Case Summary (G.R. No. 213023)
Key Dates
• March 24, 2004: Publication of the contested article.
• February 24, 2010: RTC, Makati City convicts respondents of libel and orders damages.
• August 30, 2013: Court of Appeals (CA) affirms conviction, modifies damages.
• June 13, 2014: CA issues amended decision further modifying damages.
• April 10, 2019: Supreme Court issues final decision under the 1987 Constitution.
Applicable Law
• 1987 Constitution, Article III, Section 4 (freedom of speech and of the press).
• Revised Penal Code, Article 353 (libel).
• Civil Code, Articles 2199 (actual damages), 2224 (temperate damages), 2219(7) (moral damages), and 2230 (exemplary damages).
Factual Background
In 2004 Abante Tonite published that Guy, under investigation by the Department of Finance’s Revenue Integrity Protection Service for tax fraud, sought Amatong’s intervention to halt the probe and secure documents. Guy asserted that the unverified article defamed him, damaging his business reputation.
Procedural History
Guy filed a libel complaint before the Makati City Prosecutor, leading to an amended information charging respondents. The RTC convicted them in 2010, awarding ₱5 million actual and moral damages each, plus attorney’s fees. The CA affirmed in 2013 but reduced moral damages to ₱500,000 and added ₱500,000 exemplary damages. Its 2014 amended decision deleted actual and exemplary damages, awarded only ₱500,000 moral damages and ₱211,200 attorney’s fees. Guy petitioned to reinstate the higher awards; respondents defaulted comments except Tulfo, who defended the CA’s deletions.
Issues
- Whether there is sufficient factual basis for actual damages.
- Whether moral damages are properly awarded and in what amount.
- Whether exemplary damages may be granted.
Analysis on Actual Damages
Actual damages require proof of pecuniary loss with reasonable certainty. Guy’s sole support was speculative testimony that he “might” earn ₱50 million over ten years. No financial statements or concrete evidence were presented. Temperate damages likewise require proof of measurable loss. The Court found Guy failed to establish any pecuniary loss beyond a single client’s temporary withdrawal, who later resumed business. Accordingly, no actual or temperate damages may be awarded.
Analysis on Moral Damages
Moral damages compensate mental anguish, social humiliation, and wounded feelings. Proof of causal link between defendant’s act and complainant’s suffering is required, though pecuniary loss need not be shown. Guy submitted anecdotal evidence of family embarrassment and a client’s temporary withdrawal. The Court deemed this sufficient to justify an award, fixing moral damages at ₱500,000 as commensurate with the injury.
Analysis on Exemplary Damages
Exemplary damages serve to punish especially reprehensible conduct and deter future misconduct. They are discretionary and may be
Case Syllabus (G.R. No. 213023)
Facts of the Case
- In March 2004, Abante Tonite published an article by respondent Raffy T. Tulfo alleging that petitioner Michael C. Guy, under investigation for tax fraud, sought help from former Finance Secretary Juanita Amatong.
- The article claimed that Amatong called the head of the Revenue Integrity Protection Service (RIPS) to halt the investigation and surrender all documents on Guy.
- Guy maintained these allegations were false and seriously injured his reputation as a businessman and president of MG Forex Corporation.
Procedural History
- Guy filed a Complaint-Affidavit for libel against Tulfo and various officials of Monica Publishing Corporation before the Makati City Prosecutor’s Office.
- An Amended Information charging libel was filed; on arraignment, respondents refused to plead and were entered not guilty by the trial court.
- On February 24, 2010, the Regional Trial Court (RTC) convicted all respondents of libel and awarded Guy ₱5,000,000 actual damages, ₱5,000,000 moral damages, and ₱211,200 attorney’s fees.
- Respondents appealed to the Court of Appeals (CA), which on August 30, 2013 affirmed the conviction, reduced moral damages to ₱500,000, and added ₱500,000 exemplary damages.
- On reconsideration, the CA in its June 13, 2014 Amended Decision deleted actual and exemplary damages, reinstated moral damages at ₱500,000, and retained attorney’s fees of ₱211,200.
- Guy filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court, seeking reinstatement of the RTC awards.
Issues
- Whether there is sufficient factual b