Case Summary (G.R. No. 229440)
Key Dates
- December 4, 2001: Publication of the front-page article “PCGG: no to coconut levy agreement”
- December 6, 2001: Yorac’s letters denying and demanding correction of attributed statements
- October 30, 2013: RTC Decision finding libel and awarding damages
- August 22, 2016: CA Decision affirming liability but reducing damages
- January 18, 2017: CA Resolution denying reconsideration
- July 14, 2021: Supreme Court Decision granting the petition
Applicable Law
- 1987 Philippine Constitution: Freedom of speech and of the press (Art. III, Sec. 4)
- Revised Penal Code (Articles 353–354): Elements and exceptions for libel
- Rule 45, Rules of Court: Petition for review on certiorari
Facts
- The Inquirer published an article quoting an alleged PCGG statement by Chairperson Yorac, accusing “Marcos cronies,” including Enrile, of keeping “plundered loot” from the coco levy fund.
- Enrile’s counsel sought verification; Yorac issued letters (Dec. 6, 2001) denying authorship and demanded correction, which the Inquirer did not publish before filing suit.
- Enrile filed for damages, alleging defamation by imputing (a) benefit from the coco levy fund, (b) accumulation of ill-gotten wealth, and (c) being a Marcos crony.
- The Inquirer defended on grounds of fair and true report of a public statement and lack of malice.
Procedural History
- RTC: Found all elements of libel present; awarded ₱2 M moral damages, ₱500 K exemplary damages, ₱250 K attorney’s fees.
- CA: Affirmed liability but reduced awards to ₱1 M, ₱200 K, and ₱100 K, respectively.
- SC: Granted Rule 45 petition, reversed the CA and RTC.
Issue
Whether the challenged article was libelous under the 1987 Constitution and the Revised Penal Code, considering (1) imputation of a discreditable act or condition and (2) existence of malice.
Supreme Court’s Ruling
The petition is GRANTED. The CA Decision (Aug. 22, 2016) and Resolution (Jan. 18, 2017) are REVERSED and SET ASIDE.
Reasoning
- Defamation requires: (a) imputation of a discreditable act or condition; (b) publication; (c) identification of the person; (d) malice.
- Imputation: The article merely repeated statements attributed to Yorac (“X said Y”), not assertions by the Inquirer or its reporters. Reading the article in its entirety shows it as a fair—and qualifiedly privileged—report of a public statement, not as the newspaper’s own defamatory claim.
- Qualified privilege: Reports of official acts on matters of public interest are protected from presumed malice. The coco levy fund controversy was of paramount public concern; Enrile is a public figure.
- Malice in fact: Must be proven where qualified privilege applies. Enrile failed to establish actual malice—i.e., knowledge of
Case Syllabus (G.R. No. 229440)
Parties
- Petitioners: Philippine Daily Inquirer, Inc.; authors Donna Cueto and Dona Pazzibugan; Associate Editor Abelardo S. Ulanday; News Editor Artemio T. Engracia, Jr.; Editor-in-Chief Letty Jimenez-Magsanoc
- Respondent: Senator Juan Ponce Enrile
- Nature of action: Civil action for damages for libel
Facts
- On December 4, 2001, the Philippine Daily Inquirer published a front-page article titled “PCGG: no to coconut levy agreement,” co-written by Cueto and Pazzibugan
- The article quoted a public statement allegedly made by PCGG Chairperson Haydee Yorac that the settlement would allow “Marcos cronies,” including Enrile, to keep “plundered loot” and ill-gotten wealth
- Enrile’s counsel wrote to Chairperson Yorac to confirm authorship; Yorac, by letters dated December 6, 2001, denied making or authorizing the statements and demanded correction
- Enrile, through counsel, likewise demanded public apology and retraction from the Inquirer on December 4, 2001, but received no compliance
- On December 10 and 12, 2001, Chairperson Yorac reiterated that no PCGG statement had been issued on December 2, 2001, and that reporters had failed to verify the statement’s authenticity
- Enrile filed a Complaint for Damages alleging the article defamed him by imputing (a) benefit from the coconut levy fund, (b) accumulation of ill-gotten wealth, and (c) status as a Marcos crony
- Petitioners answered that the article was a true and fair report on a matter of public interest and thus privileged, and that no libelous intent or imputation existed
- Cueto testified she wrote the article based on a press statement handed to her by PCGG Commissioner Carranza under deadline pressure, believed it genuine, and did not know of any falsehood at publication
Procedural History
- Regional Trial Court of Makati (Branch 139) Decision dated October 30, 2013:
• Found the article defamatory and published with malice
• Ordered petitioners (except Pazzibugan) to