G.R. No. 141994, 17 January 2005


Exposé is a radio documentary program hosted by Carmelo Rima and Hermogenes Alegre. Exposé is aired every morning over DZRC-AM which is owned by Filipinas Broadcasting Network, Inc. (FBNI). Exposé is heard over Legazpi City, the Albay municipalities and other Bicol areas.

Rima and Alegre exposed various alleged complaints from students, teachers and parents against Ago Medical and Educational Center-Bicol Christian College of Medicine (AMEC) and its administrators. Claiming that the broadcasts were defamatory, AMEC and the dean of AMEC’s College of Medicine, filed a complaint for damages against FBNI, Rima and Alegre.


Whether AMEC is entitled to moral damages.


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, 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.

*Case digest by Teonilo M. Bagalanon Jr., JD – 4, Andres Bonifacio College, SY 2019 – 2020