- Petitioner
- Bienvenido T. Canlapan
- Respondent
- Department of Justice
- Citation
- G.R. No. 240996
- Court
- Supreme Court
- Division
- First Division
- 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.