G.R. No. L-16969; April 30, 1966
R. MARINO CORPUS, plaintiff-appellant, vs. MIGUEL CUADERNO, SR., defendant-appellee.

FACTS

R. Marino Corpus, an employee of the Central Bank of the Philippines, filed a suit for damages against Miguel Cuaderno, Sr., then Governor of the Central Bank. Corpus alleged that Cuaderno maliciously caused his suspension and eventual removal from office through instigated administrative complaints in 1955 and 1958. Corpus claimed Cuaderno acted out of professional jealousy, particularly after Corpus gave congressional testimony contrary to Cuaderno’s. Corpus was suspended in 1955 following an administrative complaint filed by ten bank employees, found guilty on five counts, and penalized with suspension without pay. He was reinstated in 1955 and later appointed Special Assistant to the Governor. In 1958, another administrative complaint was filed by eighteen of his subordinates, leading to his suspension. While the case was pending in the lower court, a committee investigating the 1958 charges found no basis for disciplinary action and recommended reinstatement. However, the Monetary Board, upon Cuaderno’s recommendation and citing loss of confidence, resolved to consider Corpus resigned as of his suspension date. The lower court dismissed Corpus’s complaint and awarded Cuaderno P1,000 in damages on his counterclaim, finding that Corpus had committed libel against Cuaderno. Corpus appealed directly to the Supreme Court.

ISSUE

1. Whether Cuaderno is liable for damages for illegally causing Corpus’s suspension and removal.
2. Whether Corpus committed libel against Cuaderno.

RULING

1. On liability for suspension and removal: The Supreme Court held that Cuaderno was not liable. Corpus’s removal was effected by a resolution of the Monetary Board, which had the sole power to appoint and remove Central Bank officers upon the Governor’s recommendation. The Court, in a related case (G.R. No. L-23721), had already ruled that Corpus’s removal based solely on loss of confidence was illegal and ordered his reinstatement, but found no vindictiveness or wantonness by the Monetary Board. The Court found no evidence that Cuaderno instigated the administrative complaints; the 1955 and 1958 complaints were filed by bank employees, with no proof Cuaderno convinced them to do so. Some charges in the 1955 case were substantiated, negating malice. The Court also rejected Corpus’s claims regarding procedural irregularities, such as the timing of the investigating committee’s creation and the cancellation of his back salary check, finding no malicious involvement by Cuaderno.
2. On libel: The Supreme Court affirmed the lower court’s finding that Corpus committed libel against Cuaderno. During a press interview, Corpus made derogatory statements about a Central Bank official, referring to an “intriguer” who was dismissed by President Quezon and involved with a sugar central. Witnesses, including journalists and bank officials, identified Cuaderno as the person referred to, as Cuaderno had been dismissed from the Philippine National Bank by President Quezon and was associated with the Bataan Sugar Central. The Court held that the description was sufficiently clear to identify Cuaderno, and Corpus’s subsequent lawsuit against Cuaderno confirmed this. The rule in Kunkle vs. Cablenews-American (requiring clear identification to a third person) was inapplicable here, as multiple third persons identified Cuaderno. The Court upheld the P1,000 damages award, denying Cuaderno’s unappealed prayer for an increase.
The judgment of the lower court was affirmed, with costs against Corpus.