Fact: Petitioner’s broadcasters Rima ang Alegre broadcast in two separated dates malicious and libelous remarks against the respondent and its owner. Respondent filed an action against the petitioner for damages for the libelous remarks. The RTC ruled in favor of the Respondent and award Moral damages to the Respondent only and not its owners. Petitioner and Respondent went to the CA to appeal the case. CA rendered in favor of the Respondent awarding moral damages to it but not its owners. Petitioner went to SC raising the issue that the respondent is Corporation and not entitled to Moral Damages.
Issue: Whether the Respondent, a Corporation is entitled to Moral damages?
Held: Yes, A juridical person is generally not entitled to moral damages because, unlike a natural person, it cannot experience physical suffering or such sentiments as wounded feelings, serious anxiety, mental anguish or moral shock. However, the Court’s statement in Mambulao that “a corporation may have a good reputation which, if besmirched, may also be a ground for the award of moral damages” is an obiter dictum. Nevertheless, AMEC’s claim for moral damages falls under item 7 of Article 2219 of the Civil Code. This provision expressly authorizes the recovery of moral damages in cases of libel, slander or any other form of defamation. Article 2219(7) does not qualify whether the plaintiff is a natural or juridical person. Therefore, a juridical person such as a corporation can validly complain for libel or any other form of defamation and claim for moral damages. Moreover, where the broadcast is libelous per se, the law implies damages. In such a case, evidence of an honest mistake or the want of character or reputation of the party libeled goes only in mitigation of damages. Neither in such a case is the plaintiff required to introduce evidence of actual damages as a condition precedent to the recovery of some damages. In this case, the broadcasts are libelous per se. Thus, AMEC is entitled to moral damages.
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