Newspaper AD attacks GOV'T officials re: alleged corruption; Libel

In libel cases against public officials, for liability to arise, the alleged defamatory statement must relate to official conduct, even if the defamatory statement is false, unless the public official concerned proves that the statement was made with actual malice, that is, with knowledge that it was false or not. (Jalandoni vs. Hon. Secretary of Justice, G.R. Nos. 115239-40, 02 March 2000, 327 SCRA 107)

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