Newsweek, Inc. vs. Court of Appeals

NEWSWEEK, INC. VS.
COURT OF APPEALS (142 SCRA 171 [1986])
DOCTRINE: in order to maintain a libel suit, it is essential that the victim be identifiable although it is not
necessary that he be named. defamatory matter which does not reveal the Identity of the person upon
whom the imputation is cast, affords no ground of action unless it be shown that the readers of the libel
could have Identified the personality of the individual defamed Where the 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 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.
Injured Party/ Private Respondent: National Federation of Sugarcane Planters
Tortfeasor: Newsweek
Tort/Event: libelous article in Newsweek (freedom of the press)
FACTS: National Federation of Sugarcane Planters (Private Respondent)6, filed a class suit (in their own
behalf and/or as a class suit in behalf of all sugarcane planters in the province of Negros Occidental) for
libel, against NewsweeK and Fred Bruning and Barry Came ( 2 of Newsweek’s non-resident
correspondents/reporters). The complaint alleged that defendants committed libel against them
1. 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
imprunity.
2. They 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.. Newsweek filed a motion to dismiss. The trial court denied the motion to dismiss, stating
that the grounds on which the motion to dismiss On June 18, 1982. Newsweek filed a petition for
certiorari with CA which t affirmed the trial court's Orders. Newsweek (Petitioner) argues that private
respondents' complaint failed to state a cause of action because 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.
ISSUE: Whether or not the private respondents' complaint failed to state a cause of action (w/n the
article is libelous?
HELD: Suit will not prosper.
In the case of Corpus vs. Cuaderno, Sr, the ruled that "in order to maintain a libel suit, it is essential that
the victim be identifiable although it is not necessary that he be named. In an earlier case, this Court
declared that" ... defamatory matter which does not reveal the Identity of the person upon whom the
imputation is cast, affords no ground of action unless it be shown that the readers of the libel could have
Identified the personality of the individual defamed." This principle has been recognized to be of vital
importance, especially 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.
In the case of Uy Tioco vs. Yang Shu Wen , 32 Phil. 624, this Court held as follows: Defamatory remarks
directed at a class or group of persons in general language only, are not actionable by individuals
composing the class or group unless the statements are sweeping; and it is very probable that even then
no action would lie where the body is composed of so large a number of persons that common sense
would tell those to whom the publication was made that there was room for persons connected with
the body to pursue an upright and law abiding course and that it would be unreasonable and absurd to
condemn all because of the actions of a part. (supra p. 628). Where the 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 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.
Application: in this case NFSP filed a class suit for libel against Newsweek, because of an article
published tackling the plight of sugarcane Farmers in Negros, the Article Spoke of abuses made by
Sugarcane planters in general, and made no mention of any particular person. 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.
WHEREFORE, the decision of the Intermediate Appellate Court is reversed and the complaint in Civil
Case No. 15812 of the Court of First Instance of Negros Occidental is dismissed, without pronouncement
as to costs.

Newsweek, Inc. vs. Court of Appeals

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Newsweek, Inc. vs. Court of Appeals

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NEWSWEEK, INC. VS.

COURT OF APPEALS (142 SCRA 171 [1986])

Injured Party/ Private Respondent: National Federation of Sugarcane Planters

Tort/Event: libelous article in Newsweek (freedom of the press)

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