G.R. No. L-16027 - Policarpio vs. Manila Times Publication Co., Inc.

Lumen Policarpio, executive secretary of the UNESCO National Commission, filed a complaint for libel and defamation against The Manila Times Publishing Co., Inc., and four newspaper officers/authors, seeking P150,000 actual damages, P70,000 moral damages, P60,000 exemplary damages, P20,000 attorney’s fees, and costs.
Defendants admitted formal allegations, denied substantive allegations, pleaded special defenses, and counterclaimed P10,000 for attorney’s fees.
The Court of First Instance dismissed both the complaint and counterclaim for lack of proven malice. The case was certified to the Court of Appeals and then transferred to the Supreme Court on account of the amount involved.

Policarpio had filed administrative charges against Herminia D. Reyes (her subordinate). Reyes, in turn, filed counter‐charges with Col. Crisanto V. Alba (Presidential Complaints and Action Commission – PCAC) and criminal complaints for malversation and estafa with the Manila City Fiscal on August 8, 1956.
On August 11, 1956, The Saturday Mirror published a front‐page article with a banner headline “WOMAN OFFICIAL SUED” and subtitle “PCAC raps L. Policarpio on fraud,” falsely stating that PCAC filed the criminal charges after Alba’s investigation and omitting material details (only 18 stencil sheets valued at P54).
On August 13, 1956, The Daily Mirror published a second front‐page item, with photos of Policarpio and Reyes, clarifying that neither PCAC nor Alba filed the complaints and noting the number of stencil sheets, but failing to remedy all inaccuracies.

Policarpio claimed the August 11 article falsely attributed to PCAC the filing of criminal charges, misstated that charges were initiated by administrative investigation, and omitted facts that would diminish the gravity of the allegations.
Defendants contended that the inaccuracies were immaterial since the complaints existed and that they enjoyed qualified privilege in reporting non-confidential official proceedings; they also pointed to the August 13 clarification as corrective.

Are the published articles per se defamatory and libelous by reason of false and misleading statements that exposed Policarpio to public ridicule and injury?
Do defendants enjoy qualified privilege under Article 354 of the Revised Penal Code as fair and true reporters of official proceedings?
Has malice been established or, at least, presumed, thereby stripping defendants of any privilege?
What are the appropriate amounts of moral damages and attorney’s fees to which Policarpio is entitled?