party recognized himself as the person attacked or defamed, but it must be shown that

at least a third person could identify him as the object of the libelous publication. These
requisites have not been complied with in the case at bar. The element of identifiability
was not met since it was Wenceslaso who revealed he was the organizer of said
conference and had he not done so the public would not have known.

The concept of privileged communications is implicit in the freedom of the press and
that privileged communications must be protective of public opinion. Fair commentaries
on matters of public interest are privileged and constitute a valid defense in an action
for libel or slander. The doctrine of fair comment means that while in general every
discreditable imputation publicly made is deemed false, because every man is
presumed innocent until his guilt is judicially proved, and every false imputation is
deemed malicious, nevertheless, when the discreditable imputation is directed against
a public person in his public capacity, it is not necessarily actionable. In order that such
discreditable imputation to a public official may be actionable, it must either be a false
allegation of fact or a comment based on a false supposition. If the comment is an
expression of opinion, based on established facts, then it is immaterial that the opinion
happens to be mistaken, as long as it might reasonably be inferred from the facts.

The questioned article dealt with matters of public interest as the declared objective of
the conference, the composition of its members and participants, and the manner by
which it was intended to be funded no doubt lend to its activities as being genuinely
imbued with public interest. Respondent is also deemed to be a public figure and even
otherwise is involved in a public issue. The court held that freedom of expression is
constitutionally guaranteed and protected with the reminder among media members to
practice highest ethical standards in the exercise thereof.

SECOND DIVISION Coverage under the SSS is compulsory for all employers in the private sector and their
employees who are not over 60 years of age, whether with permanent or provisional
G.R. No. 126466 January 14, 1999 employment status, including domestic helpers earning at least PhP1,000 a month. All
ARTURO BORJAL a.k.a. ART BORJAL and MAXIMO SOLIVEN, petitioners, self-employed persons are also subject to mandatory coverage under the Regular Self
vs. Employed Program for artists, entertainers, proprietors and professionals, and the
COURT OF APPEALS and FRANCISCO WENCESLAO, respondents. Expanded Self Employed Program for those with monthly earnings of at least PhP1,000
regardless of trade, business or occupation. Farmers and fishermen earning at least
BELLOSILLO, J.: PhP1,500 also fall under the self-employed category.

Coverage under the SSS may also be on a voluntary basis as for the following: Filipino
Facts: A civil action for damages based on libel was filed before the court against Borjal workers recruited by foreign-based employers for work abroad, SSS members
and Soliven for writing and publishing articles that are allegedly derogatory and separated from employment but would like to continue paying contributions, and non-
offensive against Francisco Wenceslao, attacking among others the solicitation letters working spouses of SSS members (i.e., spouses who devote full time to managing the
he sends to support a conference to be launch concerning resolving matters on household and family affairs).
transportation crisis that is tainted with anomalous activities. Wenceslao however was
never named in any of the articles nor was the conference he was organizing. The
lower court ordered petitioners to indemnify the private respondent for damages which
was affirmed by the Court of Appeals. A petition for review was filed before the SC
contending that private respondent was not sufficiently identified to be the subject of
the published articles.

Issue: Whether there are sufficient grounds to constitute guilt of petitioners for libel.

Held: In order to maintain a libel suit, it is essential that the victim be identifiable
although it is not necessary that he be named. It is also not sufficient that the offended