Facts:

• On December 4, 2012, Juan Ponce Enrile (respondent) filed a civil complaint for damages against Yolanda Villanueva-Ong (petitioner) for libel in the Regional Trial Court (RTC) of Pasay City, under Civil Case No. R-PSY-12-12031-CV.
• The complaint was based on a libelous article titled "Like father like Son?" published on October 16, 2012, in the Philippine Star, authored by the petitioner.
• The article accused the respondent of being a liar, fraud, and manipulator, alleging attempts to "revise history" for electoral support for his son, Juan CastaAer Ponce Enrile, Jr. (Jack Enrile), a Senate candidate.
• The article contained statements that negatively portrayed the respondent, insinuating criminal behavior, including car smuggling.
• The respondent claimed the article was malicious and aimed to discredit his integrity as a public official.
• On January 17, 2013, the petitioner filed an Answer with Compulsory Counterclaims, asserting that the lawsuit was harassment intended to silence her as a journalist.
• The petitioner argued that the respondent's omission of the editor and publisher of the Philippine Star indicated malice and bad faith.
• The respondent filed a Motion to Dismiss, claiming the counterclaims were permissive and required compliance with procedural requirements, including docket fees.
• The RTC ordered the petitioner to pay the appropriate fees within 15 days, warning that failure to do so would result in dismissal of the counterclaims.
• The petitioner's motion for reconsideration was denied, leading her to seek relief from the Court of Appeals (CA).
• On March 4, 2014, the CA denied the petition, resulting in the current case.

Issue:

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Ruling:

• The Supreme Court ruled that the counterclaims filed by the petitioner are compulsory and should be resolved alongside ...(Unlock)

Ratio:

• A counterclaim is deemed compulsory if it arises from or is connected to the transaction or occurrence that constitutes the subject matter of the opposing party's claim.
• In this case, the respondent's complaint for damages was based on the alleged malicious publication by the petitioner, making malice and intent central to both the complaint and the counterclaims.
• The petitioner's counterclaims, alleging that the respondent's suit was filed in bad faith to harass her, were inherently...continue reading