterances are directed to Atty. Canoy as a private individual, and not in his public capacity. As such, the petitioners’ allegation that the subject articles are fair commentaries on matters of public interest are unavailing. As stated in Gertz v. Robert Welch, Inc., a newspaper or broadcaster publishing defamatory falsehoods about an individual who is neither a public official nor a public figure may not claim a constitutional privilege against liability for injury inflicted, even if the falsehood arose in a discussion of public interest. The mere fact that Atty. Canoy is a public figure does not automatically mean that every defamation against him is not actionable.

• Having established that the defamatory remarks are not privileged, the law provides that malice is presumed.

3) Element 3: Publication

There is publication if the material is communicated to a third person. It is not required that the person defamed has read or heard about the libelous remark. What is material is that a third person has read or heard the libelous statement, for “a man’s reputation is the estimate in which others hold him, not the good opinion which he has of himself.” Simply put, in libel, publication means making the defamatory matter, after it is written, known to someone other than the person against whom it has been written. “The reason for this is that [a] communication of the defamatory matter to the person defamed cannot injure his reputation though it may wound his self-esteem. A man’s reputation is not the good opinion he has of himself, but the estimation in which others hold him.” (Manila Bulletin Publishing Corporation v. Domingo, supra.)

4) Element 4: Identifiability

On the other hand, to satisfy the element of identifiability, it must be shown that at least a third person or a stranger was able to identify him as the object of the defamatory statement. It is enough if by intrinsic reference the allusion is apparent or if the publication contains matters of description or reference to facts and circumstances from which others reading the article may know the person alluded to; or if the latter is pointed out by extraneous circumstances so that those knowing such person could and did understand that he was the person referred to. (Manila Bulletin Publishing Corporation v. Domingo, supra.)

3. Things to note

The following are some additional things to note about this offense.

a. Civil aspect

Despite being included as a crime under the Revised Penal Code (RPC), a civil action28 for damages may be instituted by the injured party, which shall proceed independently of any criminal action for the libelous article and which shall require only a preponderance of evidence… (Nova Communications, Inc. v. Canoy, supra.)

b. Public officials

[E]very defamatory remark directed against a public person in his public capacity is not necessarily actionable but if the utterances are false, malicious, or unrelated to a public officer’s performance of his duties or irrelevant to matters of public interest involving public figures, the same may be actionable. (Nova Communications, Inc. v. Canoy, supra.)

A topic or story should not be considered a matter of public interest by the mere fact that the person involved is a public officer, unless the said topic or story relates to his functions as such. Assuming a public office is not tantamount to completely abdicating one’s right to privacy. (Yuchengco v. The Manila Chronicle Publishing Corporation, G.R. No. 184315, November 25, 2009, Per Chico-Nazario J.)

1) No burden to show truth of allegations of official misconduct

A rule placing on the accused the burden of showing the truth of allegations of official misconduct and/or good motives and justifiable ends for making such allegations would not only be contrary to Art. 361 of the Revised Penal Code. It would, above all, infringe on the constitutionally guaranteed freedom of expression. Such a rule would deter citizens from performing their duties as members of a self-governing community. Without free speech and assembly, discussions of our most abiding concerns as a nation would be stifled. As Justice Brandeis has said, “public discussion is a political duty” and “the greatest menace to freedom is an inert people.” (Vasquez v. CA, En Banc, G.R. No. 118971, September 15, 1999, Per Mendoza, J.)

c. Freedom of the press

A newspaper especially one national in reach and coverage, should be free to report on events and developments in which the public has a legitimate interest with minimum fear of being hauled (sic) to court by one group or another on criminal or civil charges for libel, so long as the newspaper respects and keeps within the standards of morality and civility prevailing within the general community. (Guingguing v. CA, G.R. No. 128959, September 30, 2005, Per Tinga, J.)

To avoid the self-censorship that would necessarily accompany strict liability for erroneous statements, rules governing liability for injury to reputation are required to allow an adequate margin of error by protecting some inaccuracies. It is for the same reason that the New York Times doctrine requires that liability for defamation of a public official or public figure may not be imposed in the absence of proof of “actual malice” on the part of the person making the libelous statement. (Ibid.)

4. Distinguish from other offenses

This offense is distinguished from other offenses or crimes below.

a. Libel vs Slander

Thus, libel is defamation via printed words. On the other hand, slander is defamation via spoken words.

For more information, see: Slander (or Oral Defamation)

b. Slander by deed vs Libel

Thus, libel is defamation via printed words. On the other hand, slander by deed is defamation via conduct or behavior.

Whether a certain slanderous act constitutes slander by deed of a serious nature or not, depends on the social standing of the offended party, the circumstances under which the act was committed, the occasion, etc. It is libel committed by actions rather than words. The most common examples are slapping someone or spitting on his/her face in front of the public market, in full view of a crowd, thus casting dishonor, discredit, and contempt upon the person of another. (Villanueva v. People, supra.)

For more information, see: Slander by Deed

References

• Title XIII – Crimes Against Honor, Act No. 3815, Revised Penal Code

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/Updated: May 20, 2023