We note that the publications or articles in question are neither private communications nor true reports of official proceedings without any comments or remarks. However, this does not necessarily mean that the questioned articles are not privileged. The enumeration under Art. 354 is not an exclusive list of qualified privileged communications since fair commentaries on matters of public interest are likewise privileged and constitute a valid defense in an action for libel or slander. (Villanueva v. PDI, G.R. No. 164437, May 15, 2009)
Monday, June 22, 2009
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