People vs.

Santiago *Noscitur a sociis: when a word is ambiguous, its meaning may be determined by reference to the rest of the statute. **Note: This rule was not mentioned in the case but the rule will be applied in the later part of the decision. FACTS: Appeal from an order of the Court of First instance of Manila According to the information filed, Defendant Isauro Santiago committed the crime of libel It was alleged that on the October 5, 1959, the accused for the purpose of injuring the name and reputation of Arsenio H. Lacson, and of impeaching and besmirching the latters virtue, honesty, honor and reputation, and with malicious intent of exposing him to public hatred, called Lacson, in the course of a political speech delivered at 392 Fraternal Quiapo, through an amplifier system and before a crowd of around a hundred persons, Arsenio Hayop Lacson, pinakawalang hiyang Alkalde, Mayor Lacson raped a woman at the Aroma Caf and another City Hall employee in Shellborne Hotel. The defendant moved to quash this information by arguing that the crime committed is not libel but oral defamation, which was already prescribed since it the commission of the crime is alleged to be on October 5, 1959 or more than 6 months prior to the filing of the information on August 11, 1960. (Note: the crime of oral defamation already prescribed on April 5, 1960)

ISSUES: The only issue here is whether or not the crime charged in the information is oral defamation under Article 358 of the RPC or libel under Article 355 in relation to Article 353 of the RPC.

HELD: The facts alleged in the information constitute the crime of oral defamation, which has already prescribed on April 5, 1960 or over 4 months before filing the information on August 11, 1960.

RATIO: Prosecution contends that the medium of an amplifier system, through which defamatory statements imputed to the accused were allegedly made, falls within the purview of the terms writing, printing, lithography, engraving, radio, phonograph, painting, theatrical exhibition, cinematographic exhibition,, or any similar means ( as mentioned in Article 355, which describes the means in which libel is committed) Prosecutions main argument is the use of an amplifier system is a means similar to that of a radio. The SC was not convinced by this argument. The difference can clearly be seen as follows:

Radio: as a means of publication, is the transmission and reception of electromagnetic waves without conducting wires intervening between transmitter and receiver. o Amplifier system: not through electromagnetic waves but through conducting wires intervening between transmitter and the receiver. Moreover, the word radio used in Article 355 should be considered in relation to the other terms it is associated with (writing, printing..)all of which have a common characteristic which is their permanent nature as a means of publication. This explains the logic behind the graver penalty of libel compared to oral defamation. ---(This is the principle of Noscitur a sociis in action but the case never mentioned this term) This goes to show that as opposed to making slanderous statements forming part of a manuscript read by a speaker over the radio which definitely constitutes libel according to past decisions of the SC, the action done the defendant cannot be considered to be of a permanent nature.