Under Article 353 of the Revised Penal Code of the Philippines, libel is defined as a

public and malicious imputation of a crime, or of a vice or defect, real or imaginary, or

any act, omission, condition, status or circumstance tending to discredit or cause the
dishonor or contempt of a natural or juridical person, or to blacken the memory of one
who is dead. Thus, the elements of libel are: (a) imputation of a discreditable act or
condition to another; (b) publication of the imputation; (c) identity of the person
defamed; and, (d) existence of malice. [Daez v. Court of Appeals, G.R. No. 47971, 31
October 1990, 191 SCRA 61, 67]
In libel cases, the question is not what the writer of an alleged libel means, but what
the words used by him mean. Jurisprudence has laid down a test to determine the
defamatory character of words used in the following manner, viz:
Words calculated to induce suspicion are sometimes more effective to destroy
reputation than false charges directly made. Ironical and metaphorical language is a
favored vehicle for slander. A charge is sufficient if the words are calculated to induce
the hearers to suppose and understand that the person or persons against whom they
were uttered were guilty of certain offenses, or are sufficient to impeach their honesty,
virtue, or reputation, or to hold the person or persons up to public ridicule. . . .
[Lacsa v. Intermediate Appellate Court, 161 SCRA 427 (1988) citing U.S. v.
OConnell, 37 Phil. 767 (1918)]
An allegation is considered defamatory if it ascribes to a person the commission of a
crime, the possession of a vice or defect, real or imaginary, or any act, omission,
condition, status or circumstances which tends to dishonor or discredit or put him in
contempt, or which tends to blacken the memory of one who is dead.
There is publication if the material is communicated to a third person. It is not
required that the person defamed has read or heard about the libelous remark. What
is material is that a third person has read or heard the libelous statement, for a
mans reputation is the estimate in which others hold him in, not the good opinion
which he has of himself. [Alonzo v. Court of Appeals, 241 SCRA 51 (1995)]
On the other hand, to satisfy the element of identifiability, it must be shown that at
least a third person or a stranger was able to identify him as the object of the
defamatory statement. In the case of Corpus vs. Cuaderno, Sr. (16 SCRA 807) the
Supreme Court ruled that in order to maintain a libel suit, it is essential that the
victim be identifiable (People vs. Monton, L-16772, November 30, 1962), although it
is not necessary that he be named(19 A.L.R. 116). In an earlier case, the high court
also declared that defamatory matter which does not reveal the identity of the
person upon whom the imputation is cast, affords no ground of action unless it be

shown that the readers of the libel could have identified the personality of the
individual defamed. (Kunkle vs. Cablenews-American and Lyons 42 Phil. 760).
This principle has been recognized to be of vital importance, especially where a group
or class of persons, as in the case at bar, claim to have been defamed, for it is evident
that the larger the collectivity, the more difficult it is for the individual member to
prove that the defamatory remarks apply to him. (Cf. 70 ALR 2d. 1384).