Radio Communications of the Phils., Inc. v. Court of Appeals
REITERATIONFacts
The Antecedents: Private respondent Loreto Dionela filed a civil case for recovery of damages against petitioner Radio Communications of the Phils., Inc. (RCPI). The basis of the complaint was a telegram sent through RCPI's Manila Office to Dionela, which contained additional words in Tagalog that were alleged to be defamatory. The Tagalog words were: "SA IYO WALANG PAKINABANG DUMATING KA DIYAN-WALA-KANG PADALA DITO KAHIT BULBUL MO". Dionela alleged that these words wounded his feelings, caused him embarrassment, and adversely affected his business. RCPI defended that the Tagalog words were a private joke between the sending and receiving operators, not intended for the plaintiff, and thus not part of the telegram. Procedural History: The trial court ruled in favor of Dionela, finding the Tagalog words libelous per se and holding RCPI liable for damages and attorney's fees. The Court of Appeals modified the decision by reducing the award for moral damages and attorney's fees but affirmed the findings of the lower court regarding RCPI's liability and the publication of the libelous words. The Petition: RCPI filed a Petition for Review by certiorari with the Supreme Court, assailing the decision of the Court of Appeals on several grounds, including the holding that the employer should answer directly for the civil liability arising from the employee's act, the sufficiency of publication of the libelous telegram, and the basis of the company's liability under Articles 19 and 20 of the Civil Code.
Issue(s)
Whether RCPI, as an employer, should be held directly and primarily liable for the civil liability arising from the alleged libelous act of its employee. Whether there was sufficient publication of the alleged libelous telegram as contemplated by law. Whether RCPI's liability is predicated on Articles 19 and 20 of the Civil Code (Human Relations). Whether the award of attorney's fees was proper.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals. The Court held RCPI liable for damages based on breach of contract and negligence of its employees, applying Articles 19 and 20 of the Civil Code, and not subsidiary liability under the Revised Penal Code. The Court found sufficient publication of the libelous words and upheld the award of moral damages and attorney's fees, albeit reduced by the appellate court.
Ratio Decidendi
On the issue of direct and primary liability of RCPI: The Court clarified that the action was filed directly against RCPI not for subsidiary liability under Article 1161 in relation to Article 103 of the Revised Penal Code, but based on Articles 19 and 20 of the Civil Code and breach of contract. The Court emphasized that a corporation, acting through its employees, is directly liable for the acts of those employees performed in the pursuit of the corporation's business. To allow a corporation to escape liability by claiming employees acted beyond their assigned tasks would deprive the public of an adequate remedy. The Court invoked the master and servant rule, stating that in contracts, the negligence of the employee is the negligence of the employer. On the issue of sufficient publication: The Court agreed with the appellate court that there was sufficient publication. The fact that a carbon copy of the telegram was filed among other telegrams, left hanging, and open for public inspection constituted sufficient publication. The Court distinguished this from a situation where the telegram would have been kept in a secured place, inaccessible to third parties without permission. The libelous words were included in the telegram when delivered to the plaintiff, and the office file was accessible to third parties. On the issue of liability under Articles 19 and 20 of the Civil Code: The Court affirmed that RCPI's liability was predicated on these articles, which mandate acting with justice, giving everyone his due, and observing honesty and good faith, and that anyone who contrary to law, wilfully or negligently causes damage to another shall indemnify the latter. The inclusion of libelous matters in the transmitted message, without the consent or knowledge of the sender, constituted a breach of the contract of service undertaken by RCPI. The Court also considered the application of the doctrine of 'res ipsa loquitur' (the thing speaks for itself) where negligence may be difficult to prove, given the circumstances surrounding the injury. On the issue of award of attorney's fees: The Court found that the award of attorney's fees was proper, considering the damages suffered by the plaintiff due to the libelous words, which affected his business and social standing. The reduction of the award by the Court of Appeals was deemed reasonable.
Main Doctrine
A corporation engaged in the business of transmitting messages is liable for damages arising from libelous matters included in a transmitted message, not only under the law on torts but also for breach of contract, as the acts of its employees in receiving and transmitting messages are the acts of the corporation itself. The doctrine of 'res ipsa loquitur' may be applied when negligence is difficult to substantiate.