- Petitioner
- People
- Respondent
- Isauro Santiago
- Citation
- G.R. No. L-17663
- Court
- Supreme Court
- Decided
- May 30, 1962
Whether defamatory statements made through an amplifier system constitute libel under Article 355 or oral defamation under Article 358 of the Revised…
Summary
The Supreme Court affirmed the dismissal of a libel charge against Isauro Santiago, who made defamatory statements against Mayor Arsenio Lacson through an amplifier system during a political speech. The Court distinguished between libel and oral defamation, ruling that amplifier systems do not constitute the permanent means of publication enumerated in Article 355 of the Revised Penal Code. Unlike radio transmission which uses electromagnetic waves, amplifier systems use conducting wires and lack the permanence characteristic of libel. The Court held the statements constituted oral defamation under Article 358, which had already prescribed by the time the information was filed. This decision establishes important precedent regarding the technological means that constitute libel versus oral defamation, emphasizing the permanence requirement for libel charges.
Focus of dispute
Whether defamatory statements made through an amplifier system constitute libel under Article 355 or oral defamation under Article 358 of the Revised Penal Code
Legal facts
On October 5, 1959, defendant Isauro Santiago allegedly made defamatory statements against Mayor Arsenio H. Lacson during a political speech at 392 Fraternal, Quiapo, Manila. The statements were delivered through an amplifier system before approximately 100 persons, calling the mayor 'Arsenio Hayop Lacson, pinakawalang hiyang Alkalde' and making false accusations about rape. The information was filed on August 11, 1960, charging Santiago with libel.
Judgement and reasoning
Court of First Instance of Manila: Granted defendant's motion to quash the information, ruling that the crime charged was oral defamation, not libel, and that it had already prescribed since more than six months had elapsed from October 5, 1959 to the filing of the information on August 11, 1960.
Supreme Court (SC): Affirmed the lower court's decision. The Court held that an amplifier system does not fall within the enumerated means in Article 355 (writing, printing, lithography, engraving, radio, phonograph, etc.) because: (1) radio transmission uses electromagnetic waves without conducting wires, while amplifier systems use conducting wires; (2) the enumerated means in Article 355 have a common characteristic of permanence as means of publication, explaining the graver penalty for libel versus oral defamation. The statements constituted oral defamation under Article 358, which prescribed six months after commission (April 5, 1960), over four months before the information was filed.