Case Digest (G.R. No. 213023) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Michael C. Guy vs. Raffy Tulfo, et al. (G.R. No. 213023, April 10, 2019), petitioner Michael C. Guy filed a libel complaint in Makati City after an article by respondent Raffy T. Tulfo appeared in Abante Tonite on March 24, 2004. The article claimed that Guy, under investigation by the Revenue Integrity Protection Service (RIPS) of the Department of Finance for alleged tax fraud, had gone to then-Secretary Juanita Amatong’s house to seek intervention and that she directed RIPS to surrender its documents on Guy’s case. Guy charged Tulfo and the newspaper’s representatives (Allen Macasaet, Nicolas V. Quijano, Jr., Janet Bay, Jesus P. Galang, Randy Hagos, Jeany Lacorte, and Venus Tandoc) with libel. The Regional Trial Court (RTC) of Makati City convicted them on February 24, 2010, sentencing each to a fine with subsidiary imprisonment and ordering them jointly and severally to pay Guy ₱5,000,000 actual damages, ₱5,000,000 moral damages, and ₱211,200 attorney’s fees. On appeal, t Case Digest (G.R. No. 213023) Expanded Legal Reasoning Model
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)