- Petitioner
- Sr.
- Respondent
- People
- Citation
- G.R. No. 163181
- Court
- Supreme Court
- Decided
- October 19, 2005
Grave oral defamation charges and denial of due process claims
Summary
Bonifacio L. Cañal, Sr. was convicted of grave oral defamation for publicly calling Daylinda P. Cañal a thief outside a courthouse. After his defense counsel repeatedly failed to appear at hearings, the trial court deemed his right to present evidence waived. The conviction was upheld through all appellate levels. On final review, the Supreme Court affirmed the conviction but corrected the penalty from an indeterminate sentence to a straight six months imprisonment, finding no evidence of the alleged prior conviction that justified the enhanced penalty. The Court rejected due process claims, emphasizing that clients are bound by their counsel's negligence. The case demonstrates the balance between due process rights and procedural compliance in criminal proceedings, while affirming that grave oral defamation requires proof of defamatory imputation causing injury to reputation.
Focus of dispute
Grave oral defamation charges and denial of due process claims
Legal facts
On July 25, 1996, at around 8:30 a.m. outside the 7th MCTC courthouse in Hinatuan, Surigao del Sur, Bonifacio L. Cañal, Sr. allegedly made defamatory statements against Daylinda P. Cañal, calling her a thief in the presence of several people. Daylinda filed a complaint leading to criminal charges under Article 358 of the Revised Penal Code. During trial, Bonifacio's defense counsel repeatedly failed to appear, resulting in waiver of right to present evidence.
Judgement and reasoning
7th Municipal Circuit Trial Court (MCTC) of Hinatuan-Tagbina: Found accused guilty beyond reasonable doubt of grave oral defamation. Sentenced to 6 months and 1 day to 2 years, 4 months and 1 day imprisonment, plus P5,000 moral damages and P2,000 compensatory damages. Court deemed defense waived right to present evidence due to counsel's repeated non-appearance.
Court of Appeals (CA): Denied petition and affirmed RTC decision in toto, with costs against accused-petitioner.
Regional Trial Court (RTC): Affirmed MCTC decision after careful review. Held that trial court correctly declared accused waived right to present evidence after giving several opportunities. Conviction and penalty properly imposed considering accused's previous conviction.
Supreme Court (SC): Affirmed conviction but modified penalty. Rejected due process claims, holding petitioner was afforded sufficient opportunity to present evidence but failed through counsel's negligence. Client bound by counsel's failings. However, corrected penalty to straight 6 months imprisonment due to lack of evidence of prior conviction. Deleted compensatory damages award for lack of factual basis. Affirmed P5,000 moral damages under Article 2219(7) of New Civil Code.