Case Summary (G.R. No. 159813)
Applicable Law
This case addresses the crime of libel under Article 355 in conjunction with Article 360 of the Revised Penal Code of the Philippines. Additionally, the award for moral damages and attorney’s fees is grounded on Article 2219(7) of the Civil Code.
Factual Background
On March 24, 1992, the city prosecutor filed an Information for libel against Figueroa and Flaviano following a published article in the People’s Daily Forum. The article, entitled "Footprints," allegedly contained malicious statements directed at Rivera, describing him in derogatory and defamatory terms while commenting on the state of the Bankerohan Public Market. The trial court found Rivera’s allegations sufficiently serious to uphold charges of libel against the petitioners.
Proceedings and Trial Court Decision
During the trial, both petitioners entered a plea of “Not Guilty.” On June 8, 1993, the RTC rendered a decision convicting both petitioners of libel and imposing upon them an indeterminate prison sentence alongside a joint order to pay moral damages of P50,000 and P10,000 as attorney’s fees to Rivera. The trial court found that the evidence against them was sufficient and noted no mitigating or aggravating circumstances.
Court of Appeals Ruling
The petitioners later appealed the decision to the CA, which affirmed the trial court's ruling in its decision dated October 11, 2002. The CA upheld the findings that the article was indeed libelous and ruled against the petitioners' claims regarding their defense.
Arguments Presented by Petitioners
The petitioners contended that the published article on the conditions at the public market was not directed at Rivera as an individual, but was a general commentary. They further argued that Rivera was a public officer, which would grant them a privilege under Article 354 of the Revised Penal Code, thereby mitigating any malice. However, both the trial court and the CA rejected these contentions.
Analysis of Libelous Content
The Supreme Court analyzed the text of the article, confirming that it contained direct references to Rivera and included derogatory remarks designed to harm his reputation. The decision emphasized that the presence of derogatory names in the article implied malice and intent to defame.
Public Officer Status of Rivera
The petitioners’ argument regarding Rivera's status as a public officer was dismissed. The Court held that Rivera did not possess any sovereign authority as defined in the law and that his position did not adequately confer public officer status, thus nullifying their defense based on privileged commu
...continue readingCase Syllabus (G.R. No. 159813)
Case Overview
- This case involves a petition for review under Rule 45 of the Rules of Court, filed by petitioners Tony N. Figueroa and Rogelio J. Flaviano.
- The petition seeks to set aside the Decision dated October 11, 2002, of the Court of Appeals (CA) in CA-G.R. CR No. 17235, which affirmed the decision of the Regional Trial Court (RTC) of Davao City, Branch 17, that found the petitioners guilty of libel.
Background of the Case
- On March 24, 1992, the city prosecutor of Davao filed an Information for libel against the petitioners at the instance of Aproniano Rivera.
- The case was docketed as Criminal Case No. 25,957-92 and involved allegations against Figueroa, a columnist, and Flaviano, the Publisher-Editor of the People's Daily Forum.
- The libelous article published on April 9, 1991, accused Rivera of various misconducts, including abuse of power and corruption in the context of the Bangkerohan public market.
Proceedings in the Regional Trial Court
- The RTC found that the published article contained malicious statements intended to damage Rivera’s reputation.
- On June 8, 1993, the RTC sentenced both petitioners to an indeterminate imprisonment of five months and one day to two ye