Filipinas Broadcasting Network, Inc. vs. Ago Medical and Educational Center-Bicol Christian College of Medicine (AMEC-BCCM) and Angelita F. Ago
### Facts:
The case began with “Exposé,” a radio documentary hosted by Carmelo Rima and Hermogenes Alegre on DZRC-AM, owned by Filipinas Broadcasting Network, Inc. (FBNI), airing allegations against AMEC-BCCM and Angelita Ago, its dean. The broadcasts on December 14 and 15, 1989, claimed various complaints about the institution’s policies, lack of accredited courses, and the hiring of morally and physically unfit teachers. AMEC and Ago filed a defamation lawsuit against FBNI, Rima, and Alegre on February 27, 1990. The trial at the Regional Trial Court of Legazpi City resulted in a December 14, 1992, decision finding FBNI and Alegre (but not Rima) liable for libel and ordering them to pay damages and attorney’s fees. Both parties appealed, and the Court of Appeals upheld the trial court decision with modifications, making Rima also liable.
### Issues:
1. Are the broadcasts libelous?
2. Is AMEC entitled to moral damages?
3. Is the award of attorney’s fees proper?
4. Is FBNI solidarily liable with Rima and Alegre for payment of moral damages, attorney’s fees, and costs of suit?
### Court’s Decision:
The Supreme Court denied the petition, affirming the Court of Appeals’ decision with modifications:
1. **Libelous Broadcasts**: The Court agreed the broadcasts were libelous per se, made publicly with imputations that dishonor AMEC, showing reckless disregard for their veracity.
2. **Moral Damages**: AMEC’s claim for moral damages was justified under Article 2219(7) of the Civil Code, allowing a juridical person to claim for libel or defamation. However, the awarded amount was reduced from P300,000 to P150,000.
3. **Attorney’s Fees**: The award for attorney’s fees was deleted due to insufficient justification and evidence to warrant such an award.
4. **Solidary Liability**: FBNI was held solidarily liable with Rima and Alegre, as FBNI failed to prove due diligence in the selection and supervision of its employees. The broadcasts were made within the scope of their employment, lacking evidence of FBNI’s diligence.
### Doctrine – Juridical persons such as corporations can claim for moral damages in defamation cases under Article 2219(7) of the Civil Code. Joint tort feasors, including employers and their employees, are jointly and severally liable for the torts they commit.
### Class Notes:
– **Libel**: Defamation made public imputing a crime, or causing dishonor, discredit, or contempt to a person or entity.
– **Moral Damages for Juridical Persons**: Corporations can claim moral damages for defamation under specific provisions (Article 2219(7) Civil Code).
– **Solidary Liability in Torts**: Employers can be held solidarily liable with their employees for acts done within the scope of their employment unless due diligence in selection and supervision is proven.
– **Proof of Malice**: Presumed in defamatory statements unless good intention and justifiable motive are shown.
### Historical Background:
This case reflects the legal nuances of defamation in the Philippines, particularly concerning public figures and institutions. It underscores the balance between freedom of expression and protecting reputations, emphasizing the responsibilities of media entities in reporting, alongside the legal remedies available to aggrieved parties falsely accused or defamed in public discourse.
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