Title
Jimenez vs. Cabangbang
Case Decision Date
G.R. No. 15905 Aug 3, 1966
Plaintiffs file a civil action for damages against a member of the House of
Representatives for publishing a letter, but the Supreme Court rules in favor of
the defendant, stating that the publication was not a privileged communication
and the letter was not libelous.
Case Summary (G.R. No. 15905)
Case Background and Parties Involved
The case of Jimenez v. Cabangbang involves a civil action for damages filed by
plaintiffs Nicanor T. Jimenez, Carlos J. Albert, and Jose L. Lukban against defendant
Bartolome Cabangbang.
Main Issues in the Case
The main issues in the case are whether the publication in question is a privileged
communication and whether it is libelous.
Privileged Communication Defense
The defendant, Bartolome Cabangbang, argued that the publication was privileged
under Article VI, Section 15 of the Constitution, which grants immunity to Senators
and Members of the House of Representatives from arrest and questioning for any
speech or debate made in Congress.
Court's Determination on Privileged Communication
The court determined that the publication in question did not fall within the purview
of privileged communication.
The court found that the defendant was not performing his official duty as a member
of Congress or as an officer of any Committee when he caused the communication to
be published.
Therefore, the communication was not absolutely privileged.
Examination of Libelous Nature of the Publication
The court then examined whether the publication was libelous.
The letter described alleged operational plans by certain AFP officers and civilian
political strategists.
It mentioned the involvement of the plaintiffs as being under the control of the
"planners" and belonging to the "Vargas-Arellano clique."
However, the letter also stated that it was possible that the plaintiffs were unwitting
tools of the plan and may have no knowledge of it.
Court's Conclusion on Libelous Nature
Based on the contents of the letter, the court concluded that it was not sufficient to
support the plaintiffs' action for damages.
The court considered the statement that the plaintiffs might be unaware of the
alleged plans and could be unwitting tools as not derogatory enough to entitle the
plaintiffs to recover damages.
The court took into account that the plaintiffs were officers of the Armed Forces and
under the control of the Secretary of National Defense and the Chief of Staff.
Dismissal of the Complaint
The court affirmed the dismissal of the complaint, stating that the allegations made
by the plaintiffs were inconsistent with the contents of the letter, which was the
basis of their complaint.
The court found that the letter did not support the claim that the plaintiffs'
reputation was being impeached or that they were exposed to public hatred,
contempt, dishonor, and ridicule.
Court's Final Determination
In conclusion, the court determined that the publication was not a privileged
communication and that the plaintiffs' action for damages was not supported by the
contents of the letter.
The dismissal of the complaint was affirmed.
