G.R. No. L-26526. May 27, 1974
GAUDENCIO E. ANTONINO, substituted by MAGNOLIA W. ANTONINO, administratrix of his estate, plaintiff-appellee, vs. BRIGIDO R. VALENCIA, defendant-appellant.

FACTS

This case originated from political rivalry following the November 1963 local elections in Davao. Plaintiff Senator Gaudencio E. Antonino, head of the Liberal Party (LP) in the province, publicly attributed the LP gubernatorial candidate’s loss to the alleged “sabotage” and “double-crossing” by defendant Secretary of Public Works and Communications Brigido R. Valencia, who supported an independent LP candidate. The ensuing strain led Senator Antonino, while convalescing from a heart attack, to file formal administrative charges on February 28, 1964, with the Senate Blue Ribbon Committee, requesting an investigation of four specified alleged anomalous transactions under Secretary Valencia’s department. Copies were furnished to the Commission on Appointments.
On March 5, 1964, a press release issued from the Office of the Secretary of Public Works and Communications was published in major metropolitan newspapers. The release contained severe personal attacks against Senator Antonino, including statements that he told lies, was driven by “personal selfish reasons,” abused his power as Senator and Monetary Board member, had “suspicious connections” with numerous corporations, and was involved in “high anomalous activities.” Senator Antonino subsequently filed a civil action for damages based on libel.

ISSUE

The core issue was whether defendant-appellant Brigido R. Valencia was civilly liable for the libelous press release and whether his defenses of qualified privilege and defensive libel were valid.

RULING

The Supreme Court affirmed the trial court’s decision in toto, holding defendant liable for libel and rejecting his defenses. On the factual question, the Court sustained the trial court’s finding that the press release was indisputably issued or caused by the defendant in his capacity as Department Secretary, as it originated from his office and bore the hallmarks of an official statement. The Court agreed the imputations were defamatory, as they imputed dishonorable conduct and crimes to the plaintiff, calculated to induce public suspicion and destroy his reputation.
Legally, the Court upheld the rejection of the defense of qualified privilege under Article 354 of the Revised Penal Code. For a communication to be privileged, it must be a fair and true report of an official proceeding made in good faith without comments. The press release was not a fair report but a retaliatory commentary containing malicious insinuations and accusations made outside of any official proceeding. The Court also rejected the defense of “defensive libel,” finding no basis to hold plaintiff liable for his prior charges, which were themselves qualifiedly privileged communications made in the performance of a civic duty to an official investigative body. The defendant’s response, via a widespread press release, was disproportionate and malicious, not a protected form of self-defense. Consequently, the award of moral damages, interest, and attorney’s fees was affirmed.