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1) Fourteen sugarcane planters filed a libel case against Newsweek magazine over an article portraying Negros Occidental province as dominated by exploitative landowners.
2) Newsweek filed a motion to dismiss arguing the plaintiffs were not individually identifiable and libel cannot target a group. The court denied the motion.
3) Newsweek appealed, and the Supreme Court ultimately ruled in their favor, finding libel requires identifiability of specific individuals and the article did not target the plaintiffs directly.
1) Fourteen sugarcane planters filed a libel case against Newsweek magazine over an article portraying Negros Occidental province as dominated by exploitative landowners.
2) Newsweek filed a motion to dismiss arguing the plaintiffs were not individually identifiable and libel cannot target a group. The court denied the motion.
3) Newsweek appealed, and the Supreme Court ultimately ruled in their favor, finding libel requires identifiability of specific individuals and the article did not target the plaintiffs directly.
1) Fourteen sugarcane planters filed a libel case against Newsweek magazine over an article portraying Negros Occidental province as dominated by exploitative landowners.
2) Newsweek filed a motion to dismiss arguing the plaintiffs were not individually identifiable and libel cannot target a group. The court denied the motion.
3) Newsweek appealed, and the Supreme Court ultimately ruled in their favor, finding libel requires identifiability of specific individuals and the article did not target the plaintiffs directly.
1. Causative event 2. Sugarcane planters files libel case against Newsweek in CFI. • Newsweek files MTD. • CFI denies MTD. 4. Newsweek files petition for certiorari in IAC to annul the order of CFI denying the MTD. • IAC affirms order of denial of CFI. 5. Newsweek files a special civil action for certiorari, prohibition with preliminary injunction in SC. • Statement of the issues • On identifiability as element of libel • On libel against a class • On class suit • On privileged communication • On the remedy of special civil action to annul interlocutory order of MTD denial • On the failure to state a cause of action • Newsweek wins
Causative event: 14 litigants (4 associations and 10
individuals) claim to represent 8,500. Incorporated associations of sugarcane planters in Negros Occidental claiming to have 8,500 members and several individual sugar planters, filed 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 petitioner and two of petitioners' non-resident correspondents/reporters Fred Bruning and Barry Came. The complaint alleged that petitioner and the other defendants committed libel against them by the publication of the article "An Island of Fear" in the February 23, 1981 issue of petitioner's weekly news magazine Newsweek. The article supposedly 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. Class suit for libel: Complainants therein alleged that said article, taken as a whole, showed a deliberate and malicious use of falsehood, slanted presentation and/or misrepresentation of facts intended to put them (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 that defendants be ordered to pay them PlM as actual and compensatory damages, and such amounts for moral, exemplary and corrective damages as the court may determine, plus expenses of litigation, attorney's fees and costs of suit. A photo copy of the article was attached to the complaint. Newsweek's MTD: (1) lack of cause of action (2) fails to state a cause of action The complaint made no allegation that anything contained in the article complained of regarding sugarcane planters referred specifically to any one of the private respondents; that libel can be committed only against individual reputation; and that in cases where libel is claimed to have been directed at a group, there is actionable defamation only if the libel can be said to reach beyond the mere collectivity to do damage to a specific, individual group member's reputation. CFI's denial of MTD, as affirmed by IAC / Issues: (1) complaint on its face states a valid cause of action, and (2) whether the article is actionable or not is a matter of evidence. Identifiability as element of libel: It is essential in libel that the victim is identifiable. Where a group or class of persons, as in the case at bar, claim to have been defamed, for it is evident that the larger the collectivity, the more difficult it is for the individual member to prove that the defamatory remarks apply to him. When libel against group possible: the statement must be so sweeping or all-embracing as to apply to every individual in that group or class, or sufficiently specific so that each 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. On class suit: We have here a case where 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. On privileged communication: The disputed portion of the article which refers to plaintiff Sola and which was claimed to be libelous never singled out plaintiff Sola as a sugar planter. The news report merely stated that the victim had been arrested by members of a special police unit brought into the area by Pablo Sola, the mayor of Kabankalan. Hence, the report, referring as it does to an official act performed by an elective public official, is within the realm of privilege and protected by the constitutional guarantees of free speech and press. On failure to state cause of action: The specific allegation in the complaint, to the effect that the article attributed to the sugarcane planters the deaths and brutalization of sugarcane workers, is not borne out by a perusal of the actual text. --- --