A Quezon City court has ordered Lorraine Badoy and Jeffrey Celiz, commentators at Sonshine Media Network International (SMNI), to pay TV journalist Atom Araullo a total of P2 million in damages for “abusing” their right to free speech by falsely accusing him of supporting the communist insurgency.
Judge Dolly Rose Bolante-Prado of the Quezon City Regional Trial Court Branch 306 ruled in favor of Araullo, citing “grave damage and injury” caused by Badoy and Celiz’s defamatory statements made during the SMNI program Laban Kasama ang Bayan and in a Facebook video.
“The exercise of free speech must be based on facts and should not cross into defamation,” the court said. “By engaging in Red-tagging, the defendants deliberately sought to discredit and inflict harm on (Araullo).”
Basis for Decision
The court emphasized that Red-tagging—linking individuals or groups to communist rebel organizations without evidence—is a form of bad faith. It noted that the allegations against Araullo were baseless and intended to harm his reputation as a journalist.
Their accusations also extended to Araullo’s mother, activist Carol Araullo, who was labeled an “urban infiltrator” and allegedly a senior figure in the Communist Party of the Philippines-New People’s Army-National Democratic Front of the Philippines (CPP-NPA-NDFP).
The court found that these statements fueled public hostility and threats against both Araullo and his family, disrupting their family relations and causing severe emotional distress, including sleepless nights, anxiety, and humiliation.
Damages and Penalties
Badoy and Celiz were ordered to pay a total of P2.08 million in nominal, moral, and exemplary damages, along with attorney’s fees. The amount will accrue a 6% annual interest until fully paid.
The court concluded that the defendants’ gross recklessness warranted exemplary damages to deter others from engaging in similar conduct.
Legal Framework
Araullo’s lawsuit, filed in September 2023 with Antonio La Viña as counsel, invoked key provisions of the Civil Code, including:
Sections 19, 20, and 21 (abuse of civil rights),
Section 26 (protection of dignity, privacy, and peace of mind), and
Section 33 (damages in defamation cases).
The court’s decision underscores the principle that freedom of speech comes with responsibility and cannot be misused to harm others through baseless and malicious accusations.