FACTS:

A libel case was filed against Carson Taylor, who was the acting editor, proprietor, manager, printer and
publisher of a Manila Daily Bulletin. The complaint alleges that he, on September 25, 1913, intended to
impeach the honesty, virtue and reputation of Ramon Sotelo as well as to expose him to public hatred,
contempt and ridicule by composing, printing, editing, publishing, circulating and/ or procuring to
compose an article, which they have alleged to be false and to be a malicious defamation and libel of
Ramon Sotelo. According to the article entitled Owners fired building to collect insurance, criminal
charges follows civil suit, there was a conspiracy to defraud the insurance company. The house in Calle
ODonnell was intentionally burnt and claims were made from the insurance companies. In this
conspiracy, the name of Ramon Sotello was implicated and was therefore charged with conspiracy and
fraud. Taylor was found guilty and sentenced to pay a fine of P200.He then appealed and made
assignment of errors.

ISSUES:
1. Whether or not the defendant was responsible for and guilty of alleged libel
2. Whether or not the defendant is the proprietor and publisher of Manila Daily Bulletin
HELD: The court ruled in favor of the defendant and ordered that the ruling of the lower court be
reversed. According to Act No. 277 Section Six, every author, editor or proprietor of any book,
newspaper, or serial publication is chargeable with the publication of any words contained in any part
of said book or number of each newspaper or serial as fully as if he were the author of the same.
However, in this case, the Solicitor-General said that no one is represented to be the author, editor and
proprietor. There was no word of proof in the record showing that he was either the author, editor or
proprietor. It only mentioned that the defendant was the manager. There was no proof that he as the
manager was directly responsible for writing, editing or publishing the contents in the alleged libelous
article. The prosecution only presented the newspaper to show the relationship of the defendant to it.
However, this only proves the relationship between the defendant and the publication. In the absence
of proof of a single letter showing the direct relationship and role of the defendant on the publication of
the said article, presumptions of his involvement would be unwarranted and unjust.