Alcantara v. Amoranto
REITERATIONFacts
The Antecedents: Plaintiffs Gregorio I. Alcantara and Juan Ruelo filed an action for damages against Norberto S. Amoranto, the mayor of Quezon City, alleging that the defendant made libelous statements against them in a letter addressed to the Office of the President on October 23, 1955. The letter allegedly stated that the plaintiffs were "trouble makers, drunkards, and have many pending cases against them." Procedural History: The defendant moved to dismiss the complaint on the ground of prescription, arguing that the action was filed on January 5, 1957, more than one year after the alleged defamatory statements were made on October 23, 1955. The plaintiffs opposed, asserting that they only learned of the letter's contents on January 6, 1956, when it was translated to them, and thus the one-year period should commence from that date. The trial court dismissed the case, holding that the action had prescribed. A motion for reconsideration was denied, with the court stating that the claim of late knowledge was a "foreign matter." Plaintiff Alcantara appealed. The Petition: The plaintiff-appellant argued that the prescriptive period should commence from the date of his knowledge of the libelous statements, not from the date of the letter's publication.
Issue(s)
Whether the civil action for libel filed by the plaintiff-appellant had prescribed. Whether the prescriptive period for libel commences from the date of publication or from the date the offended party acquires knowledge of the defamatory statements.
Ruling
The Supreme Court set aside the order of dismissal and remanded the case to the lower court for further proceedings concerning the plaintiff-appellant's complaint.
Ratio Decidendi
On the issue of prescription: The Court held that the one-year limitation prescribed by law for a civil action arising from libel should be counted not from the date the alleged libelous letter was sent to the Office of the President, but from January 6, 1956, when the contents of the letter came to the appellant's knowledge. The Court emphasized that while a written defamation is actionable upon publication, the libelous matter must first be exhibited to the person libeled before an action could be brought. It would be unreasonable to expect a person defamed to institute proceedings for damages when they have no knowledge of the libel. The Court also noted that under the Revised Penal Code, the period of prescription for defamation commences to run from the day the crime is discovered by the offended party, a principle it found applicable by analogy to civil actions for libel. The Court found that the lower court erred in dismissing the complaint without considering the appellant's claim of late knowledge, especially since no evidence was presented to contradict it. The court's view that this claim was a "foreign matter" was deemed an oversight, as a motion to dismiss hearing allows for the presentation of evidence. On the commencement of the prescriptive period: The Court clarified that for written defamation, the prescriptive period commences from the day the action could have been brought, which is determined by the legal possibility of bringing the action. This possibility arises when the offended party acquires knowledge of the defamatory statements, as they cannot be expected to sue for damages without such knowledge. The Court cited Article 1150 of the new Civil Code, stating that the period must be counted from the day the action could have been brought, and that the legal possibility of bringing the action determines the starting point for computation. The Court rejected the defendant's argument that the period should start from the date of the letter, October 23, 1955, as the plaintiffs had no knowledge of its contents until January 6, 1956.
Main Doctrine
The one-year period for filing a civil action for libel prescribes from the date the offended party acquires knowledge of the defamatory statements, not necessarily from the date of publication.