February 27, 1912
FACTS:
Dean Worcester, a member of the Civil Commission of the Philippines and Secretary of the Interior, filed a civil complaint against Martin Ocampo and eight others as editors, writers and administrators of newspapers “El Renacimiento” and “Muling Pagsilang.”
The papers published an editorial about a bird of prey, an eagle, committing all sorts of abuse. Worcester claimed that the editorial alluded to him as understood by the public and had made it difficult to do his job. Said editorial also made him so unpopular as to destroy public confidence in his position.
The editors and writers of the two newspapers argued Worcester's complaint was vague and unintelligible, and that the bird did not refer to a determinate person.
The Court of First Instance (CFI) Manila ruled that even though Worcester was not referred to by name, an action for libel may still be maintained for the publication of the article. The CFI also awarded damages amounting to P100,000. Hence, the instant petition.
ISSUE:
Whether the defendants may be held jointly and severally liable? -- YES.
HELD:
As a general rule, joint tortfeasors are all the persons who command, instigate, promote, encourage, advise, countenance, cooperate in, aid or abet the commission of a tort, or who approve of it after it is done, if done for their benefit. They are each liable as principals, to the same extent and in the same manner as if they had performed the wrongful act themselves.
If several persons jointly committed a tort, the plaintiff may sue all or some of the parties jointly, or all of them individually. There is no pro rata division of damages from the court; such arrangement may only exist among themselves.