- Petitioner
- People
- Respondent
- Isauro Santiago
- Citation
- G.R. No. L-17663
- Court
- Supreme Court
- Division
- En Banc
- Ponente
- Concepcion, J.
- 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.