FILIPINAS BROADCASTING NETWORK, INC. vs.

AGO MEDICAL & EDUCATIONAL CENTER - BICOL

CHRISTIAN COLLEGE OF MEDICINE
G. R. No. 141994, January 17, 2005, 448 SCRA 413

FACTS: Expose is a radio documentary program aired over DZRC-AM which is owned by petitioner
FBNI. In two (2) mornings, the program exposed various alleged complaints from students, teachers and
parents against respondent AMEC and its administrators. Claiming that the broadcasts were defamatory,
AMEC and Ago, Dean of AMECs College of Medicine, filed a complaint for damages against FBNI.
Respondent corporation alleged, among others, that due to the libelous statements, it is entitled for
moral damages.

ISSUE: Whether 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. Nevertheless, AMECs claim for moral damages falls under item 7 of Article 2219
of NCC. 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.