Case Summary (G.R. No. L-29192)
Petitioner
Baguio Midland Courier, represented by Oseo C. Hamada and Cecille C. Afable.
Respondent
Court of Appeals (Former Sixth Division) and Ramon L. Labo, Jr.
Key Dates
• January 3 & 10, 1988 – Publication of Afable’s columns questioning Labo’s literacy and unpaid obligations.
• 14 June 1990 – RTC, Branch 6, Baguio City, dismisses Labo’s civil libel suit.
• 7 January 1992 – Court of Appeals reverses RTC and awards damages.
• 29 September 1992 – CA denies petitioners’ motion for reconsideration.
• 25 November 2004 – Supreme Court decision on review.
Applicable Law
• 1987 Philippine Constitution – Guarantees freedom of speech and of the press.
• Revised Penal Code, Article 354 – Presumption of malice in defamatory imputations; privileged communications.
• Presidential Decree No. 1508 – Barangay conciliation requirement (found inapplicable to corporate parties).
• Doctrine of fair comment and public-figure privilege (New York Times Co. v. Sullivan).
Factual Background
Afable’s January 3 column raised rhetorical questions about Labo’s education, heritage, and alleged promise of P18 million in aid; it noted refusal to publish his ads for nonpayment of a prior account. Her January 10 column referred to a “Dumpty in the egg” campaigning for Cortes, to unpaid medical services of approximately P27,000, and warned of possible political fallout. Labo interpreted these as malicious imputations of illiteracy, dishonesty, and failure to meet financial obligations.
Procedural History
- Criminal libel complaint dismissed by the Department of Justice for lack of evidence.
- Civil libel suit filed in RTC; petitioners move to dismiss for failure to comply with PD 1508 and for lack of cause of action. RTC denies motions, accepts amended complaint including the corporate publisher.
- Trial limited to the January 10 article; RTC finds the column a privileged fair comment, dismisses complaint (14 June 1990).
- Court of Appeals reverses, finds petitioners guilty of libel, awards P200,000 moral damages, P100,000 exemplary damages, P50,000 attorney’s fees (7 January 1992), and denies reconsideration (29 September 1992).
- Petitioners seek certiorari relief before the Supreme Court.
Issues Presented
- Whether the CA erred in inferring malice from the relationship of petitioners as “spouses.”
- Whether the phrase “Dumpty in the egg” was shown to refer specifically to Labo.
- Whether the reference to P27,000 indebtedness applied to him rather than to the newspaper.
- Whether Afable’s column transcended fair comment and thus lost privileged status.
- Whether the CA correctly reversed the RTC’s dismissal.
Supreme Court Ruling
The petition is granted. The CA decision and resolution are reversed and set aside. The RTC decision dismissing the complaint for lack of merit is affirmed.
Reasoning on Factual Findings
• Identification errors – The CA wrongly assumed that “Dumpty in the egg” referred to Labo, despite evidence that the phrase alluded to another candidate (Cortes). No credible evidence showed a third-party identification of Labo as the target.
• Relationship mischaracterization – The appellate court’s finding that petitioners were spouses was contradicted by the record showing they were siblings.
These factual errors fall under recognized exceptions permitting review of appellate findings.
Reasoning on Legal Principles
• Privileged f
Case Syllabus (G.R. No. L-29192)
Facts
- Oseo C. Hamada was president and general manager of Baguio Printing and Publishing Co., Inc., publisher of the weekly Baguio Midland Courier, and business manager of the paper.
- Cecille Afable was editor-in-chief and columnist of the Courier, authoring the “In and Out of Baguio” column.
- Ramon L. Labo, Jr. ran for Batasang Pambansa in 1984 (with campaign manager Benedicto Carantes) and for Baguio City mayor in the 18 January 1988 elections (he won).
- During the 1984 campaign, Labo’s political ads and paraphernalia were printed and published by petitioners; an unpaid account arose amounting to P27,415.
- In early January 1988, Afable published two column excerpts:
- January 3, 1988: Questions about Labo’s literacy, his Japanese connections, pending account with the Courier, and conditional acceptance of ads upon payment of old debts.
- January 10, 1988: Reference to a “Dumpty in the egg” campaigning for Cortes, criticism of unpaid medical bills (P27,000), and predicted resignations of teachers.
Procedural History
- Labo filed criminal and civil libel actions against petitioners; DOJ dismissed the criminal case for insufficiency of evidence on 26 December 1988.
- Civil case raffled to RTC Branch 6, Baguio City. Complaint alleged malice, false imputations, and damage to the reputations of Labo and co-plaintiff Yuko Narukawa Labo.
- Petitioners moved to dismiss for failure to refer to Katarungang Pambarangay (P.D. No. 1508) and for no cause of action; RTC denied motions, holding P.D. No. 1508 inapplicable to corporate parties.
- Plaintiffs amended complaint (April 1988) to implead the publishing company; petitioners answered, denied libel, asserted fair comment and freedom of the press, and counterclaimed for damages.
- At pre-trial (31 March 1989), issues limited to libelous nature of publication, entitlement to damages, and counterclaims. Narukawa Labo withdrew her testimony; the January 3 article was no longer offered—trial focused on the January 10 column.
- Key testimony:
- Labo claimed “Dumpty in the egg” referred to him and implied business failures.
- Dr. Pedro Rovillos (Lions Club) testified that the phrase meant “zero” or “big lie” but could not explain why it denoted Labo.
- Petitioners’ accountant