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Putang Ina Principle


The words "putang ina mo" are common 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 (Reyes vs. People, G.R. Nos. L-21528 and L-21529, March
28, 1969). Thus, the statement “Putang ina mo! Limang daan na ba ito?” made
by the accused cannot be considered as slanderous (Martinez vs. People, G.R. No.
198694, February 13, 2013).

Same as words “fuck”, “son of a bitch” or “motherfucker” in America, “hijo de

puta” in Spain and, “bakero” in Japan, “putang ina” is an expletive expression of
Filipinos, which cannot be considered as a source of criminality on all occasions.
It is not an exaggeration to state that numerosity of Filipinos including the
President are expressing the words “putang ina” multiple times on a daily basis.
Obviously, the minds of these Filipinos, who are instinctively using “putang ina”
as part of their language, are not criminal.

However, if the statement “putang ina” is made not only to express hate or
displeasure but also to defame or insult a person in front of several persons, the
crime of simple slander is committed. For example, an accused, who shouted
"putang ina mo Atty. Escolango. Napakawalanghiya mo!" at the complainant, a
lawyer and candidate for vice-mayor, while the latter was conversing with his
political leaders, is liable for simple slander (Pader vs. People, G.R. No. 139157,
February 8, 2000). An accused, who pointed a dirty finger at vice-mayor in the
municipal hall in front of several persons, is liable for simple slander by deed. A
dirty finger ordinarily connotes the phrase "fuck you," which is similar to the
expression "puta" or "putang ina mo," in local parlance. While such act is an
expression of anger and displeasure, it cast dishonor, discredit or contempt upon
complainant since she is a lady and a vice-mayor, and it was made in front of
several persons (People vs. Villanueva, G.R. No. 160351, April 10, 2006).
But if the words “putang ina” is accompanied with the statement “papatayin
kita”, the crime committed is threat. The utterance “putang ina,” is not a
separate crime of slander since it is merely made to make the threat more
emphatic. In sum, the statement “putang ina” shall be considered as part of the
threat (Reyes vs. People, supra). If the statement "putang ina, bullshit" is
accompanied with banging a chair and choking of the complainant, who is a lady,
the crime committed is serious slander by deed. The cuss words shall be
considered as part of the crime of serious slander by deed (Mari v. Court of
Appeals, G.R. No. 127694, May 31, 2000).