G.R. No. L-8227; March 9, 1914
ANTONIO M. JIMENEZ, plaintiff-appellant, vs. FIDEL REYES, defendant-appellee.

FACTS:
Antonio M. Jimenez, a lawyer, druggist, and municipal councilor of Vigan, Ilocos Sur, filed a civil action for libel against Fidel Reyes, the editor and proprietor of the weekly newspaper “El Mensajero Catolico.” The complaint centered on an article published on August 29, 1910, entitled “Father Thompkins Acquitted,” which commented on the acquittal of a priest in a case where Jimenez had acted as the prosecuting attorney. The plaintiff alleged that the last sentence of the article, referring to “certain miserable creatures who have used their profession to deceive the unwary public and encompass its ruin,” was defamatory and pointed to him. Following the filing of the complaint, the defendant published a second article on September 5, 1910, titled “Our Editor Again in the Courts of Justice,” which purported to explain the first article. This second publication, while claiming no reference to Jimenez, contained satirical and ridiculing remarks about his professions and personal life, and reproduced the first article in full. The trial court ruled in favor of the defendant, awarding no damages to the plaintiff.

ISSUE:
Whether the published articles are libelous per se, and if so, what damages should be awarded to the plaintiff.

RULING:
The Supreme Court reversed the trial court’s decision. The Court held that both articles were libelous per se. The language used was plain, unambiguous, and of common import, requiring no extrinsic evidence for interpretation. The first article, by fair inference, imputed dishonest and deceitful professional conduct to the plaintiff as the attorney in the Thompkins case. The second article, far from being a retraction, was a sham explanation that compounded the libel through satirical and contemptuous commentary, thereby demonstrating express malice and ill-will.

The Court awarded compensatory damages for injury to the plaintiff’s feelings and reputation in the amount of P300. Furthermore, due to the defendant’s evident malicedemonstrated by the republication of the libel in the second article, the refusal to make a genuine retraction, and the acrimonious conduct during trialthe Court awarded exemplary damages in the amount of P200. The total damages awarded to the plaintiff amounted to P500. No costs were awarded.