Camacho v. Liquete
REITERATIONFacts
The Antecedents: On January 19, 1904, an article addressed to the plaintiff, Joaquin Pellicena Camacho, appeared in "La Democracia," a daily newspaper where the defendant, Leoncio Gonzalez Liquete, was the managing editor. The plaintiff considered the article libelous and filed an action for damages. Procedural History: The defendant filed an answer, setting up a counterclaim for damages due to an article published by the plaintiff in "El Noticiero" on January 18, 1904, which the defendant claimed was libelous against him. The defendant, who was appointed to an Honorary Commission to the St. Louis Exposition, left the Philippines on April 23, 1904, and the case was tried in July of that year in his absence. The defendant's motion for continuance due to his absence was denied, both before and after the plaintiff presented evidence. The court below entered judgment in favor of the plaintiff for $500, money of the United States. The Petition: The defendant appealed the judgment, arguing, among other things, that the plaintiff's publication of a libel justified his own publication, and that the denial of his motion for continuance was erroneous.
Issue(s)
Whether the publication of a libel by the plaintiff justifies the publication of another libel by the defendant. Whether the denial of the defendant's motion for a continuance was a valid ground for exception.
Ruling
The judgment of the court below is modified by changing the recovery from $500, money of the United States, to P250. As so modified, it is affirmed. No costs are allowed to either party in this court.
Ratio Decidendi
On whether the publication of a libel by the plaintiff justifies the publication of another libel by the defendant: The Court held that the publication of a libel by the plaintiff is not a legal justification for the publication of another libel by the defendant. Even if the defendant were the person referred to in the article published by the plaintiff, this would not serve as a legal defense. The Court cited the principle that one wrong does not justify another wrong, especially in matters of libel where the law aims to protect reputation and prevent the spread of falsehoods. The defendant's counterclaim was therefore without legal basis in this regard. On whether the denial of the defendant's motion for a continuance was a valid ground for exception: The Court ruled that the action of the trial court in denying the motion for continuance fell within the provisions of section 141 of the Code of Civil Procedure. This section specifies that rulings of the court upon motions to postpone the trial are not subject to exception. Therefore, the defendant's exception to the denial of his motion for continuance could not be sustained. The trial court acted within its discretion and legal bounds when it proceeded with the trial despite the defendant's absence.
Main Doctrine
Publication of a libel by one party is not a legal justification for the publication of another libel by the other party. A ruling on a motion to postpone a trial is not subject to exception.