Case Digest (G.R. No. 213023)
Facts:
Michael C. Guy v. Raffy Tulfo, Allen Macasaet, Nicolas V. Quijano, Jr., Janet Bay, Jesus P. Galang, Randy Hagos, Jeany Lacorte, and Venus Tandoc, G.R. No. 213023, April 10, 2019, Supreme Court Third Division, Leonen, J., writing for the Court.On March 24, 2004 an article authored by Raffy T. Tulfo and published in the newspaper Abante Tonite reported that businessman Michael C. Guy—then under investigation by the Revenue Integrity Protection Service (RIPS) of the Department of Finance for alleged tax fraud—went to then-Secretary Juanita Amatong to seek help, and that Amatong allegedly instructed the head of RIPS to surrender investigatory documents to her. Guy filed a Complaint-Affidavit for libel before the Office of the City Prosecutor of Makati City against Tulfo and representatives of the paper's publisher, Monica Publishing Corporation (named in the case as Allen Macasaet, Nicolas V. Quijano, Jr., Janet Bay, Jesus P. Galang, Randy Hagos, Jeany Lacorte, and Venus Tandoc—collectively “Macasaet, et al.”).
After preliminary investigation an Amended Information for libel was filed. At arraignment the accused refused to plead and the Regional Trial Court (RTC), Branch 132, Makati City entered pleas of not guilty and proceeded to trial. In its February 24, 2010 Judgment the RTC convicted Tulfo and Macasaet, et al., and ordered joint and several payment to Guy of P5,000,000 as actual damages, P5,000,000 as moral damages, and P211,200 as attorney’s fees, besides a fine.
Separate appeals by Tulfo and by Macasaet, et al. were brought to the Court of Appeals (CA). In its August 30, 2013 Decision the CA affirmed the conviction but modified damages—reducing moral damages and awarding exemplary damages. After motions for reconsideration the CA issued an Amended Decision dated June 13, 2014 which (1) deleted the RTC award of actual damages for lack of factual and legal basis, (2) deleted the exemplary damages previously ordered, and (3) ordered respondents to pay Guy P500,000 moral damages and P211,200 attorney’s fees.
Guy filed a Petition for Review on Certiorari under Rule 45 seeking reinstatement of the RTC’s awards, specifically contesting the CA’s deletion of actual and exemplary damages and contending that the moral damages award should be larger. Respondents filed comments (Tulfo opposed grants of some damages), the Court required replies and...(Pro-only)
Issues:
- Did petitioner Michael C. Guy prove a factual basis for an award of actual damages?
- Is petitioner entitled to moral damages, and if so, in what amount?
- Is petitioner entitled to exempla...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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