ARAFILES VS. PHIL. JOURNALISTS INC., et al.

ARAFILES VS. PHIL. JOURNALISTS INC., et al.

FACTS: About 2 a.m., while respondent Morales, a reporter of People’s Journal Tonight, was at the Western Police District (WPD) Headquarters Emelita Despuig, an employee of the National Institute of Atmospheric Sciences (NIAS), lodged a complaint against petitioner, a NIAS director, for forcible abduction with rape and forcible abduction with attempted rape. Emelita executed a sworn affidavit which was later on written in the police blotter and perused by Morales. The latter interviewed Emelita. The following day, the article appeared in the headline of respondent’s newspaper which wrote, GOV’T EXEC RAPES COED. About a year following the publication, petitioner instituted a complaint before the RTC against respondents for damages. Petitioner alleged that because of the article, his reputation was injured. Respondent answered that his write-up was protected by the constitution on freedom of the press. RTC ruled in favor of petitioner.

ISSSUE: W/N the CA erred in holding that the publication of the news item was not attended with malice to thus free respondents of liability for damages.

RULING: Petition denied.
In actions for damages for libel, it is axiomatic that the published work alleged to contain libelous material must be examined and viewed as a whole.
Respondents could of course have been more circumspect in their choice of words as the headline and first seven paragraphs of the news item give the impression that a certain director of the NIAS actually committed the crimes complained of by Emelita. The succeeding paragraphs sufficiently convey to the readers, however, that the narration of events was only an account of what Emelita had reported at the police headquarters.
Every citizen of course has the right to enjoy a good name and reputation, but we do not consider that the respondents, under the circumstances of this case, had violated said right or abused the freedom of the press. The newspapers should be given such leeway and tolerance as to enable them to courageously and effectively perform their important role in our democracy. In the preparation of stories, press reporters and [editors] usually have to race with their deadlines; and consistently with good faith and reasonable care, they should not be held to account, to a point of suppression, for honest mistakes or imperfection in the choice of words.
*Mia