Michael Guy v. Raffy Tulfo

 

Michael Guy v. Raffy Tulfo

G.R. No. 213023

April 10, 2019

FACTS:

                According to Tulfo’s article in Abante Tonite, on March 20, 2004, Michael Guy, a businessman went to the house of Amatong. Guy was being investigated by RIPS of DOF because of his tax refunds he received since 1998 to 2003. Guy was so problematic when he knew he was being investigated. He received a letter from the Central Bank requesting all transactions of his business. On that same day, Amatong called the chief of RIPS to stop the investigation against Guy and to surrender all documents gathered by RIPS against Guy. Guy claimed that Tulfo’s article tainted his reputation so he filed against Tulfo and 7 representatives Abante Tonite the crime of libel.

ISSUE:

                Whether or not he is guilty

HELD:

                Yes. This Court cannot remind the bench and the bar often enough that in order that moral damages may be awarded, there must be pleading and proof of moral suffering, mental anguish, fright and the like. While no proof of pecuniary loss is necessary in order that moral damages may be awarded, the amount of indemnity being left to the discretion of the court, it is nevertheless essential that the claimant should satisfactorily show the existence of the factual basis of damages and its causal connection to defendant's acts. This is so because moral damages, though incapable of pecuniary estimation, are in the category of an award designed to compensate the claimant for actual injury suffered and not to impose a penalty on the wrongdoer. In Francisco vs. GSIS, the Court held that there must be clear testimony on the anguish and other forms of mental suffering. Thus, if the plaintiff fails to take the witness stand and testify as to his/her social humiliation, wounded feelings and anxiety, moral damages cannot be awarded. In Cocoland Development Corporation vs. National Labor Relations Commission, the Court held that "additional facts must be pleaded and proven to warrant the grant of moral damages under the Civil Code, these being, . . . social humiliation, wounded feelings, grave anxiety, etc., that resulted therefrom." Wherefore, Raffy Tulfo, ordered to pay Guy exemplary damages.