- Petitioner
- Rudolfo S. Magat
- Respondent
- People
- Citation
- G.R. No. 92201
- Court
- Supreme Court
- Decided
- August 21, 1991
Criminal slander charges against spouses for allegedly uttering defamatory words in a hospital room and the defense of prescription of the offense
Summary
This criminal case involved slander charges against Dr. Rudolfo S. Magat and his wife Minerva for allegedly uttering defamatory words against Ma. Luisa F. Domocmat at Manila Sanitarium and Hospital on May 12, 1985. The Metropolitan Trial Court convicted them of light slander, while the Regional Trial Court modified this to serious slander with imprisonment. The Supreme Court reversed both decisions and acquitted the petitioners on two grounds: (1) the light offense of slander had already prescribed when the complaint was filed, as light offenses prescribe in two months under Article 90 of the Revised Penal Code, but the complaint was filed over four months after the incident; and (2) reasonable doubt existed regarding the credibility of the alleged statements, which the Court found implausible given the circumstances and the moral character of the accused. The case highlighted issues of prescription of criminal offenses and the importance of witness credibility in slander cases.
Focus of dispute
Criminal slander charges against spouses for allegedly uttering defamatory words in a hospital room and the defense of prescription of the offense
Legal facts
On May 12, 1985, at Room 335 of Manila Sanitarium and Hospital, spouses Dr. Rudolfo S. Magat and Minerva F. Magat allegedly uttered slanderous words against Ma. Luisa F. Domocmat in the presence of Dr. Clarita Garcia. The incident occurred around 10:00-10:30 AM. All parties were connected to the hospital and belonged to the Seventh-Day Adventist Church. The complaint was filed on September 17, 1985, over 4 months after the incident. Only four persons were present during the alleged incident. The alleged defamatory words included sexually explicit language and accusations of immoral conduct.
Judgement and reasoning
Metropolitan Trial Court of Pasay City (MTC): Convicted both accused of light slander instead of serious slander as charged. Sentenced each to pay P150.00 fine, P5,000.00 moral damages, and P3,000.00 attorney's fees plus costs. The judge expressed regret at having to decide the case as he did not hear the testimony, having taken over from another judge who inhibited himself.
Regional Trial Court of Pasay City (RTC): Modified the MTC decision and found appellants guilty of serious slander as originally charged. Sentenced each to suffer indeterminate penalty of imprisonment from 3 months of arresto mayor (minimum) to 1 year and 1 day of prision correccional (maximum). Affirmed the award of moral damages and attorney's fees.
Supreme Court (SC): GRANTED the petition and REVERSED and SET ASIDE the RTC judgment. ACQUITTED petitioners on grounds of reasonable doubt. Held that the MTC had no jurisdiction to convict for light slander as the offense had already prescribed under Article 90 of the Revised Penal Code (light offenses prescribe in 2 months). Found that the incident occurred on May 12, 1985, but complaint was filed on October 14, 1985, exceeding the 2-month prescription period. Also found reasonable doubt as to the credibility of the alleged statements, noting the implausibility of the words attributed to the accused and the questionable circumstances surrounding the trial.