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21.

Filipinas Broadcasting Network v Ago Medical besmirched, may also be a ground for the award of moral damages” is an
G.R. 141994 obiter dictum.
January 17, 2005
 Nevertheless, AMEC’s claim for moral damages falls under item 7 of
Topic: Can a corporation recover moral damages Article 2219 of the Civil Code. This provision expressly authorizes the
Petitioners: Filipinas Broadcasting Network recovery of moral damages in cases of libel, slander or any other form of
Respondents: Ago Medical and Educational Center-Bicol Christian College of defamation. Article 2219(7) does not qualify whether the plaintiff is a
Medicine natural or juridical person. Therefore, a juridical person such as a
Ponente: Carpio, J. corporation can validly complain for libel or any other form of
defamation and claim for moral damages.
Doctrine:
 Moreover, where the broadcast is libelous per se, the law implies
Facts: 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
 “Exposé” is a radio documentary program hosted by Carmelo ‘Mel’ Rima damages. Neither in such a case is the plaintiff required to introduce
(“Rima”) and Hermogenes ‘Jun’ Alegre (“Alegre”). Then Rima and Alegre evidence of actual damages as a condition precedent to the recovery of
exposed various alleged complaints from students, teachers and parents some damages. In this case, the broadcasts are libelous per se.
against Ago Medical and Educational Center-Bicol Christian College of
Medicine (“AMEC”) and its administrators.  Thus, AMEC is entitled to moral damages. However, the Court found the
award of P300,000 moral damages unreasonable. The record shows that
 Claiming that the broadcasts were defamatory, AMEC and Angelita Ago even though the broadcasts were libelous per se, AMEC has not suffered
(“Ago”), as Dean of AMEC’s College of Medicine, filed a complaint for any substantial or material damage to its reputation. Therefore, the Court
damages against FBNI, Rima and Alegre on 27 February 1990. reduced the award of moral damages from P300,000 to P150,000.

Issue:

W/N 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.
 The Court of Appeals cites Mambulao Lumber Co. v. PNB, et al. to justify
the award of moral damages. However, the Court’s statement in
Mambulao that “a corporation may have a good reputation which, if