Facts:

The case involves Catalino P. Arafiles as the petitioner and Philippine Journalists, Inc., Romy Morales, Max Buan, Jr., and Manuel C. Villareal, Jr. as respondents. The events leading to the case began in the early hours of April 14, 1987, when Emelita Despuig, an employee of the National Institute of Atmospheric Sciences (NIAS), filed a complaint against Arafiles, who was a director at NIAS, for forcible abduction and rape. This complaint was lodged at the Western Police District (WPD) Headquarters in Manila, where Morales, a reporter for People’s Journal Tonight, was present. Emelita provided a sworn statement detailing her allegations against Arafiles, claiming that he had abducted and raped her on March 14, 1987, and attempted to do so again on April 13, 1987. Following her statement, Morales interviewed Emelita and subsequently published an article in People’s Journal Tonight, which sensationalized the allegations against Arafiles, depicting him as a "sex-crazed sta...

Facts:

Incident and Police Report

• On April 14, 1987, Emelita Despuig, an employee of the National Institute of Atmospheric Sciences (NIAS), filed a complaint at the Western Police District (WPD) Headquarters against Catalino P. Arafiles, a NIAS director, for forcible abduction with rape and attempted rape.
• Emelita executed a sworn statement detailing the incidents, alleging that on March 14, 1987, Arafiles forcibly abducted and raped her, and on April 13, 1987, attempted to rape her again.
• Patrolman Benito Chio recorded the complaint in the Police Blotter, which was reviewed by Romy Morales, a reporter for People’s Journal Tonight.

Publication of the News Item

• Morales interviewed Emelita and wrote a report based on her sworn statement and the Police Blotter entry. The report was published on April 14, 1987, under the headline: “GOV’T EXEC RAPES COED.”
• The article described Emelita’s allegations in detail, including the use of chloroform, the abduction, and the rape incidents. It also mentioned Arafiles’ alleged threats to harm Emelita and her family if she reported the incidents.

Petitioner’s Complaint

• On April 13, 1988, Arafiles filed a complaint for damages against Philippine Journalists, Inc., Romy Morales, Max Buan, Jr. (editor), and Manuel C. Villareal, Jr. (president of Philippine Journalists, Inc.), alleging that the news item was malicious, sensationalized, and defamatory.
• Arafiles claimed that the publication damaged his reputation, caused public contempt, and hindered his promotion to Deputy Administrator of PAGASA.

Trial Court Decision

• The Regional Trial Court (RTC) ruled in favor of Arafiles, awarding him nominal, exemplary, and moral damages, as well as attorney’s fees, totaling P2,100,000.00.
• The RTC found that the article lacked qualifying terms like “allegedly” or “reportedly,” making it appear as if the allegations were proven facts.

Court of Appeals Decision

• The Court of Appeals (CA) reversed the RTC decision, ruling that the publication was not attended by malice and was based on a police blotter entry and an interview with Emelita.
• The CA held that the news item fell under the doctrine of fair comment and that Arafiles failed to prove that the respondents acted with malicious intent.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Doctrine of Fair Comment: The news item falls under the doctrine of fair comment, which protects publications made in good faith and based on established facts, even if the opinions expressed are mistaken.
2. Freedom of the Press: Newspapers enjoy discretion in presenting news items, provided they act in good faith and with reasonable care. The respondents’ publication, while sensational, did not violate Arafiles’ rights or abuse press freedom.
3. Burden of Proof: In civil actions for damages under Article 33 of the Civil Code, the plaintiff must prove the defendant’s liability by preponderance of evidence. Arafiles failed to meet this burden.
4. Malice Not Proven: The Court found no evidence of malice or intent to harm Arafiles. The publication was based on a police blotter entry and an interview, and the respondents acted within the bounds of journalistic discretion.

Conclusion:

The Supreme Court upheld the Court of Appeals’ decision, ruling that the respondents were not liable for damages. The publication, while sensational, was based on credible sources and did not constitute defamation. The petition was denied.