Case Digest (G.R. No. 193276) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Nova Communications, Inc., et al. v. Atty. Reuben R. Canoy and Solona T. Canoy (G.R. No. 193276, June 26, 2019; Decision promulgated September 28, 2020), petitioners Nova Communications, Inc., Angelina G. Goloy (News Editor), Yen Makabenta (Associate Publisher and Editor-in-Chief), and Ma. Socorro Naguit (Associate Editor) were sued by respondents Atty. Reuben R. Canoy and his wife, Solona T. Canoy, for libel arising from articles published in October 1990. The articles, authored by Teodoro Locsin Jr. and Louise Molina, appeared in the Philippine Free Press (October 13, 1990) and the Philippine Daily Globe (October 7, 9, and 11, 1990) and described Atty. Canoy as a “veritable mental asylum patient,” “madman,” and “lunatic” in connection with the Noble rebellion in Mindanao. The Canoys filed Civil Case No. 91-003 before the Regional Trial Court (RTC) of Makati, seeking damages for dishonor and discredit. The RTC, in its March 8, 2005 Decision, held petitioners and co-defendant Case Digest (G.R. No. 193276) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and background
- Petitioners: Nova Communications, Inc.; Angelina G. Goloy (News Editor); Yen Makabenta (Associate Publisher and Editor-in-Chief); Ma. Socorro Naguit (Associate Editor).
- Respondents: Atty. Reuben R. Canoy and his wife, Solona T. Canoy, who filed a civil libel suit.
- Publication of allegedly defamatory articles
- October 1990 issues of Philippine Free Press and Philippine Daily Globe carried articles by Teodoro L. Locsin, Jr. and Louise Molina linking Atty. Canoy to Col. Alexander Noble’s Mindanao rebellion.
- Articles described Canoy as a “veritable mental asylum patient,” “madman with about 10,000 deranged followers,” and “certified lunatic,” attributing to him a secessionist movement.
- Procedural history
- RTC (March 8, 2005): Found petitioners liable for libel; awarded P50,000 litigation expenses, P500,000 moral damages, P100,000 exemplary damages, P300,000 attorney’s fees.
- CA (Jan. 28, 2010): Modified awards to P20,000 litigation expenses, P300,000 moral damages, P50,000 exemplary damages, P100,000 attorney’s fees.
- Petitioners filed for review on certiorari before the Supreme Court.
Issues:
- Libelous nature
- Whether the articles imputed defamatory per se remarks under Article 353, RPC.
- Privilege and defenses
- Whether the publications are protected as qualifiedly privileged communications or as fair comment on matters of public interest.
- Malice
- Whether actual malice was established or if malice is presumed.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)