- Petitioner
- Rudolfo S. Magat
- Respondent
- People
- Citation
- G.R. No. 92201
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Gutierrez, Jr., J.
- 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.