CATALINO P. ARAFILES v. PHILIPPINE JOURNALISTS, INC., et al.
426 SCRA 336 (2004), THIRD DIVISION (Carpio Morales, J.)
Press reporters and editors must not be held accountable for honest mistakes or imperfection in the choice of words.
FACTS: Emelita Despuig (Emelita) lodged a complaint against petitioner Catalino Arafiles for forcible abduction with rape and forcible abduction with attempted rape before the then on duty Patrolman Benito Chio at the General Assignments Section of the Western Police District (WPD) Headquarters. In the presence of respondent Romy Morales, reporter of People‘s Journal Tonight, Emelita executed a sworn statement narrating the events surrounding the reported offenses committed against her by Arafiles.
Morales thereupon personally interviewed Emelita for the purpose of reporting the same in People‘s Journal Tonight. By his claim, he tried to contact Arafiles after the interview to verify Emelita‘s story but failed to do so. Morales then wrote an account about Emelita‘s complaint and submitted it to his editor, which later on appeared as a headline on the paper.
About a year following the publication of the report, Arafiles instituted a complaint for damages before the Regional Trial Court (RTC) of Quezon City against respondents Philippine Journalists, Inc., et al. on account of ―grossly malicious and overly senationalized repoting in the news item.‖
ISSUE: Whether or not the publication of the news item is libelous and was attended with malice
HELD: In determining the manner in which a given event should be presented as a news item and the importance to be attached thereto, newspapers must enjoy a certain degree of discretion.
Every citizen of course has the right to enjoy a good name and reputation, but the Court do not consider that the Morales, et al., under the circumstances of this case, had violated said right or abused the freedom of the press. The newspapers should be given such leeway and tolerance as to enable them to courageously and effectively perform their important role in our democracy. In the preparation of stories, press reporters and editors usually have to race with their deadlines; and consistently with good faith and reasonable care, they should not be held to account, to a point of suppression, for honest mistakes or imperfection in the choice of words.