Statements against public officials do not constitute oral defamation or slander unless proven malicious, the Supreme Court (SC) said.
In a decision promulgated in December 2023, the higher Court acquitted Argelyn Labargan of grave oral defamation against Aileen Macabangon, the barangay kagawad of Muntay, Kolambugan in Lanao del Norte. The document indicated how the latter heard Labargan yell from outside her house that the barangay official was “dull, uneducated, ignorant, and biased towards another resident".
Several people heard Labargan's remarks, prompting the Municipal Circuit Trial Court to convict the former of grave oral defamation.
However, the SC’s ruling stated that offensive remarks against public officers do not constitute defamation if it relates to their discharge of official duties, unless malice is proven.
“Under Article 358 of the Revised Penal Code, there is oral defamation or slander when (1) there is an allegation of a crime, fault, or flaw; (2) made orally; (3) publicly; (4) maliciously; (5) towards a person, alive or dead; and (6) such allegation tends to cause dishonor on the person defamed,” the SC wrote.
Due to this, the SC recognized a person's right to free speech, adding that it empowers citizens to hold public officials accountable, as the public office is a place of public trust.
“In the present case, Macabangon is a public officer. Labargan’s statements against her were criticisms of her competence as a barangay kagawad, specifically her supposed bias against Labargan in the barangay conciliation proceedings,” the SC stressed.
Macabangon's case against Labargan failed to prove actual malice on the latter's part; Concluding that while the statements may be offensive, such criticisms do not constitute defamation.
