FACTS:

On September 30, 1990, the People's Journal published a news article alleging that Francis Thoenen had shot the pets of his neighbors. Thoenen filed a civil case for damages against the petitioners, claiming that the article was false and defamatory. The petitioners admitted publishing the article but stated it was done in good faith and without malice. The article was based on a letter by Atty. Efren Angara, which requested verification of Thoenen's residency status and complained about his alleged actions. It was proven at trial that the article contained inaccuracies and no complaints against Thoenen had been lodged. Thoenen also submitted a certification that Atty. Angara was not a lawyer. The petitioners claimed to have sought confirmation from their correspondent and an anonymous woman, but did not present them in court. The Regional Trial Court ruled in favor of the petitioners.

This case involves a news article published in the People's Journal that allegedly contained defamatory statements against Francis Thoenen. The trial court dismissed the complaint, finding no malice on the part of the petitioners. However, the Court of Appeals reversed the decision, holding that the publication violated the principle of abuse of right. The appellate court awarded damages and legal fees to Thoenen. The petitioners filed a motion for reconsideration, which was denied. They then filed a petition before the Supreme Court, arguing that the article was based on a privileged communication and that the damages awarded were excessive. The main issue in this case is whether the petitioners are liable for libel and whether freedom of speech and of the press applies.

ISSUES:

1. Whether the constitutional privilege of freedom of speech and the press extends to the petitioners.

2. Whether the publication in question constitutes libel.

3. Whether the element of malice is present in the publication.

4. Whether the petitioners' story is a privileged communication.

5. Whether the news article is a fair and true report without any comments or remarks.

6. Whether the petitioners' claim of social and moral duty to inform the public on matters of general interest is valid.

RULING:

1. The constitutional privilege of freedom of speech and the press does not extend to the petitioners in this case.

2. The publication in question constitutes libel as it meets the requisites of being a public and malicious imputation of a crime or defect that tends to cause dishonor or discredit to the person defamed.

3. Malice is presumed in cases of libel, unless the good intention and justifiable motive for making the imputation is shown. In this case, the petitioners failed to prove the absence of malice.

4. The petitioners' story is not a privileged communication as it is neither a private communication nor a fair and true report without any comments or remarks.

5. The news article is not a fair and true report without any comments or remarks as it does not pertain to any judicial, legislative, or other official proceedings.

6. The petitioners' claim of social and moral duty to inform the public on matters of general interest is invalid as the respondent is a private individual and not a public official or public figure.

PRINCIPLES:

• The freedom of speech and of the press is not an absolute right and does not extend to all types of speech.

• Libel is not protected speech and is punishable under the Revised Penal Code.

• For an imputation to be considered libelous, the requisites of a discreditable act or condition, publication, identity of the person defamed, and malice must be present.

• Malice is presumed in cases of libel, unless good intention and justifiable motive is proven.

• Privileged communication may be absolute or qualified, with qualified privileged communications not being actionable unless made without good intention or justifiable motive.

• Private communication is privileged if made bona fide upon any subject matter in which the party communicating has an interest or duty, and made to a person having a corresponding interest or duty.

• Fair and true reports without any comments or remarks of judicial, legislative, or other official proceedings are privileged.

• Fair commentaries on matters of public interest are privileged, but such privilege does not extend to false allegations of fact or comments based on false suppositions.

• Newspapers or broadcasters may not claim a constitutional privilege against liability for injury inflicted when publishing defamatory falsehoods about an individual who is neither a public official nor a public figure.

• Malice is presumed when an article cannot be considered as privileged communication, and the imputation of libel attaches to the author.

• The publication of falsehoods, especially persistent and unmitigated dissemination of patent lies, does not enjoy constitutional protection.

• The intentional lie or the false statement made with reckless disregard of the truth is not protected by the constitutional right to free speech.

• The legitimate state interest underlying the law of libel is the compensation of individuals for the harm inflicted upon them by defamatory falsehoods.

• The damages in a libel case depend on the facts of the particular case and the sound discretion of the court.

• Appellate courts are more likely to reduce damages for libel than to increase them.