Case Summary (G.R. No. 130191)
Factual Background
Tejuco filed a civil complaint in the Court of First Instance of Manila, arguing that the respondents had written and publicly posted a defamatory letter about her. In this complaint, she sought damages amounting to P50,000, along with a retraction of the letter and its publicity. The trial court dismissed her complaint based on the grounds of prescription, meaning that the time limit for filing the action had expired.
Dismissal of Complaint
When Tejuco's complaint was dismissed, she filed a motion for reconsideration, which was denied. Subsequently, she appealed the dismissal. It is essential to highlight that Tejuco admitted to filing the complaint one year and six months after the letter was published on October 18, 1954, leading to the focus on the prescriptive period for her defamation claim.
Applicable Law Governing Defamation
The primary legal considerations involved in this case stem from the Revised Penal Code, particularly Articles 353, 355, and 360, which address various aspects of libel. Article 1161 of the Civil Code establishes that civil liabilities resulting from criminal offenses are subject to penal laws, with additional guidance from Articles within the Civil Code concerning obligations and liabilities. Notably, Article 112 of the Revised Penal Code articulates that civil liabilities arising from felonies are extinguished in accordance with the provisions of civil law.
Prescription of Defamation Actions
The issue of prescription is crucial in this case; Article 1129 of the Civil Code specifies that actions prescribe with the mere lapse of time as dictated by law. For defamation cases, Article 1147 of the Civil Code stipulates that the action must be filed within one year. Consequently, this leads to the conclusion that the
...continue readingCase Syllabus (G.R. No. 130191)
Case Overview
- The case involves a civil complaint filed by Milagros Tejuco (the appellant) against her former employers, E. R. Squibb & Son Philippine Corporation, for the alleged publication of a libelous letter of separation.
- The complaint was lodged in the Court of First Instance of Manila, where the appellant sought damages amounting to P50,000, plus interest, and requested a retraction of the letter's contents with due publicity.
- The appellees' motion led to the dismissal of the complaint on the grounds of prescription, prompting the appellant to appeal the decision.
Background of the Case
- The libelous letter in question was posted on the company bulletin board on October 18, 1954.
- The appellant filed her complaint one year and six months after the publication of the letter, raising questions regarding the applicable prescriptive period for filing actions arising from libel.
Legal Issues
- The principal legal issue revolves around t