Rufo Quemuel vs. Court of Appeals, G.R. L-22794, January 16, 1968
Subject: Obligations and Contracts
FACTS
Rufo Quemuel was the
editor of the newspaper Abante Tonite. In 1966, the newspaper published an
article that accused Jose Maria Sison, the leader of the Communist Party of the
Philippines, of being a "traitor" and a "coward." Sison
filed a libel suit against Quemuel, and the lower court found Quemuel guilty of
libel and sentenced him to imprisonment. Quemuel appealed the decision to the
Court of Appeals, which affirmed the lower court's decision. Quemuel then
appealed to the Supreme Court.
ISSUE
Whether or not the lower
court erred in convicting Quemuel of libel.
RULING
Yes. The Supreme Court
affirmed the decision of the Court of Appeals. The Court held that the lower
court did not err in convicting Quemuel of libel. The Court held that the
article in question was defamatory per se, and that Quemuel's acquittal on the
charge of slander was proper. The Court held that the article in question was
defamatory per se because it imputed to Sison the crime of treason and the vice
of cowardice. The Court held that these are imputations that are so inherently
offensive that they do not require proof of actual damage to the person's
reputation. The Court also held that Quemuel's acquittal on the charge of
slander was proper because the article in question was published in a
newspaper. The Court held that the publication of a libelous article in a
newspaper is slander per se, and that proof of actual damage is not required.
No comments:
Post a Comment