8/31/25, 11:26 AM Navarrete vs.
Court of Appeals
Title
Navarrete vs. Court of Appeals
Case Decision Date
G.R. No. 124245 Feb 15, 2000
A lawyer sued for defamation over harsh statements made during a property annulment
case; court ruled statements were privileged and relevant, denying damages.
Jur.ph - Case Digest (G.R. No. 124245)
Expanded Legal Reasoning Model
Facts:
Background of the Civil Case
Private respondent Leonila E. Generoso initiated Civil Case No. 87-41856 on
September 2, 1987, originally filed against Mr. Frederick S. Pumaren, Mr. Avelino
Profeta, and the Register of Deeds of Metro Manila for annulling a deed of sale
executed over her property on the ground of alleged forgery of her signature.
The subject deed of sale, which included a right to repurchase, was prepared and
notarized by petitioner's firm, placing petitioner, Antonio F. Navarrete, in a critical
position within the litigation.
Inclusion of Petitioner as a Defendant
On December 21, 1987, the complaint was amended to include petitioner and Atty.
Rafael C. Dinglasan as defendants in relation to the alleged forgery and malice
surrounding the deed.
Petitioner subsequently claimed that the testimonials and statements made by
private respondent (in her amended complaint and during hearings) were false,
malicious, and aimed at besmirching his professional reputation.
Alleged Defamatory Statements and Testimonies
Petitioner asserted that private respondent made defamatory remarks during the
hearings on December 14 and December 21, 1987.
Specific quotations from private respondent’s testimony include terms such as
“stupid”, “bastards”, “swindlers”, and “plunderers” – allegedly uttered in reference
to various parties, though not clearly or singularly directed at petitioner.
These demeaning expressions were recorded during questioning on the
identification of signatures and the genuineness of the documents related to the
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8/31/25, 11:26 AM Navarrete vs. Court of Appeals
deed of sale.
Decisions of Lower Courts
On September 27, 1990, the Regional Trial Court of Manila rendered its decision in
Civil Case No. 87-41856:
The deed of sale with the right of repurchase was annulled along with related
title transfers.
Judgment declared Leonila E. Generoso the absolute owner of the property.
The court simultaneously rendered a judgment that awarded petitioner moral
damages of P100,000.00 and attorney’s fees of P20,000.00, despite his role as a
defendant.
On March 14, 1996, the Court of Appeals modified the Regional Trial Court’s ruling
by deleting the award of moral damages and attorney’s fees in favor of petitioner,
while upholding the nullity of the deed and title transfer to the disputed party.
Grounds for Appeal by the Petitioner
Petitioner filed a petition for review contesting the deletion of the damages,
contending that his right to recover moral damages and attorney’s fees was valid.
He argued that the Court of Appeals erred by applying American cases and by
affirming a position that the statements made by private respondent had absolute
privilege, thereby deciding a question of substance not solely determined by the
lower courts or this Honorable Court.
Central to his appeal is the claim that his honor as a lawyer was unjustly and
maliciously impugned by defamatory utterances made in judicial proceedings.
Issues:
Whether the allegedly defamatory statements delivered by private respondent during
judicial proceedings are protected by absolute privilege.
Does the utterance of disparaging words, even if ignominious, fall under the
protections afforded to statements made in court?
Was the relevance of these statements to the issues in the case sufficient to invoke
absolute privilege?
Whether petitioner’s claim for moral damages and attorney’s fees is tenable given the
application of the doctrine of absolute privilege to statements made during judicial
proceedings.
Does the use of harsh and contumacious language automatically give rise to a valid
claim of defamation, notwithstanding the procedural context?
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8/31/25, 11:26 AM Navarrete vs. Court of Appeals
Should the defamatory remarks have been redacted or restrained during the
proceedings to prevent reputational harm?
Whether the reliance on American jurisprudence in determining the absolute
privilege of judicial utterances is appropriate under Philippine law and jurisprudence.
Is it proper to apply comparative law to decide on the boundaries of liability for
statements in court?
Does the Philippine legal system provide a sufficient framework to reject
petitioner’s claim despite the possible injurious nature of the language?
Ruling:
(Subscriber-Only)
Ratio:
(Subscriber-Only)
Doctrine:
(Subscriber-Only)
Note: AI summaries may not capture all details. Please refer to full text for complete accuracy.
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