G.R. No. 159813 - Figueroa vs. People

On March 24, 1992, the city prosecutor of Davao, at the instance of Aproniano Rivera, filed an Information for libel under Article 355 in relation to Article 360 of the Revised Penal Code against Tony N. Figueroa and Rogelio J. Flaviano.
The case was docketed and raffled to Branch 17 of the RTC of Davao City as Criminal Case No. 25,957-92.

The Information alleges that on or about April 9, 1991, within the City of Davao, petitioners, in their respective capacities as writer (columnist for the People’s Daily Forum under the column “Footprints”) and publisher-editor of the same publication, conspired and collaborated against Aproniano Rivera.
The publication contained numerous defamatory statements which described Rivera in derogatory terms such as “leech,” “paper tiger,” “non-Visayan pseudobully,” and portrayed him as an individual exercising undue influence over the Bankerohan Public Market.
The article not only commented on Rivera’s alleged misdeeds but also employed venomous language that directly attacked his character, aimed at causing dishonor, discredit, and contempt.

On arraignment, the petitioners entered a plea of “Not Guilty.”
Following a trial on the merits, on June 8, 1993, the RTC found both Figueroa and Flaviano guilty of libel.
The RTC imposed an indeterminate sentence comprising: a minimum penalty equivalent to five months and one day of arresto mayor (as the minimum) and a maximum penalty equivalent to two years, four months, and 31 days of prision correccional.
Additionally, the RTC ordered both accused to pay moral damages amounting to P50,000.00 and attorney’s fees of P10,000.00, jointly and solidarily to the complainant, Aproniano Rivera.

Petitioners pursued an appellate remedy.
The Court of Appeals, in its Decision dated October 11, 2002, affirmed in toto the RTC’s decision.
The appellate court upheld the conviction, the nature of the libelous publication, and the imposition of both the criminal penalties and the award of moral damages and attorney’s fees.

Petitioners elevated the case to the Supreme Court via a petition for review, contesting several aspects of the appellate decision.
Their arguments asserted that the article should be construed as a general commentary on the conditions of the Bankerohan Public Market rather than as a targeted, defamatory attack on Rivera.
They also contended that Rivera, allegedly being a public officer, should have benefited from the protection of privileged communication under Article 354(2) of the Revised Penal Code.
Finally, petitioners challenged the award of moral damages and attorney’s fees.

Whether the publication in the “Footprints” column is libelous or defamatory against Aproniano Rivera.
Whether the article, in its entirety, can be considered merely a general commentary on the state of the Bankerohan Public Market rather than a targeted personal attack.
Whether the exception of privileged communication under Article 354(2) of the Revised Penal Code applies, particularly in light of the contention that Rivera is a public officer.
Whether the imposition of moral damages and attorney’s fees against the petitioners is justified.