4. Vasquez v.

CA, GR No 113971, September 15, 1999_ Prior Restraint

Facts
This case involves a libel charge against Rodolfo R. Vasquez for allegedly making false and malicious
statements about Barangay Chairman Jaime Olmedo. The libelous statements were published in an article in the
newspaper "Ang Tinig ng Masa." The article accused Olmedo of landgrabbing and involvement in illegal
activities such as attempted murder, gambling, and theft of fighting cocks. Vasquez was charged with libel in
the Regional Trial Court of Manila and was found guilty. The Court of Appeals affirmed the decision.

Issue
The main issue in this case is whether Vasquez should be held liable for libel for his statements against Olmedo.

Ruling
The court ruled in favor of Vasquez, stating that even if the defamatory statement is false, no liability can attach
if it relates to official conduct, unless the public official concerned proves that the statement was made with
actual malice. In this case, the prosecution failed to prove that the charges made by Vasquez were false or that
he made them with knowledge of their falsity or with reckless disregard of whether they were false or not.

Ratio
The court's ratio is as follows:

1. Vasquez cannot claim to have been the source of only a few statements in the article and point to other
parties as the source of the rest, as he admitted to being the spokesperson of the families during the
interview.
2. While the information did not set out the entire news article as published, Vasquez waived objection
based on this defect by engaging in the trial of the entire article and seeking to prove its truth.
3. To prove libel, the following elements must be proven: a discreditable act or condition concerning
another, publication of the charge, identity of the person defamed, and existence of malice.
4. The defamatory statements made by Vasquez were proven to be true, based on evidence such as a letter
from the NHA Inspector General and memoranda from the NHA General Manager.
5. Even if the defamatory statement is false, no liability can attach if it relates to official conduct, unless
the public official proves that the statement was made with actual malice.

Summary
In summary, the court reversed the decision of the lower court and acquitted Vasquez of the libel charge, stating
that he was able to prove the truth of his charges against Olmedo and that placing the burden on the accused to
prove the truth of allegations of official misconduct would infringe on the freedom of expression. The court
emphasized the importance of freedom of expression and the need to protect citizens' rights to criticize public
officials.