Case Digest (G.R. No. 184315)
Facts:
Alfonso T. Yuchengco v. The Manila Chronicle Publishing Corporation, Noel Cabrera, Gerry Zaragoza, Donna Gatdula, Rodney P. Diola, Raul Valino, Thelma San Juan and Robert Coyiuto, Jr., G.R. No. 184315, November 28, 2011, Special Third Division, Peralta, J., writing for the Court.In late 1993 several articles alleged to be defamatory of Alfonso T. Yuchengco were published in The Manila Chronicle by Chronicle Publishing Corporation. Yuchengco filed Civil Case No. 94-1114 before the Regional Trial Court (RTC) of Makati City, Branch 136, asserting three causes of action: (1) damages for libel against the Chronicle and its editorial staff and writers; (2) damages for abuse of right under Articles 19 and 20 of the Civil Code against Robert Coyiuto, Jr. and Chronicle Publishing; and (3) attorneys’ fees and costs against all respondents.
On November 8, 2002 the RTC ruled for petitioner and awarded substantial moral, exemplary damages and attorneys’ fees. The Court of Appeals (CA) initially affirmed that decision on March 18, 2008. Respondents filed a motion for reconsideration; on August 28, 2008 the CA issued an Amended Decision reversing its March 18, 2008 ruling and dismissed the complaint. Petitioner sought relief before the Supreme Court, which rendered a Decision on November 25, 2009 partially granting the petition and reinstating the RTC decision with modifications in damages.
Respondents filed a Motion for Reconsideration dated January 15, 2010, and Coyiuto, Jr. filed a Supplemental Motion for Reconsideration dated March 17, 2010 contending, among other points, that he was not sued for libel but only for abuse of right; that there was no evidence he was chairman or principal owner; and that the damages were excessive. The Court recalled its March 3, 2010 denial of reconsideration, allowed Coyiuto’s supplemental motion, and required petitioner to comment; petitioner filed comments on June 22, 2010. The Court denied most of respondents’ procedural contentions, found that factual findings below (including that Coyiuto admitted...(Pro-only)
Issues:
- Did respondents’ Motion for Reconsideration and Coyiuto, Jr.’s Supplemental Motion for Reconsideration present substantial new matters warranting reversal of the Court’s November 25, 2009 Decision (procedural issue)?
- Was respondent Robert Coyiuto, Jr. shown to be chairman of Chronicle Publishing and properly held liable for the publications (factual / privity of control issue)?
- Was liability established for the publications by a preponderance of evidence and under what legal theory—libel or abuse of rights—and were damages properly awarded?
- Were the amounts of moral damages, exemplary damages and attorneys’ fees awarded on November 25, 2009 palp...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)