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Us V Bustos G.R. No. L-12592 March 8, 1918 Petitioner: THE UNITED STATES Respondent: FELIPE BUSTOS ET AL. Doctrine

The US v Bustos case centered around a petition signed by 34 citizens alleging malfeasance by a justice of the peace in Pampanga, Philippines. The petition contained specific accusations against the justice of the peace. In response, the justice of the peace alleged the petition was libelous. The court ruled that the petition was protected under freedom of speech and freedom of the press. It determined criticism of public officials and judicial conduct is allowed, as the administration of law is a matter of public concern. The court acquitted the defendants, finding citizens should be commended for efforts to improve public service through petitions rather than punished.

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4K views1 page

Us V Bustos G.R. No. L-12592 March 8, 1918 Petitioner: THE UNITED STATES Respondent: FELIPE BUSTOS ET AL. Doctrine

The US v Bustos case centered around a petition signed by 34 citizens alleging malfeasance by a justice of the peace in Pampanga, Philippines. The petition contained specific accusations against the justice of the peace. In response, the justice of the peace alleged the petition was libelous. The court ruled that the petition was protected under freedom of speech and freedom of the press. It determined criticism of public officials and judicial conduct is allowed, as the administration of law is a matter of public concern. The court acquitted the defendants, finding citizens should be commended for efforts to improve public service through petitions rather than punished.

Uploaded by

Leslie Tan
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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US v BUSTOS

G.R. No. L-12592 March 8, 1918


Petitioner: THE UNITED STATES
Respondent: FELIPE BUSTOS ET AL.

DOCTRINE
Freedom of Speech

FACTS

In 1915, numerous citizens of Pampanga assembled, and prepared and signed a petition to the Executive Secretary (privileged
communication) through the law office of Crossfield and O'Brien, and five individuals signed affidavits, charging Roman Punsalan,
justice of the peace of Macabebe and Masantol, Pampanga, with malfeasance in office and asking for his removal.

· The petition transmitted by these attorneys was signed by thirty-four citizens


· The specific charges:
- Francisca Polintan asked for money and kept her in the house for four days as a servant and took from her two chickens and
twelve "gandus;"
- Valentin Sunga asked for P50
- Leoncio Quiambao: Punsalan gave him P30 and his complaint was shelved.

· Now, Punsalan alleged that accused published a writing which was false, scandalous, malicious, defamatory, and libelous
against him.

ISSUE/S
WON accused is entitled to constitutional protection by virtue of his right to free speech and free press

PROVISIONS

- “the guaranties of a free speech and a free press include the right to criticize judicial conduct. The administration of the law is a
matter of vital public concern. Whether the law is wisely or badly enforced is, therefore, a fit subject for proper comment. If the
people cannot criticize a justice of the peace or a judge the same as any other public officer, public opinion will be effectively
muzzled. Attempted terrorization of public opinion on the part of the judiciary would be tyranny of the basest sort.”
RULING & RATIO

1. YES
- The guaranties of a free speech and a free press include the right to criticize judicial conduct. The administration of the law is a
matter of vital public concern. Whether the law is wisely or badly enforced is, therefore, a fit subject for proper comment. If the
people cannot criticize a justice of the peace or a judge the same as any other public officer, public opinion will be effectively
suppressed. It is a duty which every one owes to society or to the State to assist in the investigation of any alleged
misconduct. It is further the duty of all who know of any official dereliction on the part of a magistrate or the wrongful act of any
public officer to bring the facts to the notice of those whose duty it is to inquire into and punish them.

DISPOSITION

- We find the defendants and appellants entitled to the protection of the rules concerning qualified priviledge, growing out of
constitutional guaranties in our bill of rights. Instead of punishing citizens for an honest endeavor to improve pulic service, we
should rather commend them for their good citizenship. The defendants and appellants are acquitted with the costs de officio.
So ordered.

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