Newsweek v Inc. v .IAC and National Federation of Sugarcane Planters Inc.

224 SCRA 792 January 28,1925

Street, J.

Doctrine of the Case

The case at bar is not a class suit. It is not a case where one or more may sue for the benefit of all or where the
representation of class interest affected by the judgement or decree is indispensable to make each member of the
class an actual party.

In this case, each of the plaintiffs has a separate and distinct reputation in the community – they do not
have a common or general interest in the subject matter of the controversy.

Facts:

Newsweek, Inc. is a foreign corporation licensed to do business in the Philippines. On the other hand, private
respondents are incorporated associations of sugarcane planters in Negros Occidental claiming to have 8,500
members and several individual sugar planters.

Private respondents filed a civil case in their own behalf and/or as a class suit in behalf of all sugarcane
planters in the province of Negros Occidental against the petitioner. The complaint alleged that petitioner
committed libel against them by publication of an article entitled “AN Island of Fear,” which portrayed the
island province of Negros Occidental as a place dominated by big landowners or sugarcane planters who not
only exploited the impoverished and underpaid sugarcane workers/laborers, but also brutalized and killed
them with impunity.

Private respondents alleged that the said article, showed a deliberate and malicious use of falsehood which
was intended to put sugarcane planters in bad light, expose them to public ridicule, discredit, and humiliation
here in the Philippines and abroad, and make them objects of hatred, contempt, and hostility of their
agricultural workers and of the public in general. They prayed for the payment of damages, plus expenses of
litigation, attorney’s fees and costs of suit.

Newsweek filed a motion to dismiss on the ground that 1) the printed article is not actionable in fact and in
law; and 2) the complaint failed to state a cause of action.

NOTE: A Demurrer is a motion to dismiss on the ground of insufficiency of evidence.

CFI of Bacolod:
Denied the MTD, holding that the complaint on its face states a valid cause of action; and that the issue
regarding the printed article was a matter of evidence. Motion for reconsideration was also denied.

Intermediate Appellate Court: Newsweek filed a petition for certiorari before the IAC, seeking the annulment
of the CFI’s orders on the ground of grave abuse of discretion as amounting to lack of jurisdiction. The IAC
affirmed the CFI’s orders and held that the complaint contains a cause of action; and that certiorari under
Rule 65 cannot be made to substitute for an appeal where an appeal would lie at a proper time. Motion for
reconsideration was also denied.

Issue/s:
1. W/N private respondents’ complaint failed to state a cause of action; and
2. W/N the action can be considered as a class suit;
Ruling:

1. YES. Private respondents’ complaint failed to state a cause of action because the article complained of did
not refer specifically to any one of the private respondents – that it is not libelous In Corpus v. Cuaderno,
Sr. and Uy Tico vs. Yang Shu Wen, the court held that “where defamation is alleged to have been directed
at a group or class, it is essential that the statement must be so sweeping or all-embracing as to apply to
every individual in the class or group can prove that the defamatory statement specifically pointed to him,
so that he can bring the action separately, if need be.

2. NO. The SC held that the case is not a class suit because it is not a not a case where one or moremay sue
for the benefit of all or where the representation of class interest affected by the judgement or decree is
indispensable to make each member of the class an actual party. In this case, each of the plaintiffs has a
separate and distinct reputation in the community – they do not have a common or general interest in the
subject matter of the controversy. The disputed portion of the article which refers to plaintiff Sola and
which was claimed to be libelous never singled out Sola as a sugar planter.