Case Digest (G.R. No. 213918)
Facts:
Philippine Daily Inquirer, Inc., Donna Cueto, Artemio T. Engracia, Jr., and Abelardo S. Ulanday v. Juan Ponce Enrile, G.R. No. 229440, February 19, 2024, the Supreme Court First Division, Caguioa, J., writing for the Court.
Respondent Senator Juan Ponce Enrile filed a civil action for libel against petitioners Philippine Daily Inquirer, Inc. (Inquirer), reporters Donna Cueto and Dona Pazzibugan, and editors Letty Jimenez‑Magsanoc, Artemio T. Engracia, Jr., and Abelardo S. Ulanday arising from a December 4, 2001 Inquirer front‑page article titled “PCGG: no to coconut levy agreement.” The article reported that PCGG Chairperson Haydee Yorac had said the settlement would allow “Marcos cronies… particularly… former Sen. Juan Ponce Enrile, to keep their plundered loot,” and repeated an allegedly attributable statement that the compromise would not recover ill‑gotten wealth from named persons, including Enrile.
After publication, Yorac sent letters dated December 6 and 12, 2001 disclaiming that she made those statements and calling for correction; Enrile demanded a public apology and correction but received none. Enrile then sued for damages, alleging the article imputed that he benefited from the coco levy fund, accumulated ill‑gotten wealth, and was a Marcos crony.
At trial, reporter Cueto testified she used a press statement handed to her by PCGG Commissioner Ruben Carranza and did not personally confirm Yorac’s authorship before filing the story to meet deadline; the parties stipulated that Carranza provided the paper marked Exhibit 1. The Regional Trial Court (RTC), Branch 139, Makati, found for Enrile in its October 30, 2013 Decision, holding the article defamatory and that publication was malicious, and ordered defendants to pay moral, exemplary damages and attorney’s fees; Pazzibugan was absolved for lack of contribution to the defamatory passages. The RTC denied the defendants’ motion for reconsideration on April 25, 2014.
Petitioners appealed to the Court of Appeals (CA). In its August 22, 2016 Decision in CA‑G.R. CV No. 102710, the CA affirmed the RTC’s finding of defamation and actual malice but reduced the awards for moral, exemplary damages and attorney’s fees; its January 18, 2017 resolution denied reconsideration. ...(Subscriber-Only)
Issues:
- Is a petition under Rule 45 proper where the contest concerns whether malice attended publication (i.e., is the question one of law or of fact)?
- Did the questioned Inquirer article impute a discreditable act or condition to Enrile such that it is defamatory?
- Was there malice — actual malice or reckless disregard for the truth — in the publication, notwithstanding the article’s character as a report on a matter of public interest a...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)