Pedro S. Lacsa v. Honorable Intermediate Appellate and People of the Philippines, G.R. No.

74907, May 23, 1988 (2nd Division), C.J. Yap

Facts: Pedro S. Lacsa is a Certified Public Accountant by profession. Having previously
been a former member of the Philippine Columbian Associations Board of Directors, and then, a
representative of one of its institutional members, Pedro Lacsa offered his services for free to serve
as auditor of the Association. As auditor, Pedro Lacsa had accessed to the records of the
associations members including the personal folder of the private complainant, Ponciano Marquez,
then president of the association. Lacsa discovered that Marquez was a mere associate member
of the association, and questioned Marquez qualification to hold the presidency of the association,
when only propriety members can be voted to said position. Thus, he wrote a letter to the Board of
Directors on December 21, 1978, wherein he impugned the status of Marquez as a propriety
member and as president of the association. Lacsa contended that the issuance of a propriety
membership to Marquez, without the authority of the associations BOD was erroneous. He also
wrote a letter dated January 2, 1979 to Marquez, asking the latter to relinquish the presidency, and
likewise branded Marquez as a de facto president.The grounds he cited for such a request were
the same as the ones he gave in his letter to the BOD.Lacsa copy furnished the letter to a number
of people of familiar names. Not contented with what he had already done, Lacsa had caused the
publication in a newsletter circulated to the associations members, an item entitled Doubts as to
the Legitimacy of the Incumbent President.
Ponciano Marquez instituted separate criminal complaint and civil action against Lacsa,
claiming to have been maligned, defamed, and exposed to public ridicule by Lacsas actions. The
trial court found Lacsa guilty of libel, and was later affirmed by the Intermediate Appellate Court.
Issue: Whether or not the appellate court erred in affirming Lacsas conviction of Libel.
Ruling: The Intermediate Appellate Court did not commit any error in convicting Lacsa for
libel. The elements of libel are: 1) The imputation of a discreditable act or condition to another; 2)
publication of the imputation; 3) identity of the person defamed; and 4) existence of malice. The law
presumes that every defamatory imputation is malicious, even if it be true, if not intention and
justifiable motive for making it is shown, except in cases concerning privileged communications.

The act of Lacsa in branding Marquez as a mere de facto president and insinuating imperfection in
the latters status as a propriety member, as stated in the letters he caused to be published and
circulated, most certainly exposed Marquez to public contempt and ridicule.