- Petitioner
- Sr.
- Respondent
- People
- Citation
- G.R. No. 163181
- Court
- Supreme Court
- Division
- Second Division
- 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.