Case Digest (G.R. No. 141994) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The petition involves Filipinas Broadcasting Network, Inc. (FBNI) as petitioner and Ago Medical and Educational Center-Bicol Christian College of Medicine (AMEC-BCCM) along with Dean Angelita F. Ago as respondents in G.R. No. 141994, decided January 17, 2005 under the 1987 Constitution. In December 1989, broadcasters Carmelo “Mela” Rima and Hermogenes “Juna” Alegre, hosting the public affairs program “Exposé” on DZRC-AM (owned by FBNI), aired allegations that AMEC-BCCM imposed unfair repeat rules, offered unaccredited courses, charged for subjects without instructors, depended on nonexistent foreign foundations, and served as a “dumping ground” for “immoral and physically misfit” teachers, burdening students with “false regulations.” On February 27, 1990, AMEC-BCCM and Dean Ago filed a libel and damages complaint (Civil Case No. 8236) before the Regional Trial Court of Legazpi City. FBNI, Rima, and Alegre defended on grounds of fair reporting, public duty, and due diligence in e Case Digest (G.R. No. 141994) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Filipinas Broadcasting Network, Inc. (FBNI) operates DZRC-AM and airs the public-affairs radio program “Exposá,” hosted by broadcasters Hermogenes Alegre and Carmelo Rima.
- On December 14–15, 1989, the hosts aired allegations from unnamed students and parents against Ago Medical and Educational Center–Bicol Christian College of Medicine (AMEC-BCCM), including claims of false regulations, unaccredited courses, money-making schemes, substandard faculty, and undue burdens on students.
- Procedural History
- February 27, 1990: AMEC-BCCM and Dean Angelita F. Ago filed a complaint for libel (Civil Case No. 8236) against FBNI, Alegre, and Rima, alleging malicious and defamatory imputations.
- Trial Court (December 14, 1992 Decision): Denied FBNI’s motion to dismiss; found FBNI and Alegre liable for libel per se, Rima exonerated; awarded ₱300,000 moral damages, ₱30,000 attorney’s fees, and costs.
- Court of Appeals (January 4, 1999 Decision; January 26, 2000 Resolution): Affirmed with modification—held FBNI, Alegre, and Rima solidarily liable; denied individual claim of Dean Ago; maintained damages and fees.
- January 17, 2005: Supreme Court docketed FBNI’s petition for review under Rule 45 (G.R. No. 141994).
Issues:
- Whether the broadcasts are libelous.
- Whether AMEC-BCCM is entitled to moral damages.
- Whether the award of attorney’s fees is proper.
- Whether FBNI is solidarily liable with Rima and Alegre for moral damages, attorney’s fees, and costs.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)