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MANILA, Philippines — The Supreme Court of the Philippines has dismissed the long-standing complaint filed by GMA Network Inc. against ABS-CBN Broadcasting Corp. regarding alleged defamatory statements.
In a 12-page decision promulgated on Nov. 8, 2025, penned by Associate Justice Japar Dimaampao, the high court denied two consolidated petitions, namely the complaint for damages initiated by GMA and the subsequent counterclaims filed by ABS-CBN.
The case stemmed from accusations in December 2007 that GMA had manipulated television ratings surveys, a claim GMA argued injured its reputation and corporate character.
The high court ruled that the statements aired by ABS-CBN hosts were protected as "qualified privileged communications," saying that the broadcasts constituted a fair and true report regarding allegations that GMA personnel visited private homes to influence viewership data.
When it started. The legal battle traces back to 2007, when ABS-CBN contracted media research firm AGB Nielsen to provide television ratings for Mega Manila and other urban centers.
To ensure the integrity of the data, the locations of sample households were required to be kept strictly confidential.
However, reports surfaced that individuals allegedly hired by GMA had tracked down these homes, offering residents monthly incentives of P500 in cash and P300 worth of groceries to switch their viewing habits to GMA programs.
Evidence presented during the proceedings included testimony from a GMA employee in Iloilo, who claimed a station manager ordered a team to locate panel homes and offer monetary rewards in exchange for viewership.
Furthermore, AGB Nielsen's then-general manager, Maya Reforma, admitted in a formal letter and radio interview that the panel had indeed been tampered with.
ABS-CBN subsequently aired segments featuring these admissions, which GMA claimed were "deliberately twisted" to imply direct manipulation by the network. This prompted GMA to file a complaint.
However, the Regional Trial Court (RTC) of Quezon City dismissed GMA's complaint, ruling that the statements made by ABS-CBN's hosts and reporters were qualified privileged communications.
The RTC found that the network acted without malice, as the "truth of the contents of the supposed libelous materials was undeniably established" through AGB Nielsen's own data analysis, which confirmed that 82 panel homes had been exposed to GMA's promotional efforts. This ruling was affirmed by the Court of Appeals, putting emphasis on the legal protections afforded to the broadcasts.
Ruling. The high court affirmed both the rulings of the RTC and the Court of Appeals.
It explained that while defamatory imputations are generally presumed malicious, "qualified privileged communications" serve as an exception unless proven to be made with actual malice or bad faith.
"The general rule is that every defamatory imputation is presumed to be malicious, except when it involves privileged communication, which is of two kinds: absolute and qualified. Qualified privileged communications are those which, although containing defamatory imputations, would not be actionable unless made with malice or bad faith," the high court explained.
The high court explained that the remarks made by ABS-CBN's hosts during the segment were supported by documentary evidence and the data analysis report provided by AGB Nielsen.
Consequently, the Supreme Court found no malice in the broadcasts, noting that the comments fell under the "fair comment doctrine."
"Certainly, the subject statements are covered by the fair comment doctrine because GMA is a public figure and a mass media entity operating in an industry impressed with public interest," the high court's ruling read.
The Supreme Court also rejected ABS-CBN's counterclaims for damages, noting that GMA's initial filing was based on a legitimate, albeit unsuccessful, belief that its cause of action was valid.
"Apropos ABS-CBN's counterclaims, the RTC and CA unerringly decreed the dismissal thereof for lack of factual basis. While ABS-CBN anchors its counterclaims on the 'baselessness' of GMA's complaint, the fact remains that GMA was able to establish a cause of action against it based on the notion that the statements aired on its programs were defamatory," the high court's ruling read.
