On Aug. 18, 1995, the wife of Atty. Jose J. Pieraz retrieved a letter from their mailbox addressed to her husband. The letter was open, not contained in an envelope, and Atty. Pieraz' wife put it on her husband's desk. On that same day, Atty. Pieraz came upon the letter and made out its content.

The letter reads in part:

"This has reference to your lousy but inutile threatening letter dated August 18, 1995, addressed to our client; using carabao English.

"May we remind you that any attempt on your part to continue harassing the person of Mrs. Teresita Quingco of No.1582 Mango St., Bgy. Manggahan, Pasig City, Metro Manila - undersigned much to his regrets shall be constrained/compelled to file the necessary complaint for disbarment against you.

"You may proceed then with your stupidity and suffer the full consequence of the law.

Needless for you to cite specific provisions of the Revised Penal Code, as the same is irrelevant to present case. As a matter of fact, the same shall be used by no other than the person of Mrs. Quingco in filing administrative charge against you and all persons behind these nefarious activities."

Yours in Satan name,

(Sgd.) JOSE ALEMANIA BUATIS, JR.

Copy furnished:

All Concerned

Not personally knowing who the sender was, Atty. Pieraz responded and sent a communication by registered mail to Mr. Buatis, Jr. In reply, Mr. Buatis, Jr. dispatched a second letter dated Aug. 24, 1995 to Atty. Pieraz.

Reacting to the insulting words used by Mr. Buatis Jr. particularly: "Satan, senile, stupid, carabao English, Atty. Pieraz filed a complaint for libel against Mr. Buatis, Jr. The subject letter came to the knowledge of Atty. Pieraz' wife and children and they all chided him telling him: "Ginagawa ka lang gago dit."

Aside from the monetary expenses he incurred as a result of filing the instant case, Atty. Pieraz' frail health was affected and aggravated the letter of Mr. Buatis Jr.

Mr. Buatis Jr. denied the charge against him. He said it was at the behest of the president of the organization, "Nagkakaisang Samahan ng mga Taga Manggahan" (NATASMA), and of a member, Teresita Quingco, that he had dictated to one of his secretaries, a comment to the letter of Atty. Pieraz in the second week of August 1995.

The Regional Trial Court (RTC) found Mr. Buatis guilty of the crime of libel and was sentenced to an indeterminate penalty of imprisonment of 4 months and 1 day, as minimum to 2 years, 11 months and 10 days as maximum, and to indemnify the offended party in the amount of P20,000 as compensatory damages, P10,000 as moral damages, and another P10,000 as exemplary damages, to suffer all the accessory penalties as provided for by law, and to pay the costs.

Subsequently, Mr. Buatis, Jr. appealed the RTC decision to the Court of Appeals (CA). On Jan. 18, 2000, the CA affirmed the decision of the RTC.

Mr. Buatis, Jr. filed a motion for reconsideration of the CA ruling. On March 13, 2000, the CA denied the motion for reconsideration.

Mr. Buatis Jr. appealed to the Supreme Court (SC) by way of a petition for review on certiorari.

The SC affirmed the CA ruling. But the award for compensatory damages was deleted.
The words used in the letter dated August 18, 1995 sent by Mr. Buatis Jr. to Atty.

Pieraz is defamatory. In using words such as "lousy," "inutile," "carabao English," "stupidity," and "satan," the letter as it was written, casts aspersion on the character, integrity and reputation of Atty. Pieraz as a lawyer which exposed him to ridicule. (485 SCRA Buatis Jr. vs. People 275-293 (2006).

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