(Article 26)

People of the Philippines vs. Isauro Santiago

Facts:
The case relates to the exposure of Arsenio H. Lacson, then Mayor of the City
of Manila, to public hatred and ridicule by one Isauro Santiago, in the course
of a political speech in Quiapo, Manila on the
th
of !ctober "##. $efendant,
through an a%pli&er syste% and in the presence of a cro'd of around a
hundred persons called out (Arsenio Hayop Lacson, pinakawalang hiyang
Alkalde, Mayor Lacson raped a woman at the Aroma Cafe and another City
Hall employee in Shellborne Hotel) in 'hich the plainti* &led an infor%ation
for libel against the defendant on August "", "#+,. $efendant, through his
Motion to Quash Infor%ation, clai%ed that the charge is not libel, but oral
defa%ation, and the &ling of infor%ation of the latter has already prescribed.
Issue:
-hether or not the cri%e charged in the infor%ation is oral defa%ation, under
Article ./ of the 0e1ised 2enal Code, or libel, under Article ., in relation to
Article .., of the sa%e Code.
Held:
The Supre%e Court, 3n 4anc, held that the facts alleged in the infor%ation
constitute the cri%e of oral defa%ation, under Article ./ of the 0e1ised 2enal
Code. The grounds by 'hich the infor%ation for libel 'as &led is the erroneous
co%parison of the %edia radio and a%pli&er syste%. According to Su%%it
Hotel Co. 1s. 5ational 4roadcasting Co. 62A7"89 A.L.0. #+.:, the rules
governing such oense were declared inapplicable to e!temporaneous
remarks of scurrilous nature, made ad libitum in the course of a radio
broadcast by a person hired to read a prepared te!t, but not appearing
thereon"# The state%ents, 'hich 'ere heard through an a%pli&er syste%,
though defa%atory, are exte%poraneous such that no %anuscript or prepared
text 'as read.