- Petitioner
- M. H. Wylie
- Respondent
- Aurora I. Rarang
- Citation
- G.R. No. 74135
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Gutierrez, Jr., J.
- Decided
- May 28, 1992
Summary
US naval officers Wylie and Williams published a derogatory article in the base newsletter naming 'Auring' (Aurora Rarang) as consuming confiscated items and being 'a disgrace.' Despite the Provost Marshal office recommending deletion of the name, they negligently allowed publication. Rarang sued for defamation. Officers claimed immunity from suit as government officials performing official functions. The Supreme Court held that while US officials generally enjoy immunity for official acts, this immunity does not extend to crimes and tortious acts committed ultra vires or in bad faith. The defamatory publication was a personal tortious act, not an official duty. The officers were held personally liable under Civil Code provisions on quasi-delict and moral damages for defamation, establishing important precedent on limits of official immunity for tortious conduct.