Facts:

The case of Felix Montenegro vs. Enrique Medina (G.R. No. 48135) was decided by the Supreme Court of the Philippines on June 22, 1942. The plaintiff, Felix Montenegro, filed a complaint against the defendant, Enrique Medina, in the Court of First Instance of Oriental Negros. The complaint, dated November 14, 1939, stemmed from a prior civil case (Civil Case No. 1614) initiated by Medina against Montenegro and his brother, Nicolas Montenegro, for the recovery of a sum of money for professional services rendered. In the course of this civil case, Medina included a paragraph in his complaint that Montenegro alleged was defamatory. This paragraph accused him of frequently evading payment of his obligations despite being financially capable, and it suggested that many of his creditors had to resort to legal action to collect debts owed to them. Montenegro claimed that this statement was malicious and intended to damage his reputation, leading to emotional distress and financial ...

Facts:

The case involves an appeal from an order of the Court of First Instance of Oriental Negros, which sustained the defendant's demurrer and dismissed the plaintiff's complaint. The plaintiff, Felix Montenegro, filed a complaint dated November 14, 1939, alleging that the defendant, Enrique Medina, wrote and published defamatory and libelous words in paragraph 24 of the complaint in civil case No. 1614, which were intended to mortify the plaintiff and attack his honesty, integrity, and reputation. The plaintiff claimed damages of P25,000 for the injury to his feelings and reputation, and an additional P25,000 as punitive and exemplary damages. The defendant demurred on the grounds that the facts alleged in the complaint do not constitute a cause of action, and that there exists another case between the parties founded on the same cause of action. The trial court dismissed the complaint, holding that the plaintiff did not yet have a cause of action.

Issue:

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Ruling:

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Ratio:

1. An action for libel accrues from the date of publication and must be instituted within two years thereafter. The fact that the plaintiff had moved to strike out the allegedly libelous allegation as being immaterial, irrelevant, and impertinent did not affect his right to bring an independent action for damages.
2. The protection given to individuals in the interest of an efficient administration of justice may not be abused as a cloak from beneath which private malice may be gratified. The defamatory words must be pertinent and relevant to the subject under inquiry to be protected by the mantle of privilege.
3. The plaintiff's claim did not exist at the time of the commencement of case No. 1614 and did not arise out of the transaction therein involved. Hence, it was not obligatory for the plaintiff to set up his claim by way of counter-claim in said case.
4. The complaint under consideration states facts sufficient to constitute a cause of action for actual damages, and the plaintiff-appellant is entitled to have it heard on the merits regardless of whether or not he is entitled also to damages for injury to his feelings and reputation and to punitive damages.