G.R. No. 150256 - Arafiles vs. Philippine Journalists, Inc.

Petitioner Catalino P. Arafiles, a director of the National Institute of Atmospheric Sciences (NIAS) under PAGASA, filed a complaint for damages against the respondents, namely Philippine Journalists, Inc., Romy Morales, Max Buan, Jr., and Manuel C. Villareal, Jr.

The complaint arose as a result of a news report which, according to the petitioner, sensationalized and fabricated details regarding allegations of rape, abduction, and attempted rape attributed to him.

On April 14, 1987, at about 2 a.m., Emelita Despuig, an employee of NIAS, filed a complaint at the Western Police District (WPD) Headquarters.

Emelita accused petitioner Arafiles of forcible abduction with rape and forcible abduction with attempted rape, alleging that on March 14, 1987 and again the following night, the acts were committed against her, all witnessed or recorded in part by respondent Morales, a reporter for Peopleas Journal Tonight.

A detailed sworn statement was given by Emelita before Patrolman Benito Chio, in the presence of Morales, describing in graphic and sequential detail the alleged abduction, coercion, and sexual assault performed by Arafiles.

After interviewing Emelita and reviewing the police blotter entry made by Patrolman Chio, respondent Morales prepared an account of the incident.

The resulting news item, published on Peopleas Journal Tonight on April 14, 1987, included a headline (“GOVaT EXEC RAPES COED”) and body text that couched the allegations as factual assertions, despite being largely based on public police records and the victim’s account.

The narrative, while sensational in its language, incorporated details from Emelita’s sworn statement and the official police blotter entry, but it presented the information in a manner that suggested confirmation of dramatic allegations against petitioner Arafiles.

Petitioner subsequently filed a complaint for damages in the Regional Trial Court (RTC) of Quezon City, alleging that the news item cast aspersions on his character, tarnished his reputation, and resulted in personal and professional harm, including derailing his promotion.

The RTC ruled in favor of petitioner Arafiles, awarding nominal, exemplary, and moral damages along with attorney’s fees and costs.

Respondents then filed a motion for reconsideration, which was denied, prompting their appeal to the Court of Appeals (CA).

The CA reversed the RTC’s decision by stating that the news report, grounded on the police blotter and a personal interview with Emelita, enjoyed the privilege of freedom of the press as long as it was not made with malice.

Petitioner's subsequent motion for reconsideration of the CA decision was denied, leading to the filing of the current petition for review before the Supreme Court.

Whether the Court of Appeals erred in holding that the publication of the news item was not attended with malice, thereby freeing the respondents from liability for the alleged damages.
Whether the sensationalized presentation of allegations in the news report, despite its basis in police records and a victim’s testimony, can be deemed as malicious or as an abuse of press freedom.
Whether the petitioner’s complaint for damages, based on libel under Article 33 of the Civil Code, was liable to succeed when weighed against the protected exercise of freedom of the press in reporting matters of public interest.