G.R. No.

164437
HECTOR C. VILLANUEVA, Petitioner,
- versus -
PHILIPPINE DAILY INQUIRER, INC., LETTY JIMENEZ MAGSANOC,ROSAURO
G. ACOSTA, JOSE MARIA NOLASCO, ARTEMIO T. ENGRACIA, JR., RAFAEL
CHEEKEE, and MANILA DAILY BULLETIN PUBLISHING CORPORATION, NAPOLEON
G. RAMA, BEN F. RODRIGUEZ, ARTHUR S. SALES, CRIS J. ICBAN, JR.,
Respondents.
May 15, 2009
DOCTRINE: Consistent with good faith, reasonable care and the constitutional
guarantee of freedom of the press, the press should not be held to account, to a point of
suppression, for honest mistakes or imperfections in the choice of language. There
must be some room for misstatement of fact as well as for misjudgment. Only by giving
them much leeway and tolerance can they courageously and efectively function as
critical agencies in our democracy. A newspaper, especially one national in reach and
coverage, should be free to report on events and developments in which the public has a
legitimate interest with minimum fear of being hauled to court by one group or another
on criminal or civil charges for malice or damages, i.e. libel, so long as the newspaper
respects and keeps within the standards of morality and civility prevailing within the
general community.
For liability in libel cases to arise without ofending press freedom, there
is this test to meet: "The constitutional guarantees require, we think, a federal rule that
prohibits a public ofcial from recovering damages for a defamatory falsehood relating
to his ofcial conduct unless he proves that the statement was made with actual
malice that is, with knowledge that it was false or with reckless disregard of whether
it was false or not." There can be no presumption of actual malice on privileged
communication, thus it must be sufciently proved. Fair commentaries on matters of
public interest are privileged communication and constitute a valid defense in an action
for libel or slander for as such, no malice can be aptly be presumed on them. The
instant articles of the case dealt with matters of public interest. These are matters
about which the public has the right to be informed, taking into account the very public
character of the election itself. For this reason, they attracted media mileage and drew
public attention not only to the election itself but to the candidates. Thus, no malice
may be imputed on these articles for the action of libel to stand, it must be sufciently
proved.
FACTS:
Petitioner was one of the mayoralty candidates in Bais, Negros Oriental during
the May 11, 1992 elections.
On March 30, 1990, Ricardo Nolan, another mayoralty candidate, petitioned for
the disqualifcation of petitioner from running in the elections. Said petition, however,
was denied by the COMELEC.
Two days before the elections, or on May 9, 1992, respondent Manila Daily
Bulletin Publishing Corporation (Manila Bulletin) published the following story:
The Comelec has disqualifed Hector G. Villanueva as Lakas-
NUCD candidate for mayor of Bais City for having been convicted in
three administrative cases for grave abuse of authority and harassment
in 1987, while he was ofcer-in-charge of the mayors ofce of Bais City.
A day before the elections or on May 10, 1992, respondent Philippine Daily
Inquirer, Inc. (PDI) also came out with a similar story, to wit:
The Commission on Elections disqualifed Hector G.
Villanueva as Lakas-NUCD candidate for mayor of Bais City for
having been convicted in three administrative cases for grave abuse
of authority and harassment in 1987, while he was the ofcer-in-
charge of the mayors ofce in the city.
On May 11, 1992, the national and local elections were held as
scheduled. When results came out, it turned out that petitioner failed in his mayoralty
bid.
Believing that his defeat was caused by the publication of the above-quoted
stories, petitioner sued respondents PDI and Manila Bulletin as well as their publishers
and editors for damages before the RTC of Bais City. He alleged that the articles were
maliciously timed to defeat him. He claimed he should have won by landslide, but his
supporters reportedly believed the news items distributed by his rivals and voted for
other candidates. He asked for actual damages of P270,000 for the amount he spent for
the campaign, moral damages of P10,000,000, an unspecifed amount of exemplary
damages, attorneys fees of P300,000 and costs of suit.
ISSUE: Whether or not Manila Bulletin and Philippine Daily Inquirer are liable for
damages or libel for the published article.
RULING: NO
For liability in libel cases to arise without ofending press freedom, there is this
test to meet: "The constitutional guarantees require, we think, a federal rule that
prohibits a public ofcial from recovering damages for a defamatory falsehood relating
to his ofcial conduct unless he proves that the statement was made with actual
malice that is, with knowledge that it was false or with reckless disregard of whether
it was false or not." Fair commentaries on matters of public interest are privileged
communication and constitute a valid defense in an action for libel or slander for as
such, no malice can be aptly be presumed on them. The rule on privileged
communication had its genesis not in the nations penal code but in the Bill of Rights of
the Constitution guaranteeing freedom of speech and of the press. As early as 1918,
in United States v. Caete, this Court ruled that publications which are privileged for
reasons of public policy are protected by the constitutional guaranty of freedom of
speech.
In the instant case, there is no denying that the questioned articles dealt with
matters of public interest. These are matters about which the public has the right to be
informed, taking into account the very public character of the election itself. For this
reason, they attracted media mileage and drew public attention not only to the election
itself but to the candidates.
In the instant case, we fnd no conclusive showing that the published articles in
question were written with knowledge that these were false or in reckless disregard of
what was false or not.
Nevertheless, even assuming that the contents of the articles turned out to be
false, mere error, inaccuracy or even falsity alone does not prove actual malice. Errors
or misstatements are inevitable in any scheme of truly free expression and
debate. Consistent with good faith and reasonable care, the press should not be held to
account, to a point of suppression, for honest mistakes or imperfections in the choice of
language. There must be some room for misstatement of fact as well as for
misjudgment. Only by giving them much leeway and tolerance can they courageously
and efectively function as critical agencies in our democracy.
A newspaper, especially one national in reach and coverage, should be free to
report on events and developments in which the public has a legitimate interest with
minimum fear of being hauled to court by one group or another on criminal or civil
charges for malice or damages, i.e. libel, so long as the newspaper respects and keeps
within the standards of morality and civility prevailing within the general community.
As aptly observed in Quisumbing v. Lopez, et al.:
Every citizen of course has the right to enjoy a good name and
reputation, but we do not consider that the respondents, under the
circumstances of this case, had violated said right or abused the
freedom of the press. The newspapers should be given such leeway
and tolerance as to enable them to courageously and efectively
perform their important role in our democracy. In the preparation
of stories, press reporters and edition usually have to race with their
deadlines; and consistently with good faith and reasonable care, they
should not be held to account, to a point of suppression, for
honest mistakes or imperfection in the choice of words.
We fnd respondents entitled to the protection of the rules concerning qualifed
privilege, growing out of constitutional guaranties in our Bill of Rights. We cannot
punish journalists including publishers for an honest endeavor to serve the public when
moved by a sense of civic duty and prodded by their sense of responsibility as news
media to report what they perceived to be a genuine report.