1. U.S. V. SATURNINO CAPILLO, ET. AL.
(EN BANC)
G.R. NO. 9279, MARCH 25, 1915
FACTS: Accused was charged of the crime of exposing a legitimate child
to lose his civil status. The legitimate son of the defendant Saturnino Capillo,
delivered his son to Chua Pue Tee at the same time to lend them the sum of
P150. The lower court dismissed the case since it did not state facts sufficient
to constitute the crime charged. The contention of the prosecution is that the
true meaning of the language of the statute is that the prescribed penalties
are to be imposed upon "one who conceals, or exposes or subjects to danger
of loss of civil status, a legitimate child, with intent to cause it to lose its civil
status."
ISSUE: W/N accused were guilty of the crime of exposing a legitimate
child to lose his civil status
HELD: No. The Court confirmed that true meaning of word "expusiere"
(shall expose) in this article of the code involves the idea of abandonment by
an examination of the commentaries of the learned Spanish law writers upon
the corresponding article in the Spanish Criminal Code. The ruling at this
time is merely not the unlawful sale of a child by its father, and that such
conduct cannot properly be penalized under the provisions of the crime
charged.
2. TIRSO LOPEZ V. JOSE DELGADO (EN BANC)
G.R. NO. L-3499, MARCH 14, 1907
FACTS: The plaintiff prayed for 4,000 pesos damages for an alleged
malicious defamation expressed in writing, which was enclosed in an
envelope and sent to the plaintiff by the defendant by special messenger.
The trial court rendered judgment in favor of the plaintiff for 1 peso damages
and costs, and from this judgment the plaintiff appealed, and insists that the
damages allowed are wholly inadequate.
ISSUE: W/N the action of the defendant is sufficient to sustain a charge
of publishing a libel
HELD: No. Sending libelous matter in a sealed envelope by messenger to
the libeled person, is not such a publication of the libel as will support an
action under the provisions of Act No. 277 of the Philippine Commission.
3. JOSE ALEMANIA BUATIS, JR. V. PEOPLE
G.R. NO. 142509, MARCH 24, 2006
FACTS: The wife of private-complainant Atty. Pieraz, retrieved a letter
from their mailbox addressed to her husband. The letter was open, not
contained in an envelope. The letter contains insulting words towards the
private complainant. Meanwhile, petitioner insists that his letter was a
private communication made in the performance of his moral and social duty
as the attorney-in-fact of the Rodriguez estate where Mrs. Quingco is a
recognized tenant and to whom respondent had written the demand letter to
vacate, thus in the nature of a privileged communication and not libelous.
ISSUE: W/N petitioner is guilty of the crime of libel.
HELD: Yes. It is enough that the author of the libel complained of has
communicated it to a third person. Furthermore, the letter, when found in
the mailbox, was open, not contained in an envelope thus, open to public.
The victim of the libelous letter was identifiable as the subject letter-reply
was addressed to respondent himself. There was nothing in the said letter
which showed petitioner’s good intention and justifiable motive for writing
the same in order to overcome the legal inference of malice.
4. ROBERTO BRILLANTE V. COURT OF APPEALS, ET.AL.
G.R. NOS. 118757 & 121571, OCTOBER 19, 2004
FACTS: Petitioner Brillante held a press conference which was attended
by some 50 journalists where he accused Binay of plotting the assassination
of Syjuco. He further accused Binay of terrorism, intimidation and
harassment of the Makati electorate. Brillante also circulated among the
journalists copies of an open letter to President Aquino which discussed in
detail his charges against Binay. The open letter was subsequently published
in newspapers. Thereafter, Binay filed four complaints for libel against
Brillante, authors of the news article, and an advertising agency.
ISSUE: W/N petitioner is guilty of libel
HELD: Yes. An allegation made by a person against another is considered
defamatory if it ascribes to the latter the commission of a crime; the
possession of a vice or defect, whether real or imaginary; or any act,
omission, condition, status or circumstance which tends to dishonor or
discredit or put him in contempt, or which tends to blacken the memory of
one who is dead. Brillante’s statements during the press conference and in
the open letter explicitly referred to reprehensible acts allegedly committed
by Binay, Prudente and their associates, such as the use of goons to threaten
Binay’s opponents in the election and the plotting of Syjuco’s assassination.
5. PEOPLE V. JOSE BUAN (EN BANC)
G.R. NO. L-25366, MARCH 29, 1968
FACTS: The accused was driving a passenger bus along the MacArthur
Highway. The vehicle driven by him struck and collided with the passenger
jeep, damaging said jeep and causing it to turn turtle, and injuring its
passengers.
A charge was filed against the accused-appellant, one for slight
physical injuries through reckless imprudence in the Justice of the Peace
Court of Guiguinto, for which he was tried and acquitted. Prior to this
acquittal, however, the Provincial Fiscal filed in the Court of First Instance
information for serious physical injuries, and damage to property through
reckless imprudence. Admittedly, both charges referred to the same highway
collision.
ISSUE: W/N the second case placed the appellant twice in jeopardy for
the same offense
HELD: Yes. Once convicted or acquitted of a specific act of reckless
imprudence, the accused may not be prosecuted again for that same act. The
essence of the quasi offense of criminal negligence under Article 365 of the
Revised Penal Code lies in the execution of an imprudent or negligent act
that, if intentionally done, would be punishable as a felony. The law penalizes
the negligent or careless act, not the result thereof. The gravity of the
consequence is only taken into account to determine the penalty; it does not
qualify the substance of the offense. As the careless act is single, whether
the injurious result should affect one person or several persons, the offense
remains one and the same. It cannot be split into different crimes and
prosecutions.
6. JASON IVLER V. HON. MODESTO-SAN PEDRO
G.R. NO. 172716, NOVEMBER 17, 2010
FACTS: Petitioner Jason Ivler was charged with two separate offenses:
(1) Reckless Imprudence Resulting in Slight Physical Injuries for injuries
sustained by respondent Evangeline L. Ponce; and (2) Reckless Imprudence
Resulting in Homicide and Damage to Property for the death of respondent
Ponce’s husband Nestor C. Ponce and damage to the spouses Ponce’s
vehicle.
ISSUE: W/N petitioner’s constitutional right under the Double Jeopardy
Clause bars further proceedings in second offense charged
HELD: Yes. The doctrine that reckless imprudence under Article 365 is a
single quasi-offense by itself and not merely a means to commit other crimes
such that conviction or acquittal of such quasi-offense bars subsequent
prosecution for the same quasi-offense, regardless of its various resulting
acts, undergirded this Court’s unbroken chain of jurisprudence on double
jeopardy as applied to Article 365 starting with People v. Diaz, decided in
1954. Hence, second criminal case was dismissed.
