Tejuco v. Squibb
REITERATIONFacts
The Antecedents: Plaintiff-appellant Milagros Tejuco filed a civil complaint against her former employers, E. R. Squibb and Son Philippine Corporation, et al., alleging that they wrote her a libelous letter of separation which was posted on the company's bulletin board. She prayed for damages amounting to P50,000, a retraction of the letter, and publicity for the retraction. Procedural History: The complaint was dismissed by the Court of First Instance of Manila on the ground of prescription. The appellant's motion for reconsideration was denied. The Petition: The appellant interposed the present appeal, admitting that the complaint was filed one year and six months after the publication of the libelous letter.
Issue(s)
What is the prescriptive period for a civil action arising from libel under Philippine law? Whether the appellant's civil action for libel had prescribed.
Ruling
The order appealed from is hereby affirmed with costs against the appellant.
Ratio Decidendi
On the prescriptive period for a civil action arising from libel: The Court held that civil obligations resulting from criminal offenses are governed by penal laws, subject to specific provisions of the Civil Code. Article 112 of the Revised Penal Code states that civil liability shall be extinguished in the same manner as other obligations in accordance with Civil Law. Article 1231 of the Civil Code enumerates prescription as a cause for extinguishment of obligations. The applicable provision on prescription is Article 1147 of the Civil Code, which mandates that an action for defamation must be filed within one year. The Court clarified that the broad term "defamation" includes libel in the absence of more specific provisions. On whether the appellant's civil action for libel had prescribed: The appellant admitted that the complaint was filed one year and six months after the publication of the libelous letter on October 18, 1954. Since the prescriptive period for an action for defamation (libel) is one year under Article 1147 of the Civil Code, the action filed by the appellant had clearly prescribed. Therefore, the dismissal of the complaint by the lower court on the ground of prescription was proper.
Main Doctrine
An action for defamation, including libel, must be filed within one year from the date of publication, as provided by Article 1147 of the Civil Code.