- Petitioner
- Radio Communications of the Philippines
- Respondent
- Court of Appeals
- Citation
- G.R. No. L-44748
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Paras, J.
- Decided
- August 29, 1986
Summary
Radio Communications of the Philippines (RCPI) was held liable for damages when its employees added defamatory Tagalog words to a telegram transmitted to Loreto Dionela. The Supreme Court affirmed the Court of Appeals' decision, finding RCPI directly liable under Articles 19 and 20 of the Civil Code for breach of contract and negligence. The Court applied the master-servant rule, holding that employee negligence in contracts becomes employer negligence. Despite RCPI's defense that the words were a private joke between operators, the Court found the words libelous per se with sufficient publication through accessible office files. The case established corporate liability for employee actions within the scope of business operations, even when such actions exceed assigned duties. Dionela was awarded P15,000 in moral damages and P2,000 in attorney's fees.