G.R. No. L-8894, December 2, 1914
MARIANO PERFECTO, plaintiff-appellee, vs. FULGENCIO CONTRERAS and JULIAN OCAMPO, defendants-appellants.

FACTS:
On November 3, 1910, Mariano Perfecto, then the Governor of Ambos Camarines, filed a civil action for damages against the proprietors and associates of the bisemanal newspaper “El Camarinense.” The complaint alleged that several articles published in the newspaper on various dates in 1910 (specifically, “El Rabudo Affair,” “Balance Semestral,” “Consumatum Est,” and “Gobierno de Parientes”) were libelous and caused injury to his reputation, for which he sought P100,000 in damages.

The defendants, Fulgencio Contreras and Julian Ocampo, admitted the publications but asserted the defense of truth, good faith, justifiable ends, and that the publications were privileged. Other named defendants denied any participation in the writing or publication of the articles.

After trial, the Court of First Instance of Ambos Camarines absolved the other defendants for insufficient evidence but found Contreras and Ocampo liable. It sentenced them jointly and severally to pay P12,000 as actual damages for injury to reputation and P3,000 as punitive damages, plus costs. Contreras and Ocampo appealed, raising seven assignments of error.

ISSUE:
The principal issues raised by the appellants were:
1. Whether the trial judge was disqualified from hearing the civil case because he had previously presided over the criminal libel cases against the appellants based on the same publications.
2. Whether the published articles were libelous.
3. Whether the trial court erred in its assessment of actual and punitive damages.
4. Whether the appellants could be held jointly and severally liable.

RULING:
The Supreme Court AFFIRMED the judgment of the lower court with modifications as to the amount of damages.

1. On the Judge’s Disqualification: The Court held that the trial judge was not disqualified under Section 8 of the Code of Procedure in Civil Actions. The alleged prejudice from having presided over the prior criminal cases was not a statutory ground for disqualification (e.g., pecuniary interest, relationship, prior counsel role). Since no other judge was available, it was his duty to proceed with the trial. No error was found on this point.

2. On the Libelous Nature of the Publications: The Court sustained the finding that the articles were libelous. By agreement, the evidence from the prior criminal cases (G.R. Nos. 7897 and 7898) was incorporated into the record of this civil case. Both the trial court and the Supreme Court, upon reviewing that same evidence, had already concluded in the criminal cases that the publications constituted libel. The appellants’ defense of truth was not sustained by the evidence.

3. On the Award of Damages:
Actual Damages: The Court recognized that a good reputation is a valuable right, the unlawful attack of which warrants full compensation. However, upon re-examination of the evidence, the Supreme Court found the award of P12,000 to be excessive. It REDUCED the actual damages to P2,000.
Punitive Damages: The Court affirmed the authority to award punitive damages under Act No. 277 (The Libel Law). Considering that the appellants had already been fined P1,000 each in the related criminal cases, the Supreme Court deemed the punitive damages award of P3,000 excessive. It REDUCED the punitive damages to P500 for each defendant, to be paid jointly and severally.

4. On Joint and Several Liability: The Court affirmed the imposition of joint and several liability. Contreras and Ocampo were joint tortfeasors who acted together in committing the libel. As such, they are jointly and severally liable for the entire damage caused; the injured party may recover the full amount from any one of them.

DISPOSITIVE PORTION:
The judgment of the lower court was affirmed with the modifications that the appellants, Fulgencio Contreras and Julian Ocampo, are ordered to pay jointly and severally: (a) the sum of P2,000 as actual damages, and (b) the sum of P500 as punitive damages, plus the costs of the suit.