BUATIS vs. PEOPLE485 SCRA 275

Facts: In this case, a letter was sent to Atty. Jose J. Pieraz not personally knowing who the sender was. Nevertheless, he responded and sent a communication by registered mail to said Buatis, Jr., accused appellant. Reacting to the insulting words used by Buatis particularly: Satan, senile, stupid, english carabao, Atty. Pieraz filed a complaint for libel against accused-appellant.The defense forwarded by Buatis Jr. Was denial. According to him, it was at the behest of the president of the organization Nagkakaisang Samahan Ng Mga Taga Manggahan and of a member, Teresita Quingco, that he dictated to one of his secretaries, a comment to the letter of private-complainant. Buatis Jr. could not recall whether he had signed that letter-comment or if it was even addressed to Atty. Pieraz. Neither could he remember if he had made and sent another letter to Atty. Peiraz.Issue: Whether or not petitioner is guilty of the crime of libel?Ruling: For an imputation to be libellous, the following requisites must concur: (a) it must be defamatory; (b) it must be malicious; (c) it must be given publicity; and (d) the victim must be identifiable.(C) and (D) have been duly established by the prosecution. There is publication in this case. Petitioners subject-letter itself states that the same was copy furnished to all concerned. A written letter containing libellous matter cannot be classified as privileged when it is published and circulated among the public. Petitioner admitted that he dictated the letter to one of her secretaries who typed the same and made a print out of the computer. His lack of selectivity is indicative of malice and anathema to his claim of privilege communication. Such publication had already created upon the minds of the readers a circumstance which brought discredit and shame to respondents reputation.SC affirmed the decision of the CA, rendering the accused Buatis Jr. Guilty of the crime of libel.