See - https://www.projectjurisprudence.com/2018/07/the-putang-ina-principle-reyes-vs-people-l-21528-defamation.html?fbclid=IwAR0EhYwhsTMI2DwHLItyNmGYB8EMH3J-vcY4yDIEuvAzMe5NhE1h7BCd9Qg&m=1
"x x x.
Have you heard of the Putang Ina Principle? According to law students, this page is from a book authored by Judge Marlo Bermejo Campanilla. He cited Reyes vs. People (G.R. Nos. L-21528 and L-21529; March 28, 1969)
SUPREME COURT: The charge of oral defamation stemmed from the utterance of the words, "Agustin, putang ina mo". This is a common enough expression in the dialect that is often employed, not really to slander but rather to express anger or displeasure. It is seldom, if ever, taken in its literal sense by the hearer, that is, as a reflection on the virtues of a mother. In the instant case, it should be viewed as part of the threats voiced by appellant against Agustin Hallare, evidently to make the same more emphatic. In the case of Yebra, G.R. No. L-14348, Sept. 30, 1960, this Court said:
The letter containing the allegedly libelous remarks is more threatening than libelous and the intent to threaten is the principal aim and object to the letter. The libelous remarks contained in the letter, if so they be considered, are merely preparatory remarks culminating in the final threat. In other words, the libelous remarks express the beat of passion which engulfs the writer of the letter, which heat of passion in the latter part of the letter culminates into a threat. This is the more important and serious offense committed by the accused. Under the circumstances the Court believes, after the study of the whole letter, that the offense committed therein is clearly and principally that of threats and that the statements therein derogatory to the person named do not constitute an independent crime of libel, for which the writer maybe prosecuted separately from the threats and which should be considered as part of the more important offense of threats.
x x x."
