Thursday, January 23, 2014

Newsweek v. IAC

Facts:
·          "An Island of Fear" was published by Newsweek in its  Feb 23, 1981. It allegedly portrayed the island province of Negros Occidental as a place dominated by big landowners or sugarcane planters who not only exploited the impoverished workers, but also brutalized and killed them with impunity. #peachesdiaries
·          Newsweek filed a motion to dismiss on the grounds that
o    the printed article sued upon is not actionable in fact and in law;
o    the complaint is bereft of allegations that state, much less support a cause of action.
·          Trial court denied the motion to dismiss. Complaint on its face states a valid cause of action; and the question as to whether the printed article sued upon its actionable or not is a matter of evidence.
·          Petitioner: Complaint failed to state a cause of action because:
o    Complaint made no allegation the article referred specifically to any one of the private respondents;
o    Libel can be committed only against individual reputation;
o    in cases where libel is claimed to have been directed at a group, there is actionable defamation only if the libel can be said to reach beyond the mere collectivity to do damage to a specific, individual group member's reputation.
Issue: WON the complaint must be dismissed? YES.
·          Corpus vs. Cuaderno, Sr.: 
o    "in order to maintain a libel suit, it is essential that the victim be identifiable, although it is not necessary that he be named (19 A.L.R. 116)."
·          Uy Tioco vs. Yang Shu Wen:
o    Defamatory remarks directed at a class or group of persons in general language only, are not actionable by individuals composing the class or group unless the statements are sweeping.
·          The case at bar is not a class suit. It is not a case where one or more may sue for the benefit of all
·          We have here a case where each of the plaintiffs has a separate and distinct reputation in the community. They do not have a common or general interest in the subject matter of the controversy.


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