Knowledge, participation, approval NOT required to convict for LIBEL

To sustain a conviction for libel, proof of knowledge of and participation in the publication of the offending article is not required, if the accused has been specifically identified as “author, editor, or proprietor” or “printer/publisher” of the publication. “Article 360 is clear and unambiguous, and to apply People v. Beltran and Soliven, which requires specific knowledge, participation, and approval on the part of the publisher to be liable for the publication of a libelous article, would be reading into the law an additional requirement that was not intended by it.” (Fermin vs. People, G.R. No. 157643, 28 March 2008; Tulfo vs. People, G.R. No. 161032, 16 September 2008)