Victor Lee v. People

Summary

Victor Lee was criminally convicted of libel for distributing defamatory leaflets against Dr. Jovito Lee Jr., calling him a 'satanic doctor' and 'child abuser.' The Regional Trial Court imposed a P6,000 fine and P500,000 moral damages. The Court of Appeals affirmed the conviction and damages. On appeal to the Supreme Court, Lee challenged only the damages award. The Supreme Court denied the petition but reduced moral damages to P100,000, finding that while Dr. Lee suffered legitimate emotional distress and reputational harm from Lee's decade-long defamatory campaign, moral damages should not enrich the complainant. The case demonstrates the intersection of criminal libel prosecution with civil damages recovery.