G.R. No. 184315; November 28, 2011
ALFONSO T. YUCHENGCO, Petitioner, vs. THE MANILA CHRONICLE PUBLISHING CORPORATION, NOEL CABRERA, GERRY ZARAGOZA, DONNA GATDULA, RODNEY P. DIOLA, RAUL VALINO, THELMA SAN JUAN and ROBERT COYIUTO, JR., Respondents.

FACTS

The controversy arose in the last quarter of 1993 when several allegedly defamatory articles against petitioner Alfonso T. Yuchengco were published in The Manila Chronicle by respondent The Manila Chronicle Publishing Corporation. Petitioner filed a complaint before the Regional Trial Court (RTC) of Makati against the respondents under three causes of action: (1) for damages due to libelous publication against the editorial staff and writers and the publishing corporation; (2) for damages due to abuse of right against Robert Coyiuto, Jr. and the publishing corporation; and (3) for attorney’s fees and costs against all respondents. The RTC rendered a decision in favor of the petitioner on November 8, 2002. The Court of Appeals (CA) initially affirmed the RTC decision in toto on March 18, 2008, but later reversed itself in an Amended Decision on August 28, 2008. Petitioner elevated the case to the Supreme Court, which rendered a Decision on November 25, 2009, partially granting the petition. Respondents filed a Motion for Reconsideration, which was initially denied on March 3, 2010, but the denial was later recalled. Respondent Robert Coyiuto, Jr. filed a Supplemental Motion for Reconsideration, arguing that he was sued only for “abuse of right” in his personal capacity and not for libel, and that there was no evidence to prove he was the Chairman, principal owner, or officer of the publishing corporation. The Supreme Court noted that Coyiuto, Jr. had admitted in his Reply and Comment on Request for Admission that he was the Chairman of the Board of Manila Chronicle Publishing Corporation during the period the articles were published.

ISSUE

The primary issue for resolution in the Motion for Reconsideration and Supplemental Motion for Reconsideration is whether the Supreme Court’s Decision dated November 25, 2009, should be reconsidered, particularly with respect to the liability of respondent Robert Coyiuto, Jr. and the award of damages.

RULING

The Supreme Court denied the motions for reconsideration. It held that the Motion for Reconsideration generally restated arguments already passed upon and presented no substantial new reasons. Regarding the Supplemental Motion, the Court found that the new matter raised by Coyiuto, Jr.—challenging his status as Chairman and his liability—was without merit. The Court affirmed that it was substantially established, and even admitted by Coyiuto, Jr. himself, that he was the Chairman of the Board of Manila Chronicle Publishing Corporation when the subject articles were published. The factual findings of the trial court, as adopted by the CA, are binding and conclusive. The Court found no reason to depart from these findings, as none of the exceptions to the rule on factual review applied. Consequently, the Court upheld its previous decision, including the award of damages. The Court emphasized that the burden of proof rests on the party asserting a fact, and in this case, the petitioner’s allegations regarding Coyiuto, Jr.’s role were substantiated by his own admission.