G.R. No. 2033
September 19, 1905
PARTIES:
Plaintiff-Appellee: Rufina Causin
Defendant-Appellant: Fortunato Ricamora
FACTS:
The plaintiff, Rufina Causin, a schoolteacher, filed an action for libel against Fortunato Ricamora, the municipal president of Dumanjug. The case stemmed from an article written by Ricamora in the Visayan language and published in the Cebu newspaper Ang Suga. The article was a response to a prior publication in the same newspaper which stated that Ricamora had arrested and detained Causin for three days.
In his article, Ricamora denied the arrest but made derogatory statements about Causin. He referred to her sarcastically as having been “celebre o famosa” (celebrated or famous) in Iloilo and questioned her reputation. He insinuated that her skill in drawing was aided by a man named E. Lanza. He further described her as a “Santolona” woman (a term implying ferocity or savagery) and detailed allegations that she brutally punished her students by slapping, pinching, and tearing their hair. He called her a hypocrite (“Esta hipocrita Srita.”) and stated she was unworthy of her position.
Following the publication, Causin was discharged from her employment as a teacher. The trial court found in favor of Causin and awarded her damages. Ricamora appealed.
ISSUE:
Whether the published article written by the defendant constitutes libel for which the plaintiff is entitled to recover damages.
RULING:
Yes, the article constitutes libel and the award of damages is proper.
The Supreme Court affirmed the trial court’s decision, with modification as to the currency of the award. The Court held that a simple reading of the article shows it falls within the definition of libel under Section 1 of Act No. 277, as it was calculated to expose the plaintiff to public hatred, contempt, or ridicule.
The Court rejected the appellant’s defense that the publication was justified as a reply to a previous article. The facts that the newspaper manager suggested an answer and that a prior article existed did not justify the defendant in publishing libelous statements against the plaintiff.
The Court found the trial court’s findings of fact to be supported by evidence, specifically:
1. That the plaintiff earned thirty pesos a month as a teacher.
2. That she lost her employment because of the libel, due to both the publicity and the physical and moral suffering it caused, which deprived her of the physical aptitude necessary for her profession.
The Court cited Section 11 of Act No. 277, which allows recovery for actual pecuniary loss, injury to feelings and reputation, and punitive damages. The evidence was deemed ample to support the damages awarded by the trial court.
DISPOSITIVE PORTION:
The judgment of the lower court was MODIFIED to require payment in the equivalent Philippine currency (instead of Mexican pesos) and AFFIRMED as modified. Costs were taxed against the appellant.