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Manila Bulletin v. Domingo

G.R. No. 170341 (July 5, 2017)

Victor Domingo's libel suit against Ruther Batuigas was overturned by the Supreme Court for lack of malice.

Facts:

Petitioner Ruther D. Batuigas was a columnist for the tabloid Tempo, published by Manila Bulletin Publishing Corporation. On December 20, 1990, he wrote an article titled "Crucial task for JoeCon's successor," which discussed complaints from Waray employees of the Department of Trade and Industry (DTI), Region VIII, regarding mismanagement and other issues, specifically naming Regional Director Victor A. Domingo. On January 4, 1991, Batuigas published another article criticizing Domingo's performance, suggesting that he was responsible for the low morale and inefficiency within the DTI.

Domingo, feeling aggrieved by these articles, filed a libel complaint against Batuigas on January 18, 1991, and subsequently initiated a civil case for damages against both Batuigas and Manila Bulletin. The criminal case