Facts:

• Rosauro Almario published defamatory articles about Guillermo Guevara, the Fiscal of the City of Manila.
• The articles were published in La Vanguardia, a daily newspaper in Manila, on March 3 and March 16, 1927.
• The articles criticized Guevara as a public official and attacked his personal integrity.
• Almario pleaded guilty in a criminal action and was sentenced to pay a fine of P400.
• Guevara filed a civil case to recover damages amounting to P100,000.
• Almario claimed that the articles were true and had justifiable motives.

Issue:

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Ruling:

• The court ruled in favor of Guevara and ordered Almario to pay him P1,000 in damages.
• The other defendants, La Vanguardia Incorporated, Marciano Almari...(Unlock)

Ratio:

• The court admitted evidence from the previous criminal case where Almario pleaded guilty to the libelous articles.
• However, a judgment of conviction in a criminal proceeding cannot be admitted as evidence in a civil action.
• There was no sufficient reason presented as to why the original witnesses in the criminal case could not be produced in the civil case.
• The fact of Almario's conviction could be proved in the civil action.
• In determining the amount of damages, the court considered:
  • Special damages were not proven.
  • Nominal damages are not generally recognized under civil law.
  • Punitive damages had already been imposed in the criminal action.
• The court awarded Guevara P1,000 as general damages, which arise from legal inferences and need not be pro...continue reading