Article 20 Case Digest: Occena v. Icamina
EULOGIO OCCENA VS. HON. PEDRO M. ICAMINA, PRESIDING JUDGE, BRANCH X OF THE REGIONAL TRIAL COURT, SIXTH JUDICIAL REGION, SAN JOSE, ANTIQUE, THE PEOPLE OF THE PHILIPPINES, REPRESENTED BY THE HONORABLE PROVINCIAL FISCAL OF ANTIQUE; AND CRISTINA VEGAFRIA, RESPONDENTS.
G.R. NO. 82146, JANUARY 22, 1990
FACTS:
On May 31, 1979, the petitioner Eulogio Occena, filed a criminal complaint of grave oral defamation against the respondent, Cristina Vegafria, for allegedly uttering seriously vulgar and malicious words against the respondent in public. This caused great and irreparable damage and injury to his person and honor.
After the trial, the respondent got convicted of the said crime, but the trial court did not award damages to the petitioner. In the trial courts opinion, the facts and circumstances of the case as adduced by the evidence do not warrant the awarding of moral damages.
The petitioner then took the case to the Regional Trial Court. The appeal was then denied because of lack of merit.
ISSUE:
Whether or not the respondent is civilly liable in relation to the oral defamation case filed against her.
RULING:
Yes. Civil obligations arising from criminal offenses are governed by Article 100 of the Revised Penal Code which provides that, every person criminally liable for a felony is also civilly liable. Moreover, Article 2219, par(7) of the Civil Code allows the recovery of moral damages in case of libel, slander or any form of defamation.
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