Case Digest (G.R. No. 132980) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Philippine Daily Inquirer, Inc. et al. v. Juan Ponce Enrile (G.R. No. 229440, July 14, 2021), respondent Senator Juan Ponce Enrile filed a Complaint for Damages for libel against petitioners Philippine Daily Inquirer (a newspaper corporation), reporters Donna Cueto and Dona Pazzibugan, and editors Artemio T. Engracia, Jr., Abelardo Ulanday, and Letty Jimenez-Magsanoc. The suit stemmed from a December 4, 2001 front-page article entitled “PCGG: no to coconut levy agreement,” which attributed to PCGG Chairperson Haydee Yorac statements accusing Enrile of being a “Marcos crony”, of benefiting from the coco levy fund, and of keeping “plundered loot.” After Enrile’s counsel demanded correction and apology, and Yorac disclaimed uttering those words in letters dated December 6 and 12, 2001, no rectification appeared. The Makati RTC (Branch 139) in its October 30, 2013 Decision found the article defamatory, awarded Enrile ₱2,000,000 moral damages, ₱500,000 exemplary damages, and ₱250, Case Digest (G.R. No. 132980) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Context
- Petitioner Philippine Daily Inquirer, Inc. (Inquirer), its reporters (Donna Cueto, Dona Pazzibugan) and editors (Artemio T. Engracia, Jr.; Abelardo S. Ulanday; Letty Jimenez-Magsanoc) published an article titled “PCGG: no to coconut levy agreement” on December 4, 2001.
- Respondent Senator Juan Ponce Enrile sued for libel, alleging the article falsely quoted PCGG Chairperson Haydee Yorac as calling Enrile a “Marcos crony” who “kept plundered loot” from the coconut levy fund.
- Procedural History
- Yorac denied authorship of the statements in letters dated December 6 and December 12, 2001, requesting corrections. Enrile’s demand for public apology went unheeded.
- Enrile filed a Complaint for Damages before RTC Makati Branch 139. The RTC (Oct 30, 2013) ruled the article defamatory, awarding P2 M moral damages, P500 K exemplary damages, and P250 K attorney’s fees. Motion for reconsideration was denied (Apr 25, 2014).
- The Court of Appeals (Aug 22, 2016) affirmed liability but reduced damages to P1 M moral, P200 K exemplary, and P100 K attorney’s fees. Reconsideration was denied (Jan 18, 2017).
- Petitioners filed a Rule 45 Petition before the Supreme Court seeking reversal of libel findings.
Issues:
- Whether the Court of Appeals erred in affirming that the published article was libelous by:
- Imputing a discreditable act or condition on Enrile; and
- Exhibiting malice in publication.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)