G.R. No. 164437 - Villanueva vs. Philippine Daily Inquirer

Petitioner, Hector C. Villanueva, was a mayoralty candidate in Bais, Negros Oriental during the May 11, 1992 elections.
Prior to the election, on March 30, 1990, another candidate, Ricardo Nolan, petitioned for Villanueva's disqualification, which was denied by the COMELEC.
Villanueva had been previously appointed as Officer-in-Charge (OIC) Mayor of Bais City and later removed from office due to convictions in administrative cases for grave abuse of authority and harassment in 1987.

On May 9, 1992, the Manila Daily Bulletin Publishing Corporation published an article stating that COMELEC had disqualified Villanueva due to his conviction in three administrative cases.
On May 10, 1992, the Philippine Daily Inquirer, Inc. published a similar article with essentially identical information regarding Villanueva’s disqualification.
The articles stressed that the disqualification was based on Section 40 of the Local Government Code of 1991, which bars those removed from office from running for public office.

Petitioner alleged that the articles were published “maliciously timed” to defeat his mayoralty bid, causing his loss in the elections.
He claimed that the negative publicity, which he attributes to the reports, directly led supporters to abandon him.
Petitioner sought various damages: actual damages (P270,000 for campaign expenses), moral damages (P10,000,000), exemplary damages (unspecified amount), attorney’s fees (P300,000) and costs.

The Regional Trial Court (RTC) of Negros Oriental initially ruled in favor of the petitioner, finding the publications derogatory and injurious to his reputation.

The RTC held that the respondents were negligent in failing to verify the accuracy of their sources.
The RTC ruled that the publications were not privileged since they lacked truth and fairness.

On appeal, the Court of Appeals reversed the trial court’s decision, dismissing the complaint.

The appellate court noted the absence of evidence that the publications were obtained from an official press briefing or release.
It further determined that there was no demonstration of actual malice nor evidence that the errors in the articles caused Villanueva’s electoral defeat.

Petitioner argued his claim was based on quasi‑delict (tort) which requires proof of negligence or fault, not proof of malice as necessary in libel cases.
Respondents maintained that the complaint rested on malicious publication, inherently requiring proof of actual malice.
A dispute arose over whether the petitioner could change his underlying theory from malicious publication to quasi‑delict after filing, with respondents arguing that such a change violated due process.

Whether the petitioner is required to prove actual malice to recover damages for the publication of allegedly false and injurious statements.

The central controversy is the proper cause of action: malicious publication (libel) versus quasi‑delict (tort).
Whether the evidentiary threshold should be based on a preponderance of evidence (as in quasi‑delict) or if it must meet the stringent requirement of proving malice (actual malice) inherent in libel claims.

Whether the Court of Appeals erred in characterizing the petitioner's complaint as one arising from malicious publication, thereby necessitating proof of actual malice.