allegation was originally a valid defense only in civil libel cases. Criminal libel was construed as an offence against the public at large based on the tendency of the libel to provoke breach of peace , rather than being a crime based upon the actual defamation per se ; its veracity was therefore considered irrelevant. Section 6 of the Libel Act 1843 allowed the proven truth of the allegation to be used as a valid defense in criminal libel cases, but only if the defendant also demonstrated that publication was for the "Public Benefit". [ 22 ] In some systems, however, notably the Philippines , truth alone is not a defense. [ 23 ] Some U.S. statutes preserve historical common law exceptions to the defense of truth to libel actions. These exceptions were for statements "tending to blacken the memory of one who is dead" or " expose the natural defects of one who is alive". [ 24 ] It is also necessary in these cases to show that there is a well-founded public interest in the specific information being widely known, and this may be the case even for public figures . Public interest is generally not "what the public is interested in", but rather "what is in the interest of the public". [ 25 ] [ 26 ] Noonan v. Staples [ 27 ] is sometimes cited as precedent that truth is not always a defense to libel, but the case is actually not valid precedent on that