Enrique G. de Leon vs. People of The Philippines

ENRIQUE G. DE LEON VS.
PEOPLE OF THE PHILIPPINES

G.R. No.212613
January 11,2016
FACTS:
This case is all about Grave Oral Defamation filed against Enrique G. De Leon
who uttered some feloniously words like “Walanghiya kang mangongotong na pulis ka,
ang yabang yabang mo noon, patay ka sa akin mamaya” and other words and
expressions which brings SPO3 Pedrito L. Leonardo into public contempt, discredit and
ridicule. As the version of the prosecution, the prosecution presented three witnesses,
namely:private respondent SPO3 Leonardo, Carlito Principe and Jennifer Malupeng.
Their combined testimonies narrated that De Leon and his son, John Christopher De
Leon, filed a complaint for Grave Misconduct against SPO3 Leonardo before the
People’s Law Enforcement Board (PLEB). The words uttered by De Leon caused SPO3
Leonardo embarrassment because there were several persons present at the PLEB
premises. As the version of the defense, the defense claimed that there was a prior
incident that took place on the morning of February 27, 2006 when De Leon, with his
son John, while having breakfast with their fellow joggers at the Philippine National
Railroad in Tutuban Station, were approached by SPO3 Leonardo who arrived on his
scooter. With his gun drawn, SPO3 Leonardo walked fast towards the group and at a
distance of two meters, more or less, he said "Putang ina mo, tapos ka na Ricky Boy”
which referring to De Leon. He pressed the trigger but the gun did not fire, and when he
was to strike again, De Leon was able to escape with the help of John. On the day of
the PLEB hearing, the defense alleged that it was SPO3 Leonardo who badmouthed
and threatened De Leon by uttering the words, “Putang-ina mong mayabang ka, pag di
mo inurong demanda mo sa akin, papatayin kita.” Moments later, they caused the
incident to be entered in the police blotter. The trial court found De Leon guilty beyond
reasonable doubt of Grave Oral Defamation. It considered SPO3 Leonardo’s police
blotter as prima facie evidence of the facts contained therein and ruled that his
actuations on the day of the incident were spontaneous. On the other hand, De Leon’s
defense were found to be only an afterthought and self-serving as he merely filed
counter-charges against Leonardo after he had received the subpoena from the OCP.
On appeal, the RTC rendered its decision affirming the ruling of the MTC. De Leon’s
motion for reconsideration was likewise denied. Aggrieved, De Leon filed a petition for
review under Rule 42 before the CA, which affirmed the RTC decision with modification
as to the imposed penalty. De Leon’s move for partial reconsideration was to no avail.
ISSUE:
1. Whether the decision of the MTC failed to include the facts and the law upon
which the decision was based.
2. Whether De Leon’s guilt has been proven beyond reasonable doubt.
RULING:
There was no breach of the constitutional mandate that decisions must express
clearly and distinctly the facts and the law on which they are based. The CA correctly
stated that the MeTC clearly emphasized in its decision the factual findings, as well as
the credibility and probative weight of the evidence for the defense. The Regional Trial
Court, as an appellate court, found no reason to reverse the decision of the MeTC.
Likewise, when it comes to credibility of witnesses, this Court accords the highest
respect, even finality, to the evaluation by the lower court of the testimonies of the
witnesses presented before it. The crime committed is only Slight Oral Defamation. The
Court agrees that the words uttered by De Leon were defamatory in nature. It is of the
view that the same only constituted simple oral defamation as first, as to the relationship
of the parties, they were obviously acquainted with each other as they were former
jogging buddies. Prior to the purported gun-pointing incident, there was no reason for
De Leon to harbor ill feelings towards SPO3 Leonardo. Second, as to the timing of the
utterance, this was made during the first hearing on the administrative case, shortly
after the alleged gun-pointing incident. The gap between the gun-pointing incident and
the first hearing was relatively short, a span of time within which the wounded feelings
could not have healed. The utterance made by De Leon was but a mere product of
emotional outburst, kept inside his system and unleashed during their encounter. Third,
such words taken as a whole were not uttered with evident intent to strike deep into the
character of SPO3 Leonardo as the animosity between the parties should have been
considered. It was because of the purported gun-pointing incident that De Leon hurled
those words. There was no intention to ridicule or humiliate SPO3 Leonardo because
De Leon’s utterance could simply be construed as his expression of dismay towards his
actions as his friend and member of the community.

Enrique G. de Leon vs. People of The Philippines

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ENRIQUE G. DE LEON VS.

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