G.R. No. L-11052; April 30, 1958
MILAGROS TEJUCO, plaintiff-appellant, vs. E. R. SQUIBB and SON PHILIPPINE CORPORATION, ET AL., defendants-appellees.

FACTS

The plaintiff-appellant, Milagros Tejuco, filed a civil complaint in the Court of First Instance of Manila against her former employers, the defendants-appellees. She alleged that the appellees wrote her a libelous letter of separation, a copy of which was posted on the company’s bulletin board on October 18, 1954. She prayed for damages and for the appellees to retract the letter and give the retraction publicity. The appellees moved to dismiss the complaint on the ground of prescription. The trial court granted the motion and dismissed the complaint. The appellant’s motion for reconsideration was denied, prompting this appeal. The appellant admits the complaint was filed one year and six months after the publication of the libelous letter.

ISSUE

What is the prescriptive period for a civil action arising from libel?

RULING

The prescriptive period for a civil action arising from libel is one year. The Court ruled that civil obligations resulting from criminal offenses, such as libel under Articles 353, 355, and 360 of the Revised Penal Code, are governed by penal laws, subject to certain provisions of the Civil Code. Article 112 of the Revised Penal Code states that civil liability from felonies is extinguished in the same manner as other obligations under civil law. Article 1147 of the Civil Code requires that an action for defamation must be filed within one year. The Court held that the broad term “defamation” includes libel. Since the complaint was filed one year and six months after the publication, it had prescribed. The order of dismissal was affirmed.