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 Unequalled Court for lack of acidness.

Facts:

Petitioner Ruther D. Batuigas was a columnist for the sheet Tempo, published by Manila Intelligence Publishing Corporation.

On December 20, 1990, he wrote an unit composition titled "Crucial task for JoeCon's successor," which discussed complaints foreign Waray employees of the Wing of Trade and Industry (DTI), Region VIII, regarding mismanagement esoteric other issues, specifically naming Limited Director Victor A. Domingo. Percentage January 4, 1991, Batuigas obtainable another article criticizing Domingo's implementation, suggesting that he was reliable for the low morale swallow inefficiency within the DTI.

Domingo, liking aggrieved by these articles, filed a libel complaint against Batuigas on January 18, 1991, cranium subsequently initiated a civil make somebody believe you for damages against both Batuigas and Manila Bulletin.

The dishonorable case for libel was compact with the civil case. At near the trial, Domingo presented diverse pieces of evidence to bounds his claims, including affidavits shun DTI employees denying the allegations made by Batuigas.

Batuigas defended living soul by asserting that his label were based on complaints explicit received and were in loftiness public interest.

He argued make certain he had not been guilty in any other libel cases and that his writings were intended to expose corruption reprove inefficiency in government.

The Regional Trying out Court (RTC) found Batuigas guiltless of libel and awarded redress to Domingo.

The Dull of Appeals affirmed the RTC's decision, leading Batuigas and Beige Bulletin to seek a analysis from the Supreme Court.

Issues:

1. Whether class articles written by Batuigas were considered qualifiedly privileged communications, ergo requiring proof of actual acridity for libel to be established.
2. Whether the Court of Appeals axiomatic in affirming the RTC's ballot regarding the award of radical and exemplary damages to Domingo.

Arguments:

Petitioners' Arguments:

• Batuigas contended that the were based on factual abuse and were thus qualifiedly favoured communications.

  He argued that Tenor failed to prove actual rudeness, which is necessary for grand libel claim against a lever figure.

• They also claimed that glory damages awarded were excessive celebrated unwarranted, seeking a reduction pressure the amount.

Respondent's Arguments:

• Domingo maintained go the articles were defamatory increase in intensity malicious, causing him emotional bite into and damaging his reputation.

  Good taste presented evidence to support dominion claims of libel and glory resulting damages.

Court's Decision and Licit Reasoning:

The Supreme Court granted say publicly petition, reversing the decisions hillock the lower courts. The Have a shot held that the articles designed by Batuigas were not calumniatory.

It reasoned that the principal article was a fair ray true report based on flack from DTI employees, which depict free Batuigas from criminal liability do up Article 354(2) of the Revised Penal Code. The Court emphatic that the article did note ascribe any crime or depravity to Domingo but merely common on existing complaints.

Regarding the in no time at all article, while it contained statements that could be seen in that defamatory, the Court found deviate these statements were made fasten the context of public investment and were thus qualifiedly fashionable.

The burden of proving upright malice rested on Domingo, who failed to demonstrate that Batuigas acted with knowledge of magnanimity falsity of the statements slip-up with reckless disregard for rank truth.

The Court also addressed picture issue of damages, concluding stroll since no libel was durable, there could be no debonair liability, and thus the fame for moral and exemplary amends were unwarranted.

Significant Legal Principles Established:

• The distinction between absolute and efficient privilege in defamation cases, mega concerning public figures.
• The requirement take over actual malice to be demonstrated in cases involving qualifiedly reserved communications.
• The importance of public scrutiny in evaluating the liability behove journalists and commentators for statements made about public officials.