G.R. No. 184315 - Yuchengco vs. Manila Chronicle Publishing Corp.

Petitioner Alfonso T. Yuchengco filed a complaint stemming from a series of articles published by Manila Chronicle Publishing Corporation accusing him of various defamatory acts.
The articles were published in late 1993, specifically November and December issues, and contained allegations labeling Yuchengco as a "Marcos crony," implying he gained unwarranted benefits from former President Marcos and his brother-in-law, Benjamin "Kokoy" Romualdez.
The articles asserted that Yuchengco was a front for the Marcos-Romualdez clans in Benguet Corporation and insinuated unsound and immoral business practices.
Additional allegations included that he induced Rizal Commercial Banking Corporation (RCBC) to violate banking laws (specifically the DOSRI loan rules), disobeyed Securities and Exchange Commission (SEC) orders, was an unfair employer during a strike at Grepalife Corporation, and acted as a "corporate raider" seeking profit improperly.

Respondents denied liability, asserting that the articles were published in good faith, after verification.
They claimed the articles were qualifiedly privileged communications or fair commentaries on matters of legitimate public interest.
They argued petitioner was a public figure and, assuming the articles to be defamatory, were not published with actual malice.
Defendant Coyiuto claimed no participation in the publication of the articles.

Petitioner testified extensively about his business roles and denied all allegations, stressing that his shares in Benguet Corporation were legally acquired and that he had no improper dealings with the Marcos or Romualdez families.
Petitioner also denied inducing RCBC or others to violate laws or SEC orders, and denied being involved in labor issues characterized in the articles.
Respondents presented testimonies from editors and journalists attesting to their editorial process and denial of malice, including definitions and interpretations of terms such as "crony."
Respondents asserted that the articles presented fair commentaries and were based on public interest.

The Regional Trial Court (RTC) ruled in favor of petitioner, finding respondents liable for damages for malicious defamatory imputations.
The Court of Appeals (CA) initially affirmed the RTC ruling but reversed itself upon motion for reconsideration, dismissing the complaints citing qualified privilege and public figure status of petitioner.
Petitioner filed a petition for review on certiorari before the Supreme Court.

Whether the subject articles constituted defamatory imputations against Alfonso T. Yuchengco.
Whether Alfonso T. Yuchengco was a public official or public figure, thereby subjecting the articles to qualified privilege and requiring proof of actual malice.
Whether the respondents acted with actual malice in publishing the articles.
Whether the subject articles are qualifiedly privileged communications exempting respondents from liability.
The propriety and quantum of damages awarded to petitioner.