SC clears Trixie Cruz-Angeles, colleague over FB posts
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The Supreme Court has dismissed the administrative complaint filed against former press secretary Trixie Cruz-Angeles and fellow lawyer George Ahmed Paglinawan over Facebook posts related to their handling of the case involving former Iglesia ni Cristo (INC) minister Isaias Samson.
The complaint, filed by lawyer Randy Serrano, alleged that Angeles and Paglinawan violated the Code of Professional Responsibility and Accountability.
Paglinawan, for his part, had posted that INC members should not be allowed to leave the country.
In a decision dated July 29, 2024, penned by Associate Justice Amy Lazaro-Javier, the Supreme Court’s Second Division ruled that the complaint failed to prove the statements came from the Facebook accounts of the respondents. It emphasized that screenshots alone are insufficient and require proof of authenticity and due execution — evidence that was not presented.
Even assuming the accounts did belong to Angeles and Paglinawan, the Court held that their statements were protected under the constitutional right to freedom of speech.
“The subject statements were uttered in respondents’ defense of their own client either in a proper judicial proceeding, and were thus absolutely privileged, or in public and in valid criticism of government officials,” the ruling said.
The Court noted that the posts did not appear to constitute prejudicial publication, as there was no indication they influenced judges handling the case. Angeles’ open letter was described as a plea for fairness, and the Court reiterated that criticism of public officials is protected unless proven false, malicious, or unrelated to the officials’ public duties.
“The letter does not appear to be false, much less unrelated to the functions of the foregoing public officials,” the decision read.
While the complaint was dismissed, the Court imposed a fine of P15,000 each on Angeles and Paglinawan for failing to file their answer to the complaint, attend the preliminary conference, and submit a conference brief and position paper as required by the investigating commissioner.
The Court also issued a warning that similar acts of non-compliance in the future would be dealt with more severely.
