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Filipinas Broadcasting Network v. Ago Medical & Educational Center
Filipinas Broadcasting Network v. Ago Medical & Educational Center
speech, expression, and of the press. Both parties, namely, FBNI, Rima and Alegre,
on one hand, and AMEC and Ago, on the other, appealed the decision to the Court
of Appeals.
The Court of Appeals affirmed the trial courts judgment with modification. The
appellate court made Rima solidarily liable with FBNI and Alegre. The appellate
court denied Agos claim for damages and attorneys fees because the broadcasts
were directed against AMEC, and not against her. FBNI, Rima and Alegre filed a
motion for reconsideration which the Court of Appeals denied in its 26 January 2000
Resolution. Hence, FBNI filed the petition for review.
Issue: Whether AMEC is entitled to moral damages.
Held: A juridical person is generally not entitled to moral damages because, unlike a
natural person, it cannot experience physical suffering or such sentiments as
wounded feelings, serious anxiety, mental anguish or moral shock. The Court of
Appeals cites Mambulao Lumber Co. v. PNB, et al. to justify the award of moral
damages. However, the Courts statement in Mambulao that a corporation may
have a good reputation which, if besmirched, may also be a ground for the award of
moral damages is an obiter dictum. Nevertheless, AMECs claim for moral damages
falls under item 7 of Article 2219 of the Civil Code. This provision expressly
authorizes the recovery of moral damages in cases of libel, slander or any other
form of defamation. Article 2219(7) does not qualify whether the plaintiff is a
natural or juridical person. Therefore, a juridical person such as a corporation can
validly complain for libel or any other form of defamation and claim for moral
damages.
Moreover, where the broadcast is libelous per se, the law implies damages. In such
a case, evidence of an honest mistake or the want of character or reputation of the
party libeled goes only in mitigation of damages. Neither in such a case is the
plaintiff required to introduce evidence of actual damages as a condition precedent
to the recovery of some damages. In this case, the broadcasts are libelous per se.
Thus, AMEC is entitled to moral damages. However, the Court found the award of
P300,000 moral damages unreasonable. The record shows that even though the
broadcasts were libelous per se, AMEC has not suffered any substantial or material
damage to its reputation. Therefore, the Court reduced the award of moral damages
from P300,000 to P150,000.