G.R. No. 135306 ; January 28, 2003
MVRS PUBLICATIONS, INC., MARS C. LACONSAY, MYLA C. AGUJA and AGUSTINO G. BINEGAS, JR., petitioners, vs. ISLAMIC DA’WAH COUNCIL OF THE PHILIPPINES, INC., ABDULRAHMAN R.T. LINZAG, IBRAHIM F.P. ARCILLA, ABDUL RASHID DE GUZMAN, AL-FARED DA SILVA and IBRAHIM B.A. JUNIO, respondents.

FACTS

Respondents, the Islamic Da’wah Council of the Philippines, Inc. (a federation of Muslim religious organizations) and individual Muslims, filed a complaint for damages against petitioners (MVRS Publications, Inc., publisher of the Bulgar tabloid, and its officers) arising from an article published in the August 1, 1992 issue. The article stated that Muslims in Mindanao do not eat pigs or any kind of animal, consider them sacred, make them their God, and worship them especially during Ramadan. The complaint alleged the statement was libelous, published with intent to hurt feelings, cast insult, and disparage Muslims and Islam. Petitioners defended that the article did not specifically identify the respondents and was a mere expression of opinion published without malice. The Regional Trial Court dismissed the complaint, ruling the plaintiffs were not specifically identified and the defamatory remarks applied to a large collectivity of Muslims, making it difficult for an individual member to prove the remarks applied to him. The Court of Appeals reversed, holding the defamation was directed at all adherents of Islam, applied to the plaintiff-appellants who are Muslims, and the suit was a proper class suit.

ISSUE

1. Whether the elements of libel are present, specifically whether the published article defamed the respondents.
2. Whether the respondents have the right to institute a class suit.
3. Whether petitioners are liable for moral damages, exemplary damages, attorney’s fees, and costs of suit.

RULING

1. No, the elements of libel are not present. The Supreme Court held that defamation requires the injuring of a person’s character, fame, or reputation through false and malicious statements. Words which are merely insulting and directed at a large class of people are not actionable as libel per se, absent an allegation of special damages. Declarations about a large class cannot be interpreted to advert to an identified or identifiable individual. The article referred to Muslims in general, a class of over five million people with diverse reputations. There was no fairly identifiable person injured. The Court cited precedents, including Newsweek, Inc. v. Intermediate Appellate Court, where a class action by sugarcane planters was dismissed for lack of a specific reference to any of them. The rule on group libel is restrictive; defamation of a large group does not give an individual a cause of action unless he is the specific target. The Court also referenced foreign jurisprudence indicating no action lies for defamation of an extensive religious community.
2. No, the respondents cannot institute a class suit. For a class suit to prosper, the parties must have a common or general interest in the subject matter. The Court ruled that individual Muslims have personal, separate, and distinct reputations. They do not share a single common reputation that would give them a common or general interest in the controversy. Therefore, they do not have a cause of action in common with the class they purport to represent.
3. No, petitioners are not liable for damages. Since no cause of action for libel exists and the class suit is improper, the claim for moral damages, exemplary damages, attorney’s fees, and costs of suit necessarily fails. The decision of the Court of Appeals was reversed, and the decision of the Regional Trial Court dismissing the complaint was reinstated.