Arafiles vs. Phil. Journalists Inc., Et Al
Arafiles vs. Phil. Journalists Inc., Et Al
FACTS: About 2 a.m., while respondent Morales, a reporter of Peoples Journal Tonight, was at
the Western Police District (WPD) Headquarters Emelita Despuig, an employee of the National
Institute of Atmospheric Sciences (NIAS), lodged a complaint against petitioner, a NIAS
director, for forcible abduction with rape and forcible abduction with attempted rape. Emelita
executed a sworn affidavit which was later on written in the police blotter and perused by
Morales. The latter interviewed Emelita. The following day, the article appeared in the headline
of respondents newspaper which wrote, GOVT EXEC RAPES COED. About a year following
the publication, petitioner instituted a complaint before the RTC against respondents for
damages. Petitioner alleged that because of the article, his reputation was injured. Respondent
answered that his write-up was protected by the constitution on freedom of the press. RTC ruled
in favor of petitioner.
ISSSUE: W/N the CA erred in holding that the publication of the news item was not attended
with malice to thus free respondents of liability for damages. Whether respondent write-up was
protected by the constitution on freedom of the press
RULING: Yes respondent write-up was protected by the constitution on freedom of the press
Petition was denied.
In actions for damages for libel, it is axiomatic that the published work alleged to contain
libelous material must be examined and viewed as a whole.
Respondents could of course have been more circumspect in their choice of words as the
headline and first seven paragraphs of the news item give the impression that a certain director of
the NIAS actually committed the crimes complained of by Emelita. The succeeding paragraphs
sufficiently convey to the readers, however, that the narration of events was only an account of
what Emelita had reported at the police headquarters.
Every citizen of course has the right to enjoy a good name and reputation, but we do not
consider that the respondents, under the circumstances of this case, had violated said right or
abused the freedom of the press. The newspapers should be given such leeway and tolerance as
to enable them to courageously and effectively perform their important role in our democracy. In
the preparation of stories, press reporters and [editors] usually have to race with their deadlines;
and consistently with good faith and reasonable care, they should not be held to account, to a
point of suppression, for honest mistakes or imperfection in the choice of words.