Newsweek v. IAC

Newsweek Inc. v.
IAC Libel
4
Docket No. L-63559 Date 5-30-1986 Feria Cla
Petitioners: Newsweek Inc Respondents: IAC, National Federation of
Sugarcane Planters Inc. et al
Recit Ready Summary
Incorporated associations of sugarcane planters in Negros Occidental filed a case against petitioner and
Fred Bruning and Barry Came. The complaint alleged that petitioner and other defendants committed libel
against them by the publication of the article "An Island of Fear" in the February 23, 1981 issue of petitioner's
weekly news magazine Newsweek. The article portrayed the province of Negros Occidental as a place
dominated by big landowners or sugarcane planters who not only exploited the impoverished and underpaid
sugarcane workers/laborers, but also brutalized and killed them with impunity. Whether or not libel was
committed? No. Where the defamation is alleged to have been directed at a group or class, it is essential
that the statement must be so sweeping or all-embracing as to apply to every individual in that group or
class, or sufficiently specific so that each individual in the class or group can prove that the defamatory
statement specifically pointed to him.
Facts
1. Private respondents, incorporated associations of sugarcane planters in Negros Occidental

claiming to have 8,500 members and several individual sugar planters filed a case against
petitioner and two petitioners’ non-resident correspondents/reporters Fred Bruning and Barry
Came.
2. The complaint alleged that petitioner and other defendants committed libel against them by the
publication of the article "An Island of Fear" in the February 23, 1981 issue of petitioner's weekly
news magazine Newsweek.
3. The article portrayed the province of Negros Occidental as a place dominated by big landowners
or sugarcane planters who not only exploited the impoverished and underpaid sugarcane
workers/laborers, but also brutalized and killed them with impunity.
4. Complainants alleged that the said article
a. showed a deliberate and malicious use of falsehood, slanted presentation and
misrepresentation of facts intended to put them in bad light
b. expose them to public ridicule, discredit and humiliation in the PH and abroad
c. Make them objects of hatred, contempt and hostility of their agricultural workers and of the
public
5. They prayed that defendants be ordered to pay them P1M as damages
6. Petitioner filed a motion to dismiss on the ff grounds
a. Printed article is not actionable in fact and law
b. Complaint is bereft of allegations that support a cause of action
Issues Ruling
1. Whether or not libel was committed? 1. Yes/No
Rationale
1. In order to maintain a libel suit, it is essential that the victim be identifiable although not necessary
that he be named.
2. Where the defamation is alleged to have been directed at a group or class, it is essential that the
statement must be so sweeping or all-embracing as to apply to every individual in that group or
class, or sufficiently specific so that each individual in the class or group can prove that the
defamatory statement specifically pointed to him, so that he can bring the action separately, if need
be.
3. On whether private respondents filed a class suit in representation of all the 8,500 sugarcane
planters of Negros Occidental
a. No. They do not have a common or general interest in the subject matter of the controversy.
4. The disputed portion of the article which refers to plaintiff Sola and which was claimed to be libelous
never singled out plaintiff Sola as a sugar planter. The news report merely stated that the victim
had been arrested by members of a special police unit brought into the area by Pablo Sola, the
mayor of Kabankalan. Hence, the report, referring as it does to an official act performed by an
elective public official, is within the realm of privilege and protected by the constitutional guarantees
of free speech and press.
Disposition
WHEREFORE, the decision of the Intermediate Appellate Court is reversed and the complaint in Civil Case
No. 15812 of the Court of First Instance of Negros Occidental is dismissed, without pronouncement as to
costs.
Separate Opinions
none

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Newsweek Inc. v.

1. Private respondents, incorporated associations of sugarcane planters in Negros Occidental

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