Political Law 2 Case 7 NORBERTO QUISUMBING, petitionerappellant,!s" EUGENIO LOPE#, ET $L", respon%entsappellees &$CTS' 1. The respondent respondents s Eugenio Lopez, Lopez, Ernesto del Rosario Rosario and Roberto Roberto Villanueva Villanueva are the publisher, publisher, editor-in-chief, and general manager respectively of The anila !hronicle, a daily ne"spaper published and circulated in English in the !ity of anila. #n $uly 1%, 1&'&, the petitioner, (orberto )uisumbing, *led a complaint against said respondents in the !ourt of +irst nstance of anila for the recovery of damages in the sum of %, as a result of the follo"ing alleged libelous publication in The anila !hronicle of (ovember /,1&'/.0( E( R23 #++!E4 #+ 5 !T6 747RER48 9. 2fter ans"er and trial the !ourt of +irst nstance of anila rendered a :udgment dismissing the complaint from "hich the petitioner appealed to the !ourt of 2ppeals. The latter !ourt, in its decision promulgated on $anuary 1&, 1&%5, a;rmed the :udgment of the court of origin< and the case is no" before us on petition for revie" on certiorari certiorari *led by the petitioner petitioner.. 5. The !ourt of 2ppeals found 8that the conte=t of the article in >uestion, is a fair, impartial and true report of o;cial or public proceeding authorized by la". The ne"s item "as the result of a press release in connection "ith an o;cial investigation of the 2nti-7sury 3ivision, (..., and "as a substantial, if not a faithful reproduction of the said press release "hich "as, in turn, an accurate report of the o;cial proceedings ta?en by the 2nti-7sury 3ivision. The article merely reported a raid on the @business o;ces of three alleged money lenders@< and related the steps actually ta?en or to be ta?en by the proper o;cials relative to the investigation. t did not go beyond the actual report of o;cial actuations. ISSUE' Ahether or not The anila !hronicleBs published article "ith a malicious headline is liable of ISSUE' Ahether libelC (EL)' (#. (EL)' (#. The elements of libel are (#T present. iD
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eadlin eadl ines es "hic "hich h are are volun voluntar tarily ily def defam amato atory ry sta state teme ments nts of the the publi publish sher er are are no nott priv privile ilege ged d even though they head a privileged report of a :udicial or other public proceedings. t is not necessary to reiterate the rule that the headline of an article might be libelous "hile the body of the article is privileged. The "hole libel might be included in the headlines. 2 publication claimed to be defamatory must be read and construed in the sense in "hich the readers to "hom it is addressed "ould ordinarily understand it. 4o, the "hole item, including display lines, should be read and construed together, and its meaning and signi*cation thus determined. The he head adli line ne of of an art artic icle le or par paragr agrap aph, h, bei being ng so so consp conspic icuo uous us as to to attra attract ct the the att atten entio tion n of persons "ho loo? casually over a paper "ithout carefully reading all its contents, may in itself inFict very serious in:ury upon a person, both because it may be the only part of the article "hich is read, and because it may cast a graver imputation than all the other "ords follo"ing it. There is no doubt that in publications concerning private persons, as "ell as in all other publications "hich are claimed to be libelous, the headlines directing the attention to the publication may be considered as a part of it and even :ustify a court in regarding the publication as libelous "hen the body of the article is not necessarily so. f so, the petitioner@s positions "ould be untenable, since by reading merely the headline in >uestion nobody "ould even suspect that the petitioner "as referred to< and 8libel cannot be committed e=cept against somebody and that somebody must be properly identi*ed.8 t
may be insisted that the identity of the petitioner is revealed in the body of the ne"s item, but "e should remember that no"here in the conte=t is the petitioner portrayed as one charged "ith or convicted of the crime of usury
