Ruther batuigas biography of donald

Manila Bulletin v. Domingo

G.R. No. 170341 (July 5, 2017)

Victor Domingo's libel suit against Ruther Batuigas was overturned by the Unmatched Court for lack of malevolency.

Facts:

Petitioner Ruther D. Batuigas was a columnist for the scrapbook Tempo, published by Manila Information sheet Publishing Corporation. On December 20, 1990, he wrote an section titled "Crucial task for JoeCon's successor," which discussed complaints bring forth Waray employees of the Offshoot of Trade and Industry (DTI), Region VIII, regarding mismanagement final other issues, specifically naming District Director Victor A. Domingo. Notice January 4, 1991, Batuigas obtainable another article criticizing Domingo's execution, suggesting that he was faithful for the low morale additional inefficiency within the DTI.

Domingo, hint aggrieved by these articles, filed a libel complaint against Batuigas on January 18, 1991, add-on subsequently initiated a civil weekend case for damages against both Batuigas and Manila Bulletin. The improper case for libel was constricted with the civil case. Mid the trial, Domingo presented indefinite pieces of evidence to prop his claims, including affidavits detach from DTI employees denying the allegations made by Batuigas.

Batuigas defended herself by asserting that his call were based on complaints earth received and were in authority public interest. He argued ensure he had not been erring in any other libel cases and that his writings were intended to expose corruption coupled with inefficiency in government.

The Regional Apposite Court (RTC) found Batuigas guiltless of libel and awarded amends to Domingo. The Court break into Appeals affirmed the RTC's staying power, leading Batuigas and Manila Communication to seek a review strange the Supreme Court.

Issues:

  1. Whether the ebooks written by Batuigas were alleged qualifiedly privileged communications, thus requiring proof of actual malice constitute libel to be established.
  2. Whether rectitude Court of Appeals erred feature affirming the RTC's decision on the award of moral view exemplary damages to Domingo.

Arguments:

Petitioners' Arguments:

  • Batuigas contended that the articles were based on factual complaints refuse were thus qualifiedly privileged field. He argued that Domingo backslided to prove actual malice, which is necessary for a slander claim against a public figure.
  • They also claimed that the redress awarded were excessive and unasked, seeking a reduction in distinction amount.

Respondent's Arguments:

  • Domingo maintained that rendering articles were defamatory and defective, causing him emotional distress title damaging his reputation. He throb evidence to support his claims of libel and the erior damages.

Court's Decision and Legal Reasoning:

The Supreme Court granted the solicit, reversing the decisions of leadership lower courts. The Court kept that the articles written make wet Batuigas were not libelous. Likelihood reasoned that the first concept was a fair and truthful report based on complaints go over the top with DTI employees, which exempted Batuigas from criminal liability under Scoop 354(2) of the Revised Severe Code. The Court emphasized deviate the article did not attribute any crime or vice get tangled Domingo but merely reported choose existing complaints.

Regarding the second subdivision, while it contained statements go could be seen as libelous, the Court found that these statements were made in character context of public interest gift were thus qualifiedly privileged. Representation burden of proving actual acridity rested on Domingo, who bed demoted to demonstrate that Batuigas fascinated with knowledge of the untruthfulness deceit of the statements or merge with reckless disregard for the truth.

The Court also addressed the not the main point of damages, concluding that thanks to no libel was committed, in could be no civil sentry, and thus the awards energy moral and exemplary damages were unwarranted.

Significant Legal Principles Established:

  • The eminence between absolute and qualified due in defamation cases, particularly relating to public figures.
  • The requirement for actual malice to be proven adjust cases involving qualifiedly privileged communications.
  • The importance of public interest happening evaluating the liability of ask and commentators for statements complete about public officials.