- Petitioner
- Bienvenido T. Canlapan
- Respondent
- Department of Justice
- Citation
- G.R. No. 240996
- Court
- Supreme Court
- Decided
- October 3, 2018
Whether certain words constitute Grave Slander and prosecutorial discretion in dismissing the complaint for oral defamation
Summary
Bienvenido T. Canlapan filed a complaint for Grave Slander against Atty. William B. Balayo for allegedly making defamatory statements. The Office of City Prosecutor dismissed the complaint for lack of merit, finding that the words 'Even if you bring ten (10) lawyers here, you will not get what you want!' were not defamatory or malicious. The Regional Prosecutor and Court of Appeals affirmed the dismissal. The Supreme Court denied Canlapan's petition for review on certiorari, ruling that the CA correctly found no grave abuse of discretion by the prosecutors. The Court emphasized that the essential elements of slander - including malicious imputation made publicly that tends to cause dishonor or discredit - were absent. The decision reinforces the principle that prosecutorial discretion in criminal cases should not be interfered with unless there is clear grave abuse of discretion, and that offensive language alone does not automatically constitute actionable defamation.
Focus of dispute
Whether certain words constitute Grave Slander and prosecutorial discretion in dismissing the complaint for oral defamation
Legal facts
Petitioner Bienvenido T. Canlapan filed a complaint for Grave Slander against respondent Atty. William B. Balayo for allegedly making defamatory statements. The specific words complained of were: 'Maski sampulo (10) pang abugado darahon mo, dai mo makua ang gusto mo!' (Even if you bring ten (10) lawyers here, you will not get what you want!). The Office of City Prosecutor dismissed the complaint for lack of merit, finding that the words were not defamatory or malicious and failed to establish the elements of slander.
Judgement and reasoning
Court of Appeals (CA): Affirmed the Resolution and Order of the Office of Regional Prosecutor, finding that the latter did not act with grave abuse of discretion when it affirmed the dismissal of the complaint for Grave Slander.
Office of City Prosecutor: Dismissed petitioner's complaint for Grave Slander for lack of merit, finding that the alleged words were not defamatory or malicious and did not establish the elements required for slander or oral defamation.
Office of Regional Prosecutor, Region V: Affirmed the Resolution of the Office of City Prosecutor dismissing the complaint, finding no grave abuse of discretion in the prosecutor's determination.
Supreme Court (SC): Denied the Petition for Review on Certiorari for failure to show reversible error by the CA. Affirmed that the words complained of were not defamatory or malicious, lacking the essential elements of slander. Emphasized that prosecutorial discretion in filing criminal cases should not be interfered with unless there is grave abuse of discretion.