Bishop’s libel case vs Aries Rufo dismissed
Two elements of the crime of libel are missing: defamatory imputation and malice

MANILA, Philippines – The Tagaytay City Prosecutor’s Office has dismissed the libel complaint filed by resigned Bishop Teodoro Buhain against the author of the groundbreaking book, “Altar of Secrets,” for lack of probable cause to proceed with the case.

Buhain lodged a libel suit against journalist Aries C. Rufo in July, following the publication and release of the book where he complained he was portrayed “as a dishonest leader of the Catholic Church.”

“Altar of Secrets,” launched in June this year, tackled scandals, misdemeanors, faults and wrongdoings of Church officials and exposed long-held hidden secrets within the Catholic Church. Buhain was among the Church leaders mentioned in the book.

In his complaint, the bishop, who was forced to resign after the retirement of his patron, the late Manila Archbishop Jaime Cardinal Sin, argued that Rufo acted “with obvious malicious intent of exposing the complainant to public hatred, contempt and ridicule” in a number of instances.

In at least 9 instances, Buhain said Rufo wrote statements damaging to his reputation through “unsubstantiated allegations.”

Favored one

As one of the favored ones of Sin, the prelate was given juicy assignments in the Archdiocese of Manila, managing some of the Church’s businesses, including Radio Veritas.

In the book, Rufo wrote that the Church-run radio station was able to collect millions of pesos in donations after the EDSA 2 revolution, but there was no clear accounting where the money went. At that time, Buhain was the general manager of the Church radio station. (READ: A bishop and multimillion-peso donations)

Buhain was also a member of the board of Monte de Piedad bank when it collapsed due to bad and questionable loans to tricycle drivers and teachers. Buhain was charged and penalized by the then Central Bank for the mismanagement of the bank.

Rufo also wrote about the lingering rumors that Buhain had fathered a child which the bishop had vehemently denied.

The author said he sought to get the side of the bishop while working on the book by sending a letter to his residence but Buhain did not reply to the request for an interview.

Following the publication of excerpts from the book in Rappler, Buhain, through his lawyer, Rocherrie Santos Bayot, got in touch with Rufo to explain his side. In that interview, Buhain admitted that he was forced to resign, following the retirement of Sin, as allegations of financial and sexual indiscretions reached the door of the Vatican. (READ: Resigned bishop a ‘victim of church politics‘)

He also said he was banned from saying Mass within the ecclesiastical jurisdiction of the Archdiocese of Manila by retired Manila Archbishop Gaudencio Cardinal Rosales who succeeded Sin.


Despite the publication of his side, Buhain pressed with the filing of a libel complaint. 

He said Rufo was “prompted by personal ill-will, spite and malice” in an effort to discredit him before the public and that he suffered “sleepless nights, wounded feelings, moral and social embarrassment” as a result.

In his counter-argument, through his lawyer Kristine Anne Venzuela, Rufo argued that not all the elements of libel were present in the questioned contents of the book, specifically the fact that Buhain was not able to provide proof that the journalist acted with malice.

As a public figure, Buhain’s actions are of public interest and fair commentary on his character is qualifiedly privileged speech. In previous rulings, the Supreme Court said privileged speech is communication that is “presumably made out of a legal, moral and social duty and thus in good faith.”

Public figure

In a 4-paged resolution dated December 9, Assistant City Prosecutor Edgar Ambagan said that based on the totality of evidence, two elements of the crime of libel were missing: defamatory imputation and malice.

Citing the doctrine of fair comment, Ambagan said that “when the discreditable imputation is directed against a public person in his public capacity, it is not necessarily actionable” even if the imputation is deemed false.

As it is, “the book, Altar of Secrets, essentially deals on matters where Bishop Buhain acted in his official capacity as general manager of Radio Veritas, as director of Monte de Piedad Savings Bank and his participation in the construction of the Pope Pius  XII project. Thus the subject statements may be considered as an expression of opinion based on established facts. Any remark or discussion arising from said issues is logically public in nature since the public in general has interest in the outcome of the same,” the resolution said.

The prosecutor also pointed out that Buhain failed to establish that the journalist “had a grudge against the complainant, nor a rivalry existed between them or there was intent to injure the reputation of the complainant. What is clear is that the respondent  was motivated by his “crusade for reforms in the Church” to which all of us believers belong.”

The resolution was approved by City Prosecutor Ernesto Vida. –

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