Actual malice rule in LIBEL; Provably false factual connotation rule

The “actual malice” rule to apply not only to public officials, but also to public figures. If the statements made against the public figure are essentially true, then no conviction for libel can be had. Any statement that does not contain a provably false factual connotation will receive full constitutional protection. (Guingguing vs. Court of Appeals, G.R. No. 128959, 30 September 2005, 471 SCRA 196)

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