Title
Source: Supreme Court
Guy vs. Tulfo
Case
G.R. No. 213023
Decision Date
Apr 10, 2019
A libel case involving a businessman's reputation damaged by unverified allegations in a newspaper article, resulting in moral and exemplary damages.

Case Digest (G.R. No. 213023)
Expanded Legal Reasoning Model

Facts:

  • Publication of Libelous Article
    • On March 24, 2004, Raffy T. Tulfo published in Abante Tonite an article entitled “Malinis ba talaga o naglilinis-linisan lang (Sino si Finance Sec. Juanita Amatong?)” alleging that Michael C. Guy, under RIPS investigation for tax fraud, sought help from former Finance Secretary Juanita Amatong.
    • The article claimed, based on an unnamed “A-1 source,” that Secretary Amatong instructed the head of the Revenue Integrity Protection Service (RIPS) to surrender all documents on Guy’s case to her office.
  • Criminal Prosecution and Trial Court Judgment
    • Guy filed a Complaint-Affidavit for libel against Tulfo and seven representatives of Monica Publishing Corporation (Macasaet et al.) before the Makati City Prosecutor.
    • After a preliminary investigation, an Amended Information charged them with libel; at arraignment, a not-guilty plea was entered by court order.
    • On February 24, 2010, the RTC convicted Tulfo and Macasaet et al., sentencing each to a ₱6,000 fine (with subsidiary imprisonment) and joint and several liability for ₱5,000,000 actual damages, ₱5,000,000 moral damages, and ₱211,200 attorney’s fees.
  • Appeals and Supreme Court Petition
    • On August 30, 2013, the Court of Appeals affirmed the conviction, reduced moral damages to ₱500,000, and awarded exemplary damages of ₱500,000.
    • In its June 13, 2014 Amended Decision, the CA deleted the awards of actual and exemplary damages, affirming only ₱500,000 moral damages and ₱211,200 attorney’s fees.
    • On August 26, 2014, Guy filed a Petition for Review on Certiorari before the Supreme Court seeking reinstatement of the ₱5,000,000 actual damages, ₱5,000,000 moral damages, and exemplary damages. Respondents filed comments (Tulfo) or manifested no opposition (Macasaet et al.), and Guy filed a reply.

Issues:

  • Whether there is sufficient factual basis to award actual damages.
  • Whether petitioner Michael C. Guy is entitled to moral damages.
  • Whether petitioner is entitled to exemplary damages.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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