G.R. No. 242577 , February 26, 2020
Rico V. Domingo, Petitioner, v. Ramon Gil Macapagal, Respondent.

FACTS

Petitioner Rico V. Domingo, sole proprietor of R.V. Domingo and Associates Law Firm, filed a criminal complaint for Libel against respondent Ramon Gil S. Macapagal, Vice President for Corporate Affairs and Sustainability of Unilever Philippines, Inc. (ULP). The case stemmed from an email dated October 25, 2013, sent by respondent’s executive assistant, stating that petitioner’s law firm was “overcharging ULP” by billing P6,500.00 for appearance fees and per diems instead of the P4,000.00 rate under a 2001 retainership agreement. Petitioner replied, prompting a follow-up letter from respondent dated October 30, 2013, which questioned the basis for the increased fees, asked if the amendment was signed by ULP officers, and stated that the issue had “adversely affecting our lawyer-client relationship.”
The Office of the City Prosecutor (OCP)-Quezon City initially dismissed the complaint for lack of probable cause but later reversed itself upon petitioner’s motion for reconsideration and filed an Information for Libel. The Regional Trial Court (RTC) initially found probable cause for a warrant of arrest but, upon respondent’s motion for reconsideration, dismissed the Information. Petitioner appealed to the Court of Appeals (CA). Meanwhile, the Department of Justice (DOJ) granted respondent’s petition and reversed the OCP’s finding of probable cause, directing the withdrawal of the Information. The CA initially annulled the RTC’s dismissal orders but later issued an Amended Decision reinstating them, dismissing petitioner’s appeal.

ISSUE

1. Whether the RTC judge committed grave abuse of discretion in dismissing the Libel case against respondent.
2. Whether respondent is guilty of Libel for the contents of the email and letter.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Amended Decision of the Court of Appeals.
1. The RTC judge did not commit grave abuse of discretion. The Court held that a judge has the inherent power to reverse or amend its own orders to conform to law and justice. The RTC’s Order of dismissal dated March 7, 2016, was effectively a judgment on the merits and amounts to res judicata. The judge acted within her authority in reviewing the case and determining the absence of probable cause.
2. Respondent is not guilty of Libel. The Court found that while the words used in the email and letter were “a bit infelicitous or impolitic, they were by no means scurrilous, vituperative, insulting, or opprobrious or abusive.” The communications pertained to a legitimate billing dispute between a lawyer and his client, and the statements did not constitute defamatory imputation made with malice.