Case Summary (G.R. No. 193276)
Petitioners
Nova Communications, Inc.; Angelina G. Goloy (News Editor); Yen Makabenta (Associate Publisher and Editor-in-Chief); Ma. Socorro Naguit (Associate Editor).
Respondents
Atty. Reuben R. Canoy and Solona T. Canoy.
Key Dates
• October 7–13, 1990 – Publication of four articles in Philippine Daily Globe and Philippine Free Press.
• March 8, 2005 – RTC decision awarding damages to the Canoys.
• January 28, 2010 – CA decision affirming with modification the RTC award.
• June 26, 2019 – Supreme Court decision on the Petition for Review on Certiorari.
Applicable Law
• 1987 Constitution – protection of freedom of speech and of the press.
• Revised Penal Code, Articles 353 (definition of libel) and 354 (privileged communications).
• Civil Code, Articles 2208 (allowing attorney’s fees and litigation expenses), 2219(7) (moral damages for libel), 2229 (exemplary damages).
• New Civil Code, Article 33 (civil action for defamation proceeds independently of criminal action).
Facts of the Case
In October 1990, amid Col. Noble’s Mindanao revolt, Philippine Free Press and Philippine Daily Globe published articles characterizing Atty. Canoy as a “veritable mental asylum patient,” “madman,” and “lunatic.” These statements appeared alongside coverage of the rebellion, attributing to Canoy leadership of a federalist/secessionist fringe. The Canoys filed a civil action for libel, seeking damages for injury to reputation.
Procedural History
The RTC found the publications malicious and awarded the Canoys P950,000 plus litigation expenses and attorney’s fees. On appeal, the CA reduced moral damages to P300,000, exemplary damages to P50,000, attorney’s fees to P100,000, and litigation expenses to P20,000. Petitioners challenged the CA ruling before the Supreme Court.
Issues
- Whether the published articles constitute libel.
- Whether the articles are protected by qualified privilege or as fair comment on matters of public interest.
- Whether Atty. Canoy proved actual malice.
- Whether Solona Canoy has a cause of action.
Definition of Libel
Libel under Article 353, RPC, is a public and malicious imputation of a defect or vice tending to cause dishonor, discredit, or contempt. Civil liability may be pursued independently of criminal libel, requiring only a preponderance of evidence.
Construction and Defamatory Meaning
Defamatory words must be taken in their plain, natural, and ordinary sense. Describing Canoy as a mental patient and lunatic, absent proof of mental illness, imputes a discreditable condition. Such imputations are libelous per se and, under Article 354, presumed malicious unless shown privileged.
Privileged Communications and Fair Comment
Absolutely privileged communications (e.g., official legislative debates) and qualifiedly privileged communications (e.g., fair and true reports without comment) do not apply here. The articles contained editorial remarks; they are neither private communications in discharge of duty nor fair reports.
Fair comment on matters of public interest is a recognized privilege, but only when remarks are opinion based on established facts or reasonable inferences. The disparaging references to Canoy’s mental condition were irrelevant to the public interest in reporting the rebellion and were unsupported by verified intelligence. Accordingly, the fair comment doctrine does not shield the publications.
Presumption and Proof of Malice
Because the statements are unprivileged, malice is presumed. Petitioners’ good-faith intent to protect state security does n
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Facts of the Case
- In 1990, Col. Alexander Noble led a rebellion in Mindanao; Atty. Reuben R. Canoy was suspected to be one of his supporters due to his involvement with the Independent Mindanao Movement.
- On October 7, 9, 11 and 13, 1990, articles by Teodoro Locsin Jr. and Louise Molina were published in the Philippine Daily Globe and Philippine Free Press, containing excerpts describing Atty. Canoy as a “veritable mental asylum patient,” “madman,” and “lunatic.”
- Petitioners Nova Communications, Inc. (publisher of the Daily Globe), Angelina G. Goloy (News Editor), Yen Makabenta (Associate Publisher and Editor-in-Chief), and Ma. Socorro Naguit (Associate Editor) were responsible for the publication of the contested excerpts.
- Atty. Canoy and his wife, Solona T. Canoy, filed Civil Case No. 91-003 for damages, alleging that the articles were libelous, malicious, and intended to humiliate and ridicule them.
Procedural History
- RTC Decision (March 8, 2005): Found petitioners and other defendants (except Benjamin Ramos) liable; awarded P50,000 for litigation expenses, P500,000 moral damages, P100,000 exemplary damages, and P300,000 attorney’s fees.
- CA Decision (January 28, 2010): Affirmed with modification; reduced awards to P20,000 litigation expenses, P300,000 moral damages, P50,000 exemplary damages, and P100,000 attorney’s fees.
- Petition for Review on Certiorari filed before the Supreme Court (G.R. No. 193276, June 26, 2019 decision).
Petitioners’ Arguments
- The alleged defamatory words targeted Atty. Canoy’s involvement in the rebellion, not his mental condition.
- The articles addressed a threat to state security, and the language must be understood in that context.
- Publications were qualifiedly privileged communications made in good faith and pursuant to the press’s duty to inform the publi