ANTONINO V VALENCIA

MAY 27, 1974

FACTS:
Lorenzo Sarmiento of the Liberal Party lost to Vicente Duterte of the Nacionalista Party in the
election for governor in Davao.

Subsequently, Senator Antonino issued a statement that the loss was caused by the support given by
Valencia, the Secretary of Public Works, to the independent LP candidate Maglana which caused a
division in LP votes. Antonino was quoted in various newspapers that had Valencia not “Sabotaged”
and “double-crossed” them, the LP would have won.

Antonino then proceeded to file requests to have Valencia investigated by the Senate Blue Ribbon
Committee on alleged anomalous acquisitions of public works supplies and equipment.

Valencia retaliated by issuing a press release that he will also file charges with the Blue Ribbon
Committee regarding anomalous acts of the Senator. This release was published in newspapers

Antonino filed this case of damages. Valencia filed a counter-claim. Lower court ruled in favor of
Antonino. Valencia appealed. Antonino died and was substituted by Senator Antonino (Wife)

ISSUES:
1.W/N the Press Release was issued by Valencia
2.W/N the Press Release is libelous

Held/Ruling:
YES. The fact that Valencia caused the release and publication of the press release is seen in the
following facts:
1.The newspapers reproduced the specific charges filed by Antonino.

2.On the press release there was marked “For release” under the date.

3.It was indicated on the press release the answers made by Valencia to the charges of Antonino in
the same numerical order.

4.The press release indicated that it came from Valencia

5.The press release quoted Valencia and he admitted making the statement in his office in the
presence of the press
6.The first page of the press release consisted of quoted statements by Valencia and reports and
information he received about Antonino

7.The press release mentioned specific figures which only Valencia could know given the time
constraint

8.Valencia did not make any correction or denial of the published statement.

YES. The statements issued were defamatory and libelous in nature as they imputed upon him
certain corrupt practices. Also, because the statement was not issued privately or officially, malice is
presumed and such presumption was not overcome as
Valencia did not prove the truth of his statements or that they were published with good intentions
and with a justifiable motive or that they were made in the exercise of the right of fair comment on
the character, good faith, ability and sincerity of public officials.
The court said that had Valencia not been motivated with malice he would have filedcharges against
Antonino with the Senate seeing as Antonino was not a candidate forelection and that his term as
senator was no yet to expire.

Also, Valencia cannot claim that his actions were justified in that Antonino was first in making
libelous statements. The anomalous transactions charge was duly filed with the Blue Ribbon.

Also, the statement on sabotage and double crossingcannot be considered libelous ascontemporary
politics shows that no stigma of disgrace or disrepute befalls one who changes political parties.