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    Espuelas v. People, G.R. No. L-2990, 1951

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    Charles Dela Fuente
    Petitioner was convicted under Article 142 of the RPC for circulating a scurrilous libel against the Philippine government. Specifically, Petitioner took a photo of himself appearing to commit suicide and sent it along with a suicide note blaming the government of President Roxas to several newspapers. While the note only discredited President Roxas and his administration, the court found Petitioner guilty because Article 142 punishes libel against any duly constituted government authorities, not just the government as a whole. The essence of seditious libel is its tendency to stir up widespread discontent and induce illegal actions rather than using constitutional methods to address perceived problems.

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    Espuelas v. People, G.R. No. L-2990, 1951

    Uploaded by

    Charles Dela Fuente
    92 views1 page
    Petitioner was convicted under Article 142 of the RPC for circulating a scurrilous libel against the Philippine government. Specifically, Petitioner took a photo of himself appearing to commit suicide and sent it along with a suicide note blaming the government of President Roxas to several newspapers. While the note only discredited President Roxas and his administration, the court found Petitioner guilty because Article 142 punishes libel against any duly constituted government authorities, not just the government as a whole. The essence of seditious libel is its tendency to stir up widespread discontent and induce illegal actions rather than using constitutional methods to address perceived problems.

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    20. Espuelas v. People, G.R. No. L-2990, 1951

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    Petitioner was convicted under Article 142 of the RPC for circulating a scurrilous libel against the Philippine government. Specifically, Petitioner took a photo of himself appearing to commit suicide and sent it along with a suicide note blaming the government of President Roxas to several newspapers. While the note only discredited President Roxas and his administration, the court found Petitioner guilty because Article 142 punishes libel against any duly constituted government authorities, not just the government as a whole. The essence of seditious libel is its tendency to stir up widespread discontent and induce illegal actions rather than using constitutional methods to address perceived problems.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    92 views1 page

    Espuelas v. People, G.R. No. L-2990, 1951

    Uploaded by

    Charles Dela Fuente
    Petitioner was convicted under Article 142 of the RPC for circulating a scurrilous libel against the Philippine government. Specifically, Petitioner took a photo of himself appearing to commit suicide and sent it along with a suicide note blaming the government of President Roxas to several newspapers. While the note only discredited President Roxas and his administration, the court found Petitioner guilty because Article 142 punishes libel against any duly constituted government authorities, not just the government as a whole. The essence of seditious libel is its tendency to stir up widespread discontent and induce illegal actions rather than using constitutional methods to address perceived problems.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 1

    GR NO.

    L-2990 ESPUELAS vs PEOPLE DATE: 17 December 1951


    Petitioner was convicted for violation of ART. 142, RPC. Said Article punishes those who shall
    write, publish or circulate scurrilous libels against the Government of the Philippines or any of
    the duly constituted authorities thereof or which suggest or incite rebellious conspiracies or
    riots or which tend to stir up the people against the lawful authorities or to disturb the peace of
    the community.

    Petitioner allegedly photograph himself making it seem like he was hanging lifeless, when in
    FACTS fact he was standing on a barrel. After securing the photo, Petitoner sent copies of the same to
    several newspaper of general circulation throughout the PH. He also attached a suicide note to
    the photo.

    In the said suicide note, Petitioner blamed the government under Roxas administration and that
    he is ashamed of the same.

    Petitioner then admitted that he did wrote the letter and sent the same to various publications.
    WHETHER OR NOT PETITIONER VIOLATED ART. 142, RPC?
    ISSUE/S
    A: Yes
    The court notes that writings which tend to overthrow or undermine the security of the
    government or to weaken the confidence of the people in the government are against the
    public peace, and are criminal not only because they tend to incite to a breach of the peace but
    because they are conducive to the destruction of the very government itself.

    Although there is a constitutional guaranty on the freedom of speech, the same is not absolute
    and should not be taken advantage.

    In the case at bar, even though it can be construed from the note that it only discredit
    HELD President Roxas and his men, however, this doesn’t mean that Art. 142 is not committed. Art.
    142 punishes not only all libels against the Government but also libels against any of the duly
    constituted authorities thereof.

    The essence of seditious libel may be said to its immediate tendency to stir up general
    discontent to the pitch of illegal courses; that is to say to induce people to resort to illegal
    methods other than those provided by the Constitution, in order to repress the evils which
    press upon their minds.

    RULING: GUILTY

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