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Also, the matters contained in the following were written in accordance with the law, rules, and jurisprudence prevailing at the time of writing and posting, and do not include any future developments on the subject matter under discussion.
AT A GLANCE:
In the case Argelyn M. Labargan v. People of the Philippines, G.R. No. 246824, December 6, 2023, the Supreme Court emphasized that statements against public officers do not constitute oral defamation when made in relation to their discharge of official duties, unless the prosecution establishes that they were uttered with actual malice.
FACTS:
Petitioner Argelyn M. Labargan was charged with grave oral defamation and light threats by Respondent Aileen R. Macabangon, a barangay kagawad in Muntay, Kolambugan, Lanao del Norte. The Complaint for other light threats was dismissed, but she was found guilty of grave oral defamation.
Petitioner Labargan allegedly insulted Macabangon by calling her “dull,” “ignorant,” and biased during a barangay conciliation session. These words were publicly uttered as Macabangon passed by Petitioner Labargan’s house near a public highway, where other people heard the remarks. Petitioner Labargan denied the accusations against her and claimed that she had an argument with Edna, and not Macabangon.
The Municipal Circuit Trial Court found Petitioner Labargan guilty of grave oral defamation but dismissed the light threats charge. The Regional Trial Court and Court of Appeals affirmed the conviction.
ISSUE:
Whether the Petitioner Labargan is guilty beyond reasonable doubt of grave oral defamation.
RULING:
The Supreme Court ruled that Petitioner Labargan is not guilty of grave oral defamation.
Statements against public officers do not constitute oral defamation when made in relation to their discharge of official duties, unless the prosecution establishes that they were uttered with actual malice.
Public office is a public trust. Persons with authority, especially elective officials, must be prepared for public scrutiny and criticisms related to their official duties. Freedom of speech and its cognate rights are indispensable in a democracy such as ours, where “sovereignty resides in the people and all government authority emanates from them.” These constitutional guarantees ensure that any Filipino may participate in the governance of the country, peaceably assemble, and “petition the government for redress of grievances.” Absent these freedoms, authoritarianism – the antithesis of democracy – prevails.
In the present case, Petitioner Labargan’s defamatory remarks against Macabangon were related to the latter’s official duties as a barangay kagawad. Moreover, the prosecution failed to show actual malice. Therefore, she is not guilty of grave oral defamation.
Source:
Argelyn M. Labargan vs. People of the Philippines
G.R. No. 246824 | December 06, 2023
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