Facts
In 1981, the respondent association of sugarcane planters filed a class suit in representation of 8,500 members alleging libel against Newsweek Inc., and two of its reporters. Newsweek is a foreign company licensed to do business in the Philippines. This is in connection with their article “An Island of Fear” which portrayed the province as a place dominated by big landowners who exploited, underpaid and brutally kill the impoverished laborers (or “sakadas”). The planters argue that the article show a deliberate and malicious use of falsehood, putting them in bad light, humiliation, making them objects of hatred and contempt in the international community.
Newsweek filed a motion to dismiss on the grounds that (1) The article: is not actionable in fact and in law. It is non-libelous. (2) Negros sugarcane planters fail to support a cause of action.
Issue 1
(1) Did the Negros sugar planters have an actionable basis or cause of action? (Are they real parties in interest, is there an actionable basis) No.
Ruling 1
The libel complaint filed by the sugar planters failed to specify that the article reached beyond the mere collectivityand did damage to the reputation of a specific, individual group member; that libel can be committed only against individual reputation;
In Corpus vs. Cuaderno, “to maintain a libel suit, it is essential that→the victim be identifiable” although it is not necessary that he be named.
The larger the collectivity (of the party), the more difficult it is for the individual member to prove the defamatory remarks.
(1a) Not a class suit
Class suit↔it is where one or more may sue for the benefit of all (Mathay vs. Consolidated Bank and Trust)
We agree with Newsweek that the filing of a class suit on behalf of 8500 sugarcane planters does not cure→the absence of any actionable basis.
The plaintiffs must have a→common or general interest in the subject matter of the controversy.
When the article mentioned mayor Sola bringing a special police unit to arrest a victim, it is not libel because it referred to an official act performed by an elective public official which is within the realm of privilege speechand protected by the constitutional guarantees of free speechand press.
Issue 2
Is Civil action for certiorari or prohibition available to Newsweek when its motion to dismiss the complaint and MR were denied?
Ruling 2
Yes. As a general rule, an order denying a motion to dismiss is merely interlocutory and cannot be subject of appeal until final judgment or order is rendered. (Sec. 2 of Rule 41).
The exception is that: if the court denied the motion to dismiss, acts without or in excess of jurisdiction or with grave abuse of discretion, then the certiorari lies. Reason: It would be unfair for the defendant to undergo the ordeal and expense of a trial if the court has no jurisdiction over the subject matter, or the court is not the proper venue.
The IAC correctly stated the general rule and exceptions, but ruled that none of the exceptions apply in this case, hence, the case needs a full-blown trial to get to the bottom of the controversy.
SC: There is no need for full-blown trial because article is not libelous.
The specific allegation in the complaint does not match the actual text of the complaint.
Allegation: Complaint points out that article is libelous.
Actual complaint: Merely recites the favorable working conditions of the agri workers, and various programs supported by the planters’ associations.
Admonition: Newseek should check its sources to ensure truth.
IAC decision dismissed. SC favored Newsweek.
English