G.R. No. 83551 - Albano vs. Reyes

Petitioners Manuel Elizalde, Fred J. Elizalde, and Prudencio R. Europa were the Publisher, Assistant Publisher, and Editor-in-Chief respectively of the Evening News, a newspaper of general circulation.
They were charged with libel following the publication of a news item based on a dispatch furnished by the reputable Philippine News Service.
The news item reported on the testimony of Jaime Jose, a witness in a pending rape case, and repeatedly mentioned Vincent Crisologo, the alleged offended party.

The news article was an accurate and faithful reproduction of the testimony given by Jaime Jose, which involved allegations regarding a rape case and the involvement of Vincent Crisologo.
The excerpt detailed events such as the alleged involvement of Vincent Crisologo with a group of companions, the taxi incident, and subsequent actions after a party, without distorting the substance of the testimony.
The headline “LINK CRISOLOGO SON TO PASAY RAPE CASE” was used to portray the contents of the report objectively without sensationalism.

An information for libel was filed against petitioners by the Provincial Fiscal, Jesus F. Guerrero, dating February 5, 1970.
Petitioners filed a motion to quash on August 14, 1970, invoking their constitutional right to freedom of expression and the free press.
The motion to quash was denied by Respondent Judge Mario J. Gutierrez on December 17, 1970, and the denial was later reaffirmed upon a motion for reconsideration in February-March 1971.

Petitioners based their petition on the constitutional guarantee of free speech and press, citing the free press provision found in both the 1935 and the present Constitution.
The Bustos doctrine was invoked, emphasizing that no libel prosecution should undermine the fundamental right to a free press.
The doctrine of privileged communication – protected both by jurisprudence (notably United States v. Bustos and subsequent decisions like Quisumbing v. Lopez and People v. Andres) and the Revised Penal Code – was central to the petitioners’ defense.

Petitioners sought certiorari and prohibition, arguing that the lower court’s denial of their motion to quash was in direct contravention of constitutional protections.
They demanded that the orders denying their motions be set aside and that further proceedings in the libel case be restrained except for the purpose of dismissing the case.

Whether the denial of the motion to quash by the trial judge amounted to a violation of the petitioners’ constitutional right to freedom of expression and of the press.
Whether the publication of the news item, as a faithful reproduction of a dispatch from a reputable news service, should be protected under the doctrine of privileged communication.

Whether a news report that faithfully reproduces factual judicial testimony, even if it bears a defamatory aspect, constitutes a violation of libel laws.
Whether the invocation of the Bustos doctrine and related jurisprudence should lead to the dismissal of the libel case.

Whether the denial of the constitutional right and the consequent grave abuse of judicial discretion rendered the lower court’s actions jurisdictionally untenable.
Whether the inherent protection in the Revised Penal Code for fair and true reports (privileged communications) applies to this case.