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Public Figure Doctrine in Libel Law

Public figure doctrine in libel suits establishes that when the plaintiff is a public figure or official, they must prove actual malice on the part of the defendant for the case to succeed. However, the courts have issued inconsistent rulings on when this doctrine applies, such as to private individuals involved in public issues. This makes it difficult to determine who qualifies as a public figure in libel cases. The study suggests amending laws to provide a clear definition of public figure and the factors that transform a private individual into a public figure.

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Crystal Joy Malizon
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6 views1 page

Public Figure Doctrine in Libel Law

Public figure doctrine in libel suits establishes that when the plaintiff is a public figure or official, they must prove actual malice on the part of the defendant for the case to succeed. However, the courts have issued inconsistent rulings on when this doctrine applies, such as to private individuals involved in public issues. This makes it difficult to determine who qualifies as a public figure in libel cases. The study suggests amending laws to provide a clear definition of public figure and the factors that transform a private individual into a public figure.

Uploaded by

Crystal Joy Malizon
Copyright
© All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd

Malizon, Crystal Joy M.

PUBLIC FIGURE DOCTRINE IN LIBEL SUITS


As a general rule, malice is always presumed in the publication of defamatory
matters in the absence of proof to the contrary. Public figure doctrine, as the exception,
provides that when the plaintiff in a libel suit is a public figure/public official, he must prove
that there is actual malice on the part of the defendant in order for the case to prosper.
Nevertheless, the Court once ruled, in Borjal v. Court of Appeals, that a person even if
not a public official or at least a public figure could still be the subject of public comment
for as long as he was involved in a public issue. Therefore, public figure doctrine is also
applicable in cases where the plaintiff is a private individual who is drawn into a public
controversy and suddenly becomes a public figure. However, the Court has likewise held,
in Yuchengco v. The Manila Chronicle Publishing Corporation, that the said doctrine
cannot be applied automatically to a person even if he is a public officer and even if the
controversy where the latter is involved deals with matters of public concern.
These cases make little sense and are of no help to determine in libel suits
whether the plaintiff is a public figure and could be the subject of public comment. Courts
have been unable to articulate a consistent standard for measuring whether a person
involved in public events automatically waives his right to privacy once involved in such
issue. Courts should make clear that private disputes should not be interpreted as public
controversy solely because the purported dispute draws attention from the public.
This study suggests to amend Article 360 of Revised Penal Code by including the
concrete definition of public figure as well as the factors which transform a private
individual into a public figure.

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