Title
Ruiz vs. Topacio
Case
G.R. No. 45072
Decision Date
Jun 29, 1940
A former Director of Correos is held liable for defamation and ordered to pay damages, affirming the trial court's jurisdiction and the absence of prescription for the civil action, despite a dissent advocating for further review.
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Case Digest (G.R. No. 45072)

Facts:

  • The case involves Juan Ruiz (plaintiff) and Jose Topacio (defendant).
  • The Supreme Court of the Philippines rendered its decision on June 29, 1940.
  • The case originated in the Court of First Instance of Manila.
  • Juan Ruiz, the Director of Posts, filed a civil suit against his predecessor, Jose Topacio, for libel.
  • The lower court ruled in favor of Ruiz, awarding him P30,000 in damages (P25,000 for reputation and feelings, P5,000 as punitive damages).
  • Topacio appealed, claiming twenty errors by the trial judge, focusing on two preliminary legal issues.
  • Topacio argued that the judgment was null due to the trial court's lack of jurisdiction, asserting that Judge Pedro Ma. Sison lacked authority as the case was assigned to a different sala.
  • The court noted that Sison had presided over the case from the beginning and heard all evidence.
  • The appeal also questioned the legal basis of the action, including claims of prescription and the applicability of the repealed Libel Law.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed that the trial court had jurisdiction to hear and decide the case, validating Judge Sison's authority.
  • The Court held that the action for damages was legally sustainable, as claims of prescription did not apply to all libelous statements, and the action arose under the repe...(Unlock)

Ratio:

  • The Supreme Court emphasized that jurisdiction is conferred by law, not merely by case assignment among judges.
  • Judge Sison was duly assigned and presided over the case, affirming his jurisdiction.
  • The ...continue reading

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