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Daquer, Jr. vs. People

CLAUDIO DAQUER, JR., PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

G.R. No. 206015 | 2021-06-30

DECISION
 
LEONEN, J.:
 
In cases of criminal libel where public figures, particularly public officers, are private complainants, actual malice—knowledge that the defamatory statement was false or with reckless disregard as to its falsity—must be proved. It is the burden of the prosecution to prove actual malice, and not the defense's burden to disprove.

This Court resolves a Petition for Review on Certiorari[1] under Rule 45 of the Rules of Court, assailing the Court of Appeals Decision[2] and Resolution[3] affirming the Regional Trial Court Decision,[4] which found Claudio Daquer, Jr. (Daquer)...