REPUBLIC OF THE PHILIPPINES

COURT OF APPEALS
MANILA

CA-G.R. CR NO. ____

[Cyber Libel]

PEOPLE OF THE PHILIPPINES,

Plaintiff-Appellee,

-versus-

_______,
Accused-Appellant.

x-----------------------------------------------------------------x

BRIEF FOR THE ACCUSED-APPELLANT

BRIEF FOR THE ACCUSED-APPELLANT
People of the Philippines v. _________
CA-G.R. CR No. _____
FOR: Cyber Libel

TABLE OF CONTENTS
Pages

I. Assignment of Errors ……………………….………………… 3

II. Statement of the Case ………………..……………………. 4-7
III. Statement of the Facts …………………………………. 7-8
Evidence for the Prosecution …………………………. 7-8
Evidence for the Defense ..…………………….……… 8
IV. Arguments …..……………………………………………………. 9-18
V. Prayer ……………………………………………………………………. 18
VI. Explanation ……………….……………………………………….. 19
AUTHORITIES/LAWS CITED

 People v. Arapok, G.R. No. 134974, December 8, 2000

 Vicario v. Court of Appeals and People, G.R. No. 124491, June 1, 1999
 Uy v. Centro Ceramica Corporation, et al., G.R. No. 174631, October
19, 2011
 Guingguing v. The Honorable Court of Appeals and People, G.R. No.
128959, September 30, 2005
 Disini, et al. v. Secretary of Justice, et al., G.R. No. 203335, February
18, 2014
 United States v. Bustos, 37 Phil. 731 (1918)
 Manila Bulletin Publishing Corporation and Batuigas v. Domingo and
People, G.R. No. 170341, July 5, 2017
 Orfanel v. People, 141 Phil. 519 (1969)
 Vicario v. Court of Appeals and People, G.R. No. 124491, June 1, 1999
 Bautis, Jr. v. People and Atty. Pieraz, G.R. No. 142509, March 24,
2006
 Sazon v. Court of Appeals, G.R. No. 120715, March 29, 1996
 Tulfo v. People and Atty. So, G.R. No. 161032, September 16, 2008
 Section 14 (2), Article III of the 1986 Constitution
 Rule 130 (Sections 48 and 49) and Rule 133 (Section 2) of the Rules
of Court and Sections
 North Carolina Journal of Law & Technology: “Tracking Criminals with
Internet Protocol Addresses: Is Law Enforcement Correctly Identifying
Perpetrators?” By Erin Larson (April 2017)
 Rule 6 (Section 28) and Rule 3 (Sections 9 and 10) of the
Implementing Rules and Regulation of RA 10175
 Article 355 of the Revised Penal Code

APPENDIX “A” Joint Judgment

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BRIEF FOR THE ACCUSED-APPELLANT
People of the Philippines v. _________
CA-G.R. CR No. _____
FOR: Cyber Libel

REPUBLIC OF THE PHILIPPINES

COURT OF APPEALS
MANILA

PEOPLE OF THE PHILIPPINES,

Plaintiff-Appellee,

- versus - CA-G.R. CR NO. _____

_________,
Accused-Appellant.
x-------------------------------x

BRIEF FOR THE ACCUSED-APPELLANT

ASSIGNMENT OF ERRORS

I.

THE TRIAL COURT GRAVELY ERRED IN

FINDING THE ACCUSED-APPELLANT GUILTY
OF THREE (3) COUNTS OF CYBER LIBEL,
DESPITE THE FAILURE OF THE PROSECUTION
TO ESTABLISH THAT HE WAS THE AUTHOR
OF THE SUBJECT FACEBOOK POSTS.

II.

THE TRIAL COURT GRAVELY ERRED IN

FINDING THE ACCUSED-APPELLANT GUILTY
OF THREE (3) COUNTS OF CYBER LIBEL,
DESPITE THE ABSENCE OF ACTUAL MALICE
OF THE SUBJECT FACEBOOK POSTS.

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BRIEF FOR THE ACCUSED-APPELLANT
People of the Philippines v. _________
CA-G.R. CR No. _____
FOR: Cyber Libel

STATEMENT OF THE CASE

1. Accused _________ was charged with three (3)

counts of Cyber Libel under Republic Act No 10175 1 before
the Regional Trial Court of ____, ___, Branch __, the
accusatory portion of the three (3) separate Informations
are hereunder quoted as follows:

CRIMINAL CASE NO. ____

“That on or about xxxx

CONTRARY to Republic Act No. 10175,

otherwise known as the Cybercrime Prevention
Act..”2

CRIMINAL CASE NO. ____

“That on or about xxxx

CONTRARY to Republic Act No. 10175,

otherwise known as the Cybercrime Prevention
Act..”3

CRIMINAL CASE NO.

“That on or about xxxx

CONTRARY to Republic Act No. 10175,

otherwise known as the Cybercrime Prevention
Act..”4

2. On arraignment, the accused pleaded NOT GUILTY to

the offenses charged. After pre-trial, trial on the merits
ensued.

3. On June 28, 2019, the trial court rendered a Joint

Judgment,5 the dispositive portion of which reads:

“WHEREFORE, premises considered, xxxx

1
Cybercrime Prevention Act of 2012
2
Criminal Information, as cited in RTC Joint Judgment, pp. 1-2, a duplicate original
copy of which is hereto attached as Appendix “A”
3
Ibid. pp. 2-3
4
Ibid. p. 3
5
Appendix “A” hereof

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BRIEF FOR THE ACCUSED-APPELLANT
People of the Philippines v. _________
CA-G.R. CR No. _____
FOR: Cyber Libel

He is sentenced to suffer imprisonment from

prision correcccional in its maximum period to prision
mayor in its minimum period and to pay a fine of one
hundred thousand pesos (P100,000.00), without
subsidiary imprisonment in case of insolvency, for
each case.

SO ORDERED.”6

4. Aggrieved, the accused interposed the present

appeal.

STATEMENT OF THE FACTS

EVIDENCE FOR THE PROSECUTION:

5. On February 18, 2016, the Facebook page of a

certain _________ posted in Facebook a statement, “xxxx,
which post referred to private complainant xxxxx, the
incumbent mayor of xxxx.7

5.1. On March 6, 2016, xxxx posted two (2) photos of

________ with text, PUPPET FOR 2016 xxxx” in his
Facebook page.8 This was followed by a post on March 7,
2016, which read, “xxxxx.”9

5.2. The said posts were seen by ______, 10 ______,11

and _______.12

5.3. ______, the Information Technology (IT) Officer of

the Municipality of _______, was able to determine that the
Facebook account _____ and another account of a certain
______ and ________ belong to accused _______. 13

6
Ibid. p. 10
7
TSN, December 22, 2017, pp. 5-10. Also: TSN, August 9, 2018, pp. 5-7. In re:
Screenshot of the Facebook post dated February 18, 2016, Exhibit “D” for the
prosecution.
8
Screenshot of the two (2) Facebook post dated March 6, 2016, Exhibits “C” or the
prosecution
9
Screenshot of the Facebook post dated February 28, 2016, Exhibit “B” for the
prosecution
10
TSNs, February 21, 2019, pp. 4-9; March 7, 2019, pp. 3-5
11
TSNs, November 29, 2018, pp. 5-21; January 17, 2019, pp. 3-8
12
TSN, April 12, 2019, pp. 4-10
13
TSNs, November 29, 2018, pp. 5-21; January 17, 2019, pp. 3-8

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BRIEF FOR THE ACCUSED-APPELLANT
People of the Philippines v. _________
CA-G.R. CR No. _____
FOR: Cyber Libel

Meanwhile, ______ saw _______ once in a computer shop

editing a picture of Mayor ______.14

EVIDENCE FOR THE DEFENSE:

6. Accused XXX vehemently denied the accusation

against him, and maintained that he has only one (1)
Facebook account bearing his name, XXX and under the
Uniform Resource Locator (URL), http://www.Facebook.com/
XXXX, which he maintained since 2010.15

ARGUMENTS

In Support of the First Assigned Error:

I.

THE TRIAL COURT GRAVELY ERRED IN

FINDING THE ACCUSED-APPELLANT GUILTY
OF THREE (3) COUNTS OF CYBER LIBEL,
DESPITE THE FAILURE OF THE PROSECUTION
TO ESTABLISH THAT HE WAS THE AUTHOR
OF THE SUBJECT FACEBOOK POSTS.

7. Before delving on the main consideration in

concluding accused-appellant’s guilt for cyber libel, worth
considering is that nowhere in the assailed Joint Judgment
did the trial court discuss how the evidence of the
prosecution pointed that it was him who made the alleged
libelous Facebook posts.

8. In every criminal prosecution, the correct

identification of the offender is the primal concern for proper
prosecution of a crime.16 In other words, irrespective f
whether the evidence of prosecution fulfilled the elements of
the crime charged, it would not matter if the same pieces of
evidence failed to establish whether the person charged
thereof was the person who committed the same.17

9. In this instance, the prosecution, through Mayor

_____, claimed that the Facebook account that published
14
TSN, April 12, 2019, pp. 4-5. In re: ____ Judicial Affidavit
15
TSN, April 25, 2019, pp. 8-11. In re: XXXs Judicial Affidavit, pp. 1-3
16
People v. Arapok, G.R. No. 134974, December 8, 2000
17
See: Vicario v. Court of Appeals and People, G.R. No. 124491, June 1, 1999

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BRIEF FOR THE ACCUSED-APPELLANT
People of the Philippines v. _________
CA-G.R. CR No. _____
FOR: Cyber Libel

the subject posts under the name of XXXX,18 could be

traced with another Facebook account of a certain XXXX,
which posts similar criticisms against her.19 This account of
XXX bears a similar profile picture to that of the alleged
Facebook account of the accused-appellant with URL
www.facebook.com/XXX.20

9.1 The prosecution would further supplement the

above, through ______, by claiming that the Facebook
account under the name of XXXX was later on changed to
XXXX.

9.1.1. According to _____, the February 12, 1986 date

of birth indicated in the alleged Facebook account of the
accused-appellant (www.facebook.com/xxxx) corresponds
with the numbers (______) found in the URL of XXXX
Facebook account (Facebook.com/XXXX).

9.1.2. Likewise, both accounts of XXX and XXXX

indicate a previous employment at _______l, Incorporated
as ________ med rep….21

10. However, the connection of the alleged XXXX and

the alleged Facebook account of the accused-appellant, was
only made through the testimony of ____. While _____ was
the IT Officer of the Municipality of ______, 22 the
prosecution explicitly presented him as a mere
ordinary witness.23 Since his testimony pertains to matters
requiring special knowledge, skill, experience, or training, 24
the absence of any showing that _____ possesses any of
these qualifications, renders his testimony in identifying the
accused-appellant as the owner of the alleged Facebook
accounts as mere ordinary opinion, which is not admissible
in evidence.25

18
See: Exhibits “B”, “C”, and “D” for the prosecution
19
In re: Annex “C-series” of Mayor Complaint Affidavit, Exhibit “A” for the
prosecution
20
TSNs, August 9, 2018, pp. 5-7; November 15, 2018 [Mayor Re-Direct
Examination], pp. 4-10
21
TSN, November 29, 2018, pp. 15-21
22
Ibid. pp. 5-6
23
TSN, January 17, 2019, p. 3
24
In re: Section 49, Rule 130 of the Rules of Court:
“Section 49. Opinion of expert witness. — The opinion of a witness on
a matter requiring special knowledge, skill, experience or training which he
shown to posses, may be received in evidence.”
25
Section 48, Rule 130 of the Rules of Court:

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BRIEF FOR THE ACCUSED-APPELLANT
People of the Philippines v. _________
CA-G.R. CR No. _____
FOR: Cyber Libel

10.1. The prosecution did not likewise present any

proof (screen-captured image) that would show that there
were indeed similarities in the birthdates and work
employment history in XXXX and the alleged Facebook
account of the accused-appellant.

10.2. Even assuming that there were indeed similarities

in the aforesaid two (2) Facebook accounts, nonetheless, the
creation of Facebook account can be made easily by anyone.
Facebook does not implement a mechanism that the
registration of an account must be that of the person’s
actual name. It does not also implement a verification
process for ordinary accounts, except for known
personalities, i.e.: politicians and celebrities. Consequently,
it is very possible that anyone could create the alleged
Facebook account of XXX with URL:
www.facebook.com.ncidn . Even by coincidence, it is highly
possible that there are former employees of _______-,
Incorporated, other than the accused-appellant, whose
birthdays fall on ______, 1986. Thus, it is unjust to single
out the accused-appellant based on these two (2) details
alone (______, 1986 date of birth and employment history
at _______, Incorporated).

11. Corollary, the accused-appellant strongly disowned

the aforesaid Facebook accounts, and maintained that
he has been using a single Facebook account with
URL http:/www.facebook.com/dkjscbnk since 2010. 26

11.1. Further considering that the accused-appellant is

computer literate, he would not use his personal details and
own picture in the aforesaid Facebook accounts that posted
the alleged libelous posts. As he puts it, “_________.”27

12. Neither the testimony of _____ that he had

allegedly seen the accused-appellant at _____ Computer
Shop editing Mayor ____ picture sufficiently connects the

“Section 48. General rule. — The opinion of witness is not admissible,

except as indicated in the following sections.”

26
TSN, April 25, 2019, pp. 8-11. In re: Judicial Affidavit, pp. 1-3
27
Ibid. p. 26 [Italicization supplied]

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BRIEF FOR THE ACCUSED-APPELLANT
People of the Philippines v. _________
CA-G.R. CR No. _____
FOR: Cyber Libel

accused-appellant as the person who owned the subject

Facebook accounts.28

12.1. Foremost, _____ is employed under a “Job

Order” arrangement with the Local Government Unit (LGU)
of the Municipality of _____.29 As a “Job Order” employee,
______ continued employment depends upon the LGU
concerned, which was headed by Mayor _____, the private
complainant herself. In other words, ______ testimony lacks
the badge of credibility, as he is beholden to his employer.
Consequently, _____ claim that he had seen the accused-
appellant editing Mayor _______ picture could be treated as
a mere self-serving statement that cannot be given any
probative value.30

12.1. Even granting that there was an incident that the

accused-appellant edited ____ picture at ______ Computer
Shop, ______ merely claimed that he saw the accused-
appellant the editing and nothing else. He neither saw the
accused-appellant uploading the edited photo in Facebook
nor did he claimed that the accused-appellant was using
Facebook under the accounts of XXXX, XXXX, XXXX, or the
alleged account of the accused-appellant with URL
www.facebook.com/lsmdl.

13. From the foregoing, it appears that the evidence

presented by the prosecution that allegedly point to the
accused-appellant as the person who published the subject
Facebook posts, were in fact, inconclusive, to support such
premise.

14. Worth mentioning also is that the public prosecutor

and the presiding Honorable Judge both admitted that they
are not familiar with Facebook.31 On this regard, in due
consideration of the presumption of innocence that is
accorded to every accused32 vis-à-vis the requirement of
proof beyond reasonable doubt to find someone guilty of a
crime,33 caution should have been exercised, especially
when the subject of the proceedings is of technical matters
28
TSN, April 12, 2019], p. 10. In re.: Judicial Affidavit, p. 3
29
Judicial Affidavit, p. 2
30
Jhorizaldy Uy v. Centro Ceramica Corporation and/or Ramonita Sy and Milagros
Garcia, G.R. No. 174631, October 19, 2011
31
TSNs, January 17, 2019, p. 4; TSN, October 11, 2018, pp. 9-10
32
Section 14 (2), Article III of the 1986 Constitution
33
Section 2, Rule 133 of the Rules of Court

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BRIEF FOR THE ACCUSED-APPELLANT
People of the Philippines v. _________
CA-G.R. CR No. _____
FOR: Cyber Libel

that mere inference or assumptions should not have been

enough.

14.1. Instead of reliance on the insufficiency of the

aforesaid pieces of evidence, focus should have been placed
on tracing the Internet Protocol (IP) address of the subject
Facebook posts. Being similar to a phone number assigned
to a telephone device, an IP address is assigned to a specific
computer,34 from which the Facebook posts could have
originated. By tracing the IP address, the prosecution would
have competent basis in finding and prosecuting the person
responsible for the subject Facebook posts.

14.2. Moreover, while there are known difficulties in

tracing IP address,35 the trial court and the prosecution has
recourse by seeking the assistance of the Department of
Justice – Office of Cybercrime (DOJ-OOC), the proper
government agency that is tasked, pursuant to Republic Act
No. 10175, as the “competent authority for all requests
for assistance for investigation or proceedings
concerning cybercrimes, facilitate the provisions of
legal or technical advice, preservation and production
of date, collection of evidence, giving legal
information and location of suspects.”36 The help of the
Cybercrime Divisions of the National Bureau of Investigation
(NBI) and Philippine National Police (PNP) could have also
supported the correct prosecution for the alleged cyber libel,
especially when these offices have the power to investigate
all cybercrimes and conduct data recovery and forensic
analysis in pursuance to their mandated in the efficient and
effective law enforcement of the provisions of Republic Act
No. 10175.37 Yet, in this instance, the above available means
were not resorted to.

15. Accordingly, the accused-appellant cannot be held

liable for Cyber Libel, as the evidence of the prosecution
grossly failed to establish that it was him who published the
subject Facebook posts.

34
North Carolina Journal of Law & Technology; “Tracking Criminals with Internet
Protocol Addresses: Is Law Enforcement Correctly Identifying Perpetrators?” By Erin
Larson (April 2017), p. 317
35
Ibid. pp. 317-324
36
Section 28, Rule 6 of the Implementing Rules and Regulation of RA 10175
37
Sections 9 and 10, Rule 3 of the Implementing Rules and Regulation of RA 10175

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BRIEF FOR THE ACCUSED-APPELLANT
People of the Philippines v. _________
CA-G.R. CR No. _____
FOR: Cyber Libel

In Support of the Second Assigned Error:

II.

THE TRIAL COURT GRAVELY ERRED IN

FINDING THE ACCUSED-APPELLANT GUILTY
OF THREE (3) COUNTS OF CYBER LIBEL,
DESPITE THE ABSENCE OF ACTUAL MALICE
OF THE SUBJECT FACEBOOK POSTS.

16. With respect to the conclusion that the the

elements of Cyber Libel were established in ruling the
accused-appellant’s guilt, the trial court held in this wise:

“In the case at bar, all the elements to

constitute libel are all present.

The elements of Libel are: (a) imputation of

a discreditable act or condition to another; (b)
publication of the imputation; (c) identity of the
person defamed; and (d) existence of malice.

Verily, there is an imputation of discreditable

act or condition to another. In the cases at bar, the
following imputations of discreditable act or
condition against the private complainant are the
following:

XXXX

In the cited postings in the Facebook, the

private complainant is portrayed as a crook and
corrupt public official, a prostitute and a puppet.
They are words tending to degrade, attack and
defamed (sic) the private complainant.”38
[Emphases in the original]

17. The accused-appellant respectfully begs to disagree.

18. Section 4 (c)(4) of Republic Act No. 10175 defines the

cyber offense of Libel as, “[t]he unlawful or prohibited acts of
libel as defined in Article 355 of the Revised Penal Code, as
38
RTC Joint Judgment, pp. 8-9, Appendix “A” hereof

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People of the Philippines v. _________
CA-G.R. CR No. _____
FOR: Cyber Libel

amended, committed through a computer system or any other

similar means which may be devised in the future.”

18.1. Corollarily, the Revised Penal Code defines Libel as

the “public and malicious imputation of a crime, or of a vice or
defect, real or imaginary, or any act, omission, condition, status,
or circumstances tending to cause the dishonor, discredit, or
contempt of a natural or juridical person, or to blacken the
memory of one who is dead.”39

18.2. With the foregoing, the elements of Cyber Libel are as

follows: “(a) imputation of a discreditable act or condition to
another; (b) publication of the imputation; (c) identity of the
person defamed; and (d) existence of malice”,40 and (e) the
publication was made through computer system or any other
similar means.

19. In this case, the prosecution failed to establish the

existence of actual malice due to the unique consideration that
herein private complainant, was the elected Mayor of the
Municipality ______.41

19.1. Since the private complainant is public official, worth

considering is the case of Disini, et al. v. Secretary of Justice, et
al..42 In the said case, the Supreme Court held that since libel
mainly targets to prosecute private persons, the “laws imply a
stricter standard of ‘malice’ to convict the author of a
defamatory statement where the offended party is a public
figure. Society’s interest and the maintenance of good
government demand a full discussion of public affairs.” 43

19.2. In connection thereto, when it has been

recognized that there should be a complete liberty to
comment on the conduct of public officials in the interest of
society and the maintenance of good government, 44 the
Supreme Court held in Manila Bulletin Publishing Corporation
and Batuigas v. Domingo and People:45

“xxx when confronted with libel cases

involving publications which deal with public
39
Article 353 of the Revised Penal Code
40
Guingguing v. The Honorable Court of Appeals and People, G.R. No. 128959,
September 30, 2005 [Emphasis supplied]
41
TSN, August 9, 2018, 7-8
42
G.R. No. 203335, February 18, 2014
43
Ibid
44
United States v. Bustos, 37 Phil. 731 (1918)
45
G.R. No. 170341, July 5, 2017

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BRIEF FOR THE ACCUSED-APPELLANT
People of the Philippines v. _________
CA-G.R. CR No. _____
FOR: Cyber Libel

officials and the discharge of their official

functions, this Court is not confined within the
wordings of the libel statute; rather, the case
should likewise be examined under the
constitutional precept of freedom of the press. But
if the utterances are false, malicious, or
unrelated to a public officer's performance of
his duties or irrelevant to matters of public
interest involving public figures, the same
may give rise to criminal and civil liability. In
contrast, where the subject of the libelous article is
a private individual, malice need not be proved by
the plaintiff. The law explicitly presumes its
existence (malice in law) from the defamatory
character of the assailed statement.” [Emphasis
and underscoring supplied]

19.2.1. Thus, if the comment made against a public

official pertains to his/her function or performance, even if
the statements contain defamatory imputations, the same
are deemed qualifiedly privileged communication.46

9.2.2. As a qualifiedly privileged communication, malice

is not presumed by the fact of its publication; rather, the
prosecution still bears the burden of proving the existence of
actual malice or malice in fact.47

19.3. To establish malice, Vicario v. Court of Appeals and

People48 laid that the “ill will must be personal. So if the
ill will is engendered by one's sense of justice or other
legitimate or plausible motive, such feeling negatives
actual malice.”49

20. In this instance, the statements found in the alleged

libelous Facebook posts50 pertain to criticism against ______
performance as the incumbent Mayor of the Municipality ______
and an expression of opposition against the latter’s plan to run
for re-election. With the aforesaid motivations, it cannot be said
that the person who published the said Facebook posts has
personal ill-will against _______ for the element of malice to
arise. At most, these Facebook posts are only but an expression
of dissatisfaction on Mayor _______’s administration.
46
Orfanel v. People, 141 Phil. 519 (1969)
47
Ibid
48
G.R. No. 124491, June 1, 1999
49
Ibid [Emphasis supplied]
50
See: Supra. Note 38

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BRIEF FOR THE ACCUSED-APPELLANT
People of the Philippines v. _________
CA-G.R. CR No. _____
FOR: Cyber Libel

21. Accordingly, malice cannot be attributed to the person

who made the Facebook posts, even if it was the accused-
appellant, since the subject matter of the aforesaid posts
pertains to the public position and function of the private
complainant as Mayor of the Municipality of _____. In the
absence of malice, no conviction for the crime of libel can be had.

22. Notwithstanding the above disquisition, the accused-

appellant most respectfully submits that while Article 355 of the
Revised Penal Code, in connection with Section 4(c)(4) of
Republic Act No. 10175, gives the trial court a liberty to impose a
single or conjunctive penalty of imprisonment and a fine, 51
however, considering that this is the first time the accused-
appellant is accused of a crime, and the Facebook posts that are
being attributed to him were in fact, mere criticism against Mayor
_________ administration, a penalty of fine only should have
been imposed. This is consistent with Bautis, Jr. v. People and
Atty. Pieraz,52 where the Supreme Court declared that, ”the State
is concerned not only in the imperative necessity of protecting
the social organization against the criminal acts of destructive
individuals but also in redeeming the individual for economic
usefulness and other social ends.” The deletion of penalty of
imprisonment were likewise applied in Sazon v. Court of
Appeals53 and Tulfo v. People and Atty. So.54

23. In fine, the accused-appellant cannot be held guilty for

Cyber Libel, since the the evidence presented by the prosecution
failed to concretely establish that it was him who published the
alleged Facebook posts, and that their publication was with
actual malice borne out of personal ill-will. Hence, the accused-
appellant must be acquitted of the offense charged.

PRAYER

WHEREFORE, premises considered, it is most

respectfully prayed of this Honorable Court that the Joint
Judgment of the Regional Trial Court of ______, Branch ___,
dated ______, 2019 be REVERSED and SET ASIDE, and a
new one be rendered ACQUITTING the accused-appellant of
Cyber Libel under Republic Act No. 10175.

Quezon City for Manila,

51
Bautis, Jr. v. People and Atty. Pieraz, G.R. No. 142509, March 24, 2006
52
Ibid
53
G.R. No. 120715, March 29, 1996
54
G.R. No. 161032, September 16, 2008

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BRIEF FOR THE ACCUSED-APPELLANT
People of the Philippines v. _________
CA-G.R. CR No. _____
FOR: Cyber Libel

date.

EXPLANATION
(Pursuant to Section 11, Rule 13
of the 1997 New Rules of Civil Procedure)

The foregoing Brief for the Accused-Appellant is being served by

registered mail, personal service not being practicable due to the
limited number of messengers in the undersigned’s office.

Copy furnished:

OFFICE OF THE SOLICITOR GENERAL

134 Amorsolo Street Reg. Receipt No. _______
1229 Legazpi Village, Makati City Date: ________________

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