Case Digest (G.R. No. 128959) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On September 30, 2005, the Supreme Court, Second Division, decided G.R. No. 128959 entitled Ciriaco ‘Boy’ Guingguing v. The Honorable Court of Appeals and The People of the Philippines. The case originated from Criminal Case No. CBU-26582 filed before the Regional Trial Court (RTC), Branch 7 of Cebu City by broadcast journalist Cirse ‘Choy’ Torralba against Segundo Lim and Ciriaco ‘Boy’ Guingguing for libel under Articles 353 and 355 of the Revised Penal Code. On October 13, 1991, Lim paid for a one-page advertisement in the Sunday Post, edited and published by Guingguing, which reprinted criminal blotter entries and photographs of Torralba’s arrests for malicious mischief, estafa and serious physical injuries, suggesting pending warrants. Torralba alleged that those cases had long been settled or dismissed and that the publication was meant to degrade him and impair his reputation as a radio commentator whose programs aired across the Visayas and Mindanao. The RTC found both ac Case Digest (G.R. No. 128959) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Ciriaco “Boy” Guingguing (petitioner) and Segundo Lim were sued by broadcast journalist Cirse “Choy” Torralba for criminal libel under RPC Arts. 353, 354, and 355.
- Torralba hosted two widely aired radio programs on DYLA and DYFX, reaching listeners in the Visayas and Mindanao.
- Publication and Content
- On October 13, 1991, Lim paid for a one-page advertisement in the Sunday Post, a weekly newspaper edited and published by petitioner, circulated in Bohol, the Visayas, and Mindanao.
- The advertisement reproduced:
- Records of three criminal cases filed against Torralba (malicious mischief, estafa, serious physical injuries), indicating their status (pending, provisionally dismissed).
- Photographs—first with the subject’s face blotted out, then clearly showing Torralba—depicting his arrest and captioned to imply misconduct.
- A request to Torralba to explain the disposition of these cases and to confirm his identity in the arrest photos.
- Procedural History
- RTC, Branch 7, Cebu City (May 17, 1994) convicted Lim and petitioner of libel, sentenced them to prision correccional, awarded P50,000 damages, and denied their self-defense plea.
- Court of Appeals (July 29 and October 3, 1996) affirmed with modification, reducing the penalty but rejecting self-defense and freedom-of-press claims.
- Guingguing alone filed a Rule 45 petition before the Supreme Court, as Lim’s conviction had become final.
Issues:
- Does the publication of the paid newspaper advertisement constitute criminal libel under the Revised Penal Code?
- Can the petitioners invoke the constitutional guarantee of freedom of speech and of the press as a defense to the libel charge?
- Is Torralba a public figure obliging the prosecution to prove “actual malice,” and were the statements in fact false or published with knowledge of falsity or reckless disregard for the truth?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)