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Facts: In the case of Macasaet v.

Francisco, here, there was an action for damages filed by a


retired police officer. This is because of the allegedly libelous articles that petitioners published
in the 2000 issue of Abante Tonite. By reason of this action, Abante Tonite, which is a daily
tabloid of general circulation, was impleaded as one of the defendants. Now, this was
questioned by Macasaet (the publisher of the tabloid) by arguing that Abante Tonite could not
be made a party in the action considering the fact that it was neither a natural nor a juridical
person. Therefore, it should be dropped as one of the defendants.

Issue: So the issue now in this case is whether or not the inclusion of Abante Tonite as party in
the case was proper? The Supreme Court ruled that yes applying the doctrine of corporation by
estoppel.

Ruling: Since Abante Tonite is a daily tabloid of a general circulation wherein it is a public
consumption since people all over the country could buy a copy of "Abante Tonite" and read it.
The persons who organized said publication obviously derived profit from it and that having
represented itself to the reading public as a corporation despite its not being incorporated
with the SEC, it is therefore deemed a corporation by estoppel considering that it possesses
attributes of a juridical person. Otherwise, it cannot be held liable for damages and injuries it
may inflict to other persons, whether natural or juridical.

So Abante Tonite’s inclusion as a party in the case was proper.

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