Case Digest (G.R. No. 139120)
Facts:
- Petitioners: Freddie and Elizabeth Webb and their children.
- Filed a Joint Affidavit-Complaint on October 13, 1995, with the Office of the City Prosecutor of Makati City (I.S. No. 95-3485).
- Respondents: Members of the Board of Directors of the Philippine Daily Inquirer (PDI) and key editorial staff.
- Complaint based on seven allegedly false and defamatory articles linking the Webb family to the Vizconde rape slay case.
- Respondents claimed articles were true reports on public interest and thus protected.
- Makati City Prosecutor's Office dismissed the complaint against PDI Board members, citing Article 360 of the Revised Penal Code.
- Probable cause found against several PDI reporters, leading to libel informations against them.
- Secretary of Justice affirmed dismissal against PDI Board members and reversed probable cause against reporters.
- Petitioners' motion for reconsideration was denied, leading to a petition for certiorari with the Court of Appeals.
- Court of Appeals dismissed the petition for being late, prompting the current petition for review on certiorari.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the Court of Appeals did not err in dismissing the petition for certiorari due to late filing.
- The Supreme Court found that the Secretary of Justice did not commit grave abu...(Unlock)
Ratio:
- The Supreme Court emphasized the necessity of following procedural rules, particularly the timelines in Section 4, Rule 65 of the 1997 Rules of Civil Procedure.
- Petitioners failed to file within the prescribed period; claims of excusable negligence were not sufficient to overlook procedural lapses.
- Amendments to rules regarding filing periods could no...continue reading
Case Digest (G.R. No. 139120)
Facts:
The case involves petitioners Freddie and Elizabeth Webb, along with their children Hubert Jeffrey P. Webb, Gran Jason Webb, Joanna Marie Webb, Marybeth Webb-Agcaoili, and Fritz Gabriel Webb, who filed a Joint Affidavit-Complaint on October 13, 1995, with the Office of the City Prosecutor of Makati City. This complaint, docketed as I.S. No. 95-3485, was against several members of the Board of Directors of the Philippine Daily Inquirer (PDI), including Marixi R. Prieto, Patricio A. Garcia, Karla P. Delgado, Carlos F. Rufino, and Macario S. Rufino, as well as PDI Publisher Isagani Yambot, editor-in-chief Letty Jimenez-Magsanoc, managing editor Jose Ma. D. Nolasco, and several reporters. The complaint stemmed from the publication of seven allegedly false and defamatory articles that implicated the Webb family in the Vizconde rape slay case and suggested a cover-up.
In response, the respondents filed a Joint Counter-Affidavit asserting that the articles were not libelous as they constituted true and fair reports on matters of public interest, thus enjoying constitutional protection. They argued that the presumption of malice was destroyed by the privileged nature of the publication and that the complaint was deficient as it lacked supporting affidavits from third parties. After a preliminary investigation, the Makati City Prosecutor's Office dismissed the complaint against the PDI Board members, citing Article 360 of the Revised Penal Code, which specifies that only the publisher, author, or editor of a publication can be held liable for defamation. However, probable cause was found against several PDI reporters, leading to the filing of libel informations against t...