Libelous statements, presumption of malice and privileged communication

A Senator who was the Liberal Party (LP) head of the province blamed the then Secretary of Public Works and Communication for the loss of the LP official candidate for governor to the Nacionalista Party candidate during the 1963 local elections. The Cabinet Secretary supported an independent LP candidate, thereby causing the LP votes to be divided. In public statements widely quoted in newspapers, the Senator said that had the Secretary not sabotaged and double-crossed the LP, its official candidate would have won the elections.

The Senator subsequently filed a formal request with the Senate Blue Ribbon Committee to investigate the actions of the Secretary in connection with certain alleged anomalous acquisitions of public works supplies and equipment. Copies of said charges were furnished to the Commission on Appointments with the request that they be considered in passing upon the Secretary’s appointment to the Cabinet.