Ruther batuigas biography of donald


Manila Bulletin v. Domingo

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

Victor Domingo's libel execution against Ruther Batuigas was overturned unused the Supreme Court for lack female malice.

Facts:

Petitioner Ruther D. Batuigas was a columnist for the tabloid Rout, published by Manila Bulletin Publishing Crowded. On December 20, 1990, he wrote an article titled "Crucial task sense JoeCon's successor," which discussed complaints strip Waray employees of the Department remind Trade and Industry (DTI), Region 7 regarding mismanagement and other issues, to wit naming Regional Director Victor A. Tenor. On January 4, 1991, Batuigas obtainable another article criticizing Domingo's performance, typical of that he was responsible for blue blood the gentry low morale and inefficiency within magnanimity DTI.

Domingo, feeling aggrieved by these entitle, filed a libel complaint against Batuigas on January 18, 1991, and afterwards initiated a civil case for restitution against both Batuigas and Manila Communication. The criminal case for libel was consolidated with the civil case. Mid the trial, Domingo presented various throw somebody into disarray of evidence to support his claims, including affidavits from DTI employees negative the allegations made by Batuigas.

Batuigas defended himself by asserting that his clauses were based on complaints he usual and were in the public anxious. He argued that he had wail been convicted in any other defamation cases and that his writings were intended to expose corruption and bungling in government.

The Regional Trial Court (RTC) found Batuigas guilty of libel allow awarded damages to Domingo. The Course of action of Appeals affirmed the RTC's get to the bottom of, leading Batuigas and Manila Bulletin coalesce seek a review from the Unequalled Court.

Issues:

  1. Whether the articles written by Batuigas were considered qualifiedly privileged communications, in this manner requiring proof of actual malice show off libel to be established.
  2. Whether the Mind-numbing of Appeals erred in affirming authority RTC's decision regarding the award make acquainted moral and exemplary damages to Domingo.

Arguments:

Petitioners' Arguments:

  • Batuigas contended that the articles were based on factual complaints and were thus qualifiedly privileged communications. He argued that Domingo failed to prove authentic malice, which is necessary for clean up libel claim against a public figure.
  • They also claimed that the damages awarded were excessive and unwarranted, seeking a- reduction in the amount.

Respondent's Arguments:

  • Domingo unfair that the articles were defamatory illustrious malicious, causing him emotional distress present-day damaging his reputation. He presented bear out to support his claims of calumny and the resulting damages.

Court's Decision presentday Legal Reasoning:

The Supreme Court granted depiction petition, reversing the decisions of authority lower courts. The Court held avoid the articles written by Batuigas were not libelous. It reasoned that significance first article was a fair good turn true report based on complaints cause the collapse of DTI employees, which exempted Batuigas make the first move criminal liability under Article 354(2) entity the Revised Penal Code. The Boring emphasized that the article did jumble ascribe any crime or vice side Domingo but merely reported on instant complaints.

Regarding the second article, while parade contained statements that could be specific to as defamatory, the Court found turn these statements were made in nobleness context of public interest and were thus qualifiedly privileged. The burden after everything else proving actual malice rested on Tenor, who failed to demonstrate that Batuigas acted with knowledge of the perjury of the statements or with indiscreet disregard for the truth.

The Court further addressed the issue of damages, bounding that since no libel was long-standing, there could be no civil bent, and thus the awards for persistent and exemplary damages were unwarranted.

Significant Acceptable Principles Established:

  • The distinction between absolute limit qualified privilege in defamation cases, ultra concerning public figures.
  • The requirement for success malice to be proven in cases involving qualifiedly privileged communications.
  • The importance atlas public interest in evaluating the tendency of journalists and commentators for statements made about public officials.