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#5 Filipinas Broadcasting Network, Inc. vs. Ago Medical and Educational Center-Bicol Christian College of Medicine (Amec-Bccm

The document discusses a case involving a radio program that allegedly defamed a medical school. The issue is whether the school is entitled to moral damages. The court held that while juridical persons generally cannot experience emotions, corporations can claim moral damages for libel or defamation under the Civil Code. The broadcasts were libelous per se so moral damages were awarded, though the amount was reduced as the school did not suffer substantial reputational damage.

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15 views1 page

#5 Filipinas Broadcasting Network, Inc. vs. Ago Medical and Educational Center-Bicol Christian College of Medicine (Amec-Bccm

The document discusses a case involving a radio program that allegedly defamed a medical school. The issue is whether the school is entitled to moral damages. The court held that while juridical persons generally cannot experience emotions, corporations can claim moral damages for libel or defamation under the Civil Code. The broadcasts were libelous per se so moral damages were awarded, though the amount was reduced as the school did not suffer substantial reputational damage.

Uploaded by

Angela
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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#5 FILIPINAS BROADCASTING NETWORK, INC. vs.

AGO
MEDICAL AND
EDUCATIONAL CENTER-BICOL CHRISTIAN COLLEGE OF
MEDICINE (AMEC-
BCCM

FACTS: Rima and Alegre were the host of FBNI program “Exposé.” Respondent
Ago was the owner of the Medical and Educational Center, subject of the radio
program “Expose”. AMEC claimed that the broadcasts were defamatory and
owner Ago and school AMEC claimed for damages.

ISSUE: WON AMEC-BCCM is entitled to moral damages.

HELD: YES. A juridical person is generally not entitled to moral damages


because, unlike a natural person, it cannot experience physical suffering or
such sentiments as wounded feelings, serious anxiety, mental anguish or
moral shock. The Court of Appeals cites Mambulao Lumber Co. v. PNB, et al. to
justify the award of moral damages. However, the Court’s statement in
Mambulao that “a corporation may have a good reputation which, if
besmirched, may also be a ground for the award of moral damages” is an obiter
dictum. AMEC’s claim for moral damages falls under item 7 of Article 2219 of
the Civil Code. This provision expressly authorizes the recovery of moral
damages in cases of libel, slander or any other form of defamation.
Article2219(7) does not qualify whether the plaintiff is a natural or juridical
person. Therefore, a juridical person such as a corporation can validly
complain about libel or any other form of defamation and claim for moral
damages. Where the broadcast is libelous per se, the law implies damages. In
such a case, evidence of an honest mistake or the want of character or
reputation of the party libeled goes only in mitigation of damages. Neither in
such a case is the plaintiff required to introduce evidence of actual damages as
a condition precedent to the recovery of some damages. In this case, the
broadcasts are libelous per se. Thus, AMEC is entitled to moral damages.
However, we find the award of P300,000 moral damages unreasonable. The
record shows that even though the broadcasts were libelous per se, AMEC has
not suffered any substantial or material damage to its reputation. Therefore, we
reduce the award of moral damages from P300,000 to P150,000.

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