- Petitioner
- Domingo Imperial
- Respondent
- Venancio Ziga
- Citation
- G.R. No. L-19726
- Court
- Supreme Court
- Division
- En Banc
- Ponente
- Reyes, J.
- Decided
- April 13, 1967
Libel action for moral and exemplary damages due to defamatory publications
Summary
This libel case involved Domingo Imperial's suit against Venancio P. Ziga and Anastacia V. de Muñoz for P600,000 in damages due to defamatory publications. The defendants published a mimeographed article and letters to the Commission on Appointments containing false accusations against Imperial's character and conduct as Chairman of the Commission on Elections, including charges of electoral fraud, corruption, and nepotism. The Supreme Court affirmed the Court of First Instance of Albay's decision awarding P20,000 in moral damages, finding that Ziga was the real author of all defamatory materials and that they were published with actual malice despite their claimed privileged character. The Court rejected exemplary damages but ordered legal interest from the original judgment date, demonstrating that qualified privilege is lost when communications are made with actual malice and lack good faith basis.