Yuchengco vs The Manila Chronicle

FACTS:
Petitioner, Alfonso Yuchengco filed a cause of action against respondents Alberto Cojuito, jr.
and reporters of Manila Chronicle for defamatory articles stating him as Marcos Crony, by
acting as a dummy for the late dictator Marcos and Romualdez clans in Benguet Corp., which
sought to take the management of Oriental Petroleum Mineral Corp., and further portraying
him as unfair and uncaring employer when the employess of the Grepalife Corp. staged a strike.
The basis of his cause of action is the “abuse of rights”, or the Art. 19, in relation to the Art. 20
of the Civil Code, which warrants the award of damages.

ISSUE:

Manila Chronicle, owned by respondent Coyuito and in which respondents are employees,
were sued by Yuchengco in a civil action for damages for libelous publication, abuse of right and
attorney’s fees and costs. RTC and CA ruled for Yuchengco andfound respondents liable as
all elements for the acti on were present including actual malice. However, the CA
later reversed in aResolution ruling that the articles published were qualifiedly privileged
communication as they are fair commentaries on matters of public interest despite actual
malice being present and therefore exempted for liability for damages.
SC held that CA erred in ruling thatqualifi edly privileged communicati ons are
automati cally exempted from liability despite the fi nding of actual malice. RPC 354
onlypertains to presumptions and as exceptions to such presumptions, qualifiedly privileged
communications like fair commentaries can stillhold a person liable if actual malice is
proven as in the case at bar. Even if actual malice is proven, the subject arti cles
cannot beconsidered as fair commentaries on matters of public interest as Yuchengco is not a
public figure or official but a private individual.