Case Digest (G.R. No. 184315) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In the last quarter of 1993, The Manila Chronicle Publishing Corporation under the chairmanship of Robert Coyiuto, Jr. published several articles alleging wrongdoing by Alfonso T. Yuchengco, then a prominent businessman and government envoy. Aggrieved by what he deemed defamatory statements, Yuchengco filed Civil Case No. 94-1114 before the Regional Trial Court (RTC) of Makati City, Branch 136, on October 17, 1994, asserting three causes of action: (1) damages for libelous publication against the Chronicle’s editorial staff (Noel Cabrera, Gerry Zaragoza, Donna Gatdula, Rodney P. Diola, Raul Valino, Thelma San Juan, Neal H. Cruz, Ernesto Tolentino), (2) damages for abuse of right against Coyiuto, Jr. personally, and (3) attorney’s fees and costs against all respondents. On November 8, 2002, the RTC rendered judgment in Yuchengco’s favor, awarding substantial moral and exemplary damages and attorney’s fees. The respondents appealed to the Court of Appeals (CA), which on March 18, Case Digest (G.R. No. 184315) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Publication and initial complaint
- In the last quarter of 1993, The Manila Chronicle (Chronicle Publishing Corp.) published several allegedly defamatory articles against petitioner Alfonso T. Yuchengco, authored and edited by respondents Noel Cabrera, Gerry Zaragoza, Donna Gatdula, Rodney P. Diola, Raul Valino, Thelma San Juan, Neil H. Cruz and Ernesto Tolentino.
- October 17, 1994: Petitioner filed an amended complaint in RTC Makati (Civil Case No. 94-1114) under three causes of action:
- Damages for libelous publication (against editorial staff & Chronicle Publishing).
- Damages for abuse of right (against Robert Coyiuto, Jr. and Chronicle Publishing).
- Attorney’s fees and litigation costs (against all respondents).
- Trial court and appellate proceedings
- November 8, 2002: RTC Branch 136 rendered judgment for petitioner, awarding moral and exemplary damages in all three causes of action.
- March 18, 2008: Court of Appeals (CA) affirmed the RTC decision.
- August 28, 2008: CA Amended Decision on motion for reconsideration reversed the RTC, dismissing the complaint.
- November 25, 2009: Supreme Court granted petitioner’s petition for review, set aside the CA Amended Decision, and reinstated the RTC judgment with modified damages.
- January 15 & March 17, 2010: Respondents filed motions for reconsideration (including Supplemental Motion by Coyiuto, Jr.).
- April 21, 2010: SC recalled its March 3 denial, entertained supplemental motion, required petitioner’s comment.
- June 22, 2010: Petitioner filed comments; SC resolved motions by partially adjusting damage awards.
Issues:
- Issues raised in petitioner’s petition for review
- Whether the CA erred in relying on Arturo Borjal, et al. v. CA, et al. to reverse the RTC decision.
- Whether the CA erred in treating the subject articles as privileged communications.
- Whether the CA erred in deeming petitioner a public official or public figure.
- Issues raised in respondents’ motions for reconsideration
- Lack of proof of malice in fact.
- Petitioner’s status as a public figure bars full recovery without showing malice.
- Publications constituted fair comment on matters of public interest.
- Qualified privilege protected respondents’ publications.
- No legal or evidentiary basis to hold certain staff members (Gatdula, San Juan) liable.
- Coyiuto, Jr. was not involved in editorial decisions; sued only in personal capacity for abuse of right.
- Awarded damages are excessive, inequitable and unjustified.
- Issues raised in Coyiuto, Jr.’s Supplemental Motion
- Coyiuto, Jr. was not sued for libel in the first cause of action; hence no basis for moral and exemplary damages under Articles 2219 & 2229 Civil Code.
- No evidence he was Chairman, officer or principal owner of Chronicle Publishing at the time of publication.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)