In a libel case, the Supreme Court of the Philippines addressed the delicate balance between freedom of speech and the protection of individual reputation. The Court partially affirmed the conviction of Eliseo Soriano for libel, emphasizing that while religious expression is protected, it cannot be used as a shield for malicious insults. This decision clarifies the boundaries of permissible speech, ensuring that criticism does not devolve into defamation, which undermines the honor and dignity of individuals.

Words as Weapons: When Religious Discourse Crosses the Line into Defamation

The case of Eliseo Soriano v. People of the Philippines stemmed from statements made by Soriano during his radio program, “Ang Dating Daan.” These statements, directed at Evangelist Wilde Almeda and members of the Jesus Miracle Crusade International Ministry (JMCIM), led to two counts of libel against Soriano. The legal question at the heart of the matter was whether Soriano’s statements, made in the context of religious broadcasting, constituted actionable libel or were protected under the constitutional guarantee of freedom of expression.

Libel, as defined under Article 353 of the Revised Penal Code, involves the public and malicious imputation of a crime, vice, or defect that causes dishonor, discredit, or contempt to a person or entity. The Supreme Court reiterated the four requisites for an imputation to be considered libelous: it must be defamatory, malicious, given publicity, and the victim must be identifiable. The presence of these elements determines whether a statement crosses the line from protected speech to unlawful defamation.

The Court scrutinized Soriano’s statements, particularly the use of terms like “GAGO,” “TARANTADONG PASTOR,” “PASTOR NG DEMONYO IYAN,” and “BULAANG PROPETA.” These words, the Court found, were clearly defamatory as they disparaged Evangelist Almeda. Quoting Manila Bulletin Publishing Corporation and Ruther Batuigas v. Victor A. Domingo and the People of the Philippines, the Court emphasized that a defamatory allegation ascribes to a person the commission of a crime, the possession of a vice, or any circumstance that tends to dishonor or discredit them. The natural interpretation of Soriano’s words led to the conclusion that they were indeed defamatory.

The element of malice is crucial in libel cases. The Revised Penal Code presumes that every defamatory imputation is malicious, even if true, unless a good intention and justifiable motive are shown. Article 354 of the Revised Penal Code provides:

Art. 354. Requirement for publicity. – Every defamatory imputation is presumed to be malicious, even if it be true, if no good intention and justifiable motive for making it is shown, except in the following cases:

1. A private communication made by any person to another in the performance of any legal, moral or social duty; and
2. A fair and true report, made in good faith, without any comments or remarks, of any judicial, legislative or other official proceedings which are not of confidential nature, or of any statement, report or speech delivered in said proceedings, or of any other act performed by public officers in the exercise of their functions.

Soriano argued that his motive was to caution religious leaders against misusing religion, but the Court found that his statements lacked any justifiable motive and instead served to degrade and insult Almeda. The Court also rejected the argument that Soriano’s statements were qualifiedly privileged communications, noting that even fair commentaries on matters of public interest could be actionable if actual malice is proven.

Addressing the element of publication, the Court noted that Soriano’s statements were broadcasted through his radio program, thereby satisfying the requirement that the defamatory matter be made known to someone other than the person against whom it was written. As the Court stated, “Libel is published not only when it is widely circulated, but also when it is made known or brought to the attention or notice of another person other than its author and the offended party.”

The final element, identification, proved pivotal in the Court’s partial acquittal of Soriano. While the Court affirmed Soriano’s guilt concerning statements against Almeda, it acquitted him in Criminal Case No. IR-4848, which involved statements against the JMCIM as a whole. The Court cited MVRS Publications, Inc., et al. v. Islamic Da’wah Council of the Phils., Inc., emphasizing that declarations about a large class of people cannot be interpreted to refer to an identified or identifiable individual. The Court reasoned that the information in Criminal Case No. IR-4848 did not refer to any specific individual but merely mentioned “persons comprising the Jesus Miracle Crusade, International Ministry.”

The Supreme Court drew a distinction between defaming a specific individual and making broad statements about a group, highlighting the need for a clear and identifiable victim in libel cases. The Court held:

Declarations made about a large class of people cannot be interpreted to advert to an identified or identifiable individual. Absent circumstances specifically pointing or alluding to a particular member of a class, no member of such class has a right of action without at all impairing the equally demanding right of free speech and expression, as well as of the press, under the Bill of Rights.

The Court dismissed Soriano’s claim that his statements were protected expressions of religious belief. The Court clarified that insults directed at another person do not qualify as religious speech. Drawing from Soriano v. Laguardia, et al., the Court stated, “Plain and simple insults directed at another person cannot be elevated to the status of religious speech. Even petitioner attempts to place his words in context show that he was moved by anger and the need to seek retribution, not by any religious conviction.”

The Court’s decision balances the constitutional right to freedom of expression with the right to protection from defamation. It reaffirms that while individuals are free to express their opinions, including in matters of religion, they must do so without resorting to malicious and defamatory statements that harm the reputation and honor of others.

FAQs

What was the key issue in this case?	The key issue was whether Eliseo Soriano’s statements during his radio program constituted actionable libel or were protected under the constitutional guarantee of freedom of expression. The Court had to determine if the elements of libel were present in Soriano’s statements.
What are the elements of libel?	The four essential elements of libel are: (a) it must be defamatory; (b) it must be malicious; (c) it must be given publicity; and (d) the victim must be identifiable. All these elements must be present for a statement to be considered libelous.
Why was Soriano acquitted in one of the libel charges?	Soriano was acquitted in Criminal Case No. IR-4848 because the statements were made about a general group (JMCIM) and not a specifically identifiable individual. The Court held that declarations about a large class of people do not automatically defame individual members of that class.
What is the significance of “malice” in a libel case?	Malice is a critical element because a defamatory imputation is presumed malicious unless a good intention and justifiable motive are shown. If the speaker acted with malice, their statements are more likely to be considered libelous.
Are religious statements protected under freedom of speech?	While religious expression is protected, it is not absolute. The Court clarified that plain insults directed at individuals, even within a religious context, do not qualify as protected religious speech and can be considered libelous.
What does “publication” mean in the context of libel?	In libel law, “publication” means making the defamatory statement known to someone other than the person making the statement and the person being defamed. This element is satisfied when the statement is communicated to a third party.
Can statements about a group be considered libelous to individuals within that group?	Generally, statements about a large group cannot be considered libelous to individual members unless there are specific circumstances that point directly to particular individuals within the group. The victim must be identifiable for a libel case to succeed.
What are qualifiedly privileged communications?	Qualifiedly privileged communications are statements made under circumstances that provide some protection against libel claims, such as private communications made in the performance of a legal, moral, or social duty, or fair reports of official proceedings. However, even these can be actionable if actual malice is proven.

This case underscores the importance of responsible speech, especially in public forums like radio broadcasting. It serves as a reminder that while freedom of expression is a fundamental right, it comes with the responsibility to avoid making defamatory statements that harm the reputation and dignity of others. The Supreme Court’s decision provides valuable guidance on balancing these competing rights within the framework of Philippine law.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Eliseo Soriano v. People, G.R. No. 225010, November 21, 2018