GR 200150; (November, 2016) (Digest)
G.R. No. 200150. November 07, 2016
CATHERINE CHING, LORENZO CHING, LAURENCE CHING, AND CHRISTINE CHING, PETITIONERS, V. QUEZON CITY SPORTS CLUB, INC.; MEMBERS OF THE BOARD OF DIRECTORS, NAMELY: ANTONIO T. CHUA, MARGARET MARY A. RODAS, ALEJANDRO G. YABUT, JR., ROBERT C. GAW, EDGARDO A. HO, ROMULO D. SALES, BIENVENIDO ALANO, AUGUSTO E. OROSA, AND THE FINANCE MANAGER, LOURDES RUTH M. LOPEZ, RESPONDENTS.
FACTS
Respondent Quezon City Sports Club, Inc. (Club) imposed a special assessment of ₱2,500 on its members via Board Resolution to satisfy a final judgment for illegal dismissal against it. Petitioner Catherine Ching, a member, was notified and the amount was debited from her account in monthly installments. Believing the assessment was unjust, she deliberately underpaid her monthly statements by the assessment amount, accumulating an unpaid balance. The Club later passed a resolution suspending the privileges of members who had not paid the assessment. Catherine continued using the Club’s facilities while underpaying. In May 2003, her son Laurence was denied entry at the Club due to the suspension of her membership. Catherine then discovered her name listed in a memorandum posted in the Club identifying her as a suspended member for non-payment.
ISSUE
Whether the respondents are liable for damages for posting Catherine Ching’s name in a memorandum as a suspended member for non-payment of the special assessment.
RULING
No, the respondents are not liable. The Court affirmed the Court of Appeals’ dismissal of the complaint. The legal logic rests on the absence of malice or bad faith required for an actionable defamation under Article 19 of the Civil Code. The posting of the memorandum was a legitimate exercise of the Club’s right to inform its staff of the suspension of a member’s privileges to enforce its internal rules and prevent unauthorized access. The communication was made in good faith, directed only to employees at their workstations for a legitimate business purpose, and was not published to the general membership or public in a manner constituting defamation. The act was not attended by ill will or a malicious intent to injure reputation. Since the factual basis for the suspension—the non-payment of a duly assessed fee—was true, and the act of posting was done in the ordinary course of business, no legal wrong was committed. Consequently, the essential elements for awarding moral and exemplary damages, as well as attorney’s fees, were not present.