A different standard in Gertz v Welch

There was a new twist in the series of rulings handed down by the United States Supreme Court since the promulgation of New York Times Co. v. L.B. Sullivan ruling in 1964.
In the chronology of decisions, the prevailing doctrine then was the rule in Rosenbloom v. Metromedia Inc. which laid down what I would describe as the "public interest" test.
In Rosembloom the United States Supreme Court ruled that the actual malice standard applies if the publication that contained defamatory falsehoods was one of public interest.
Here the "status-of-the-plaintiff" standard was sent to the back burner.
Remember, in Rosembloom v Metromedia Inc. the Supreme Court said: "If a matter is a subject of public or general interest, it cannot suddenly become less so merely because a private individual is involved, or because in some sense the individual did not "voluntarily" choose to become involved".
The Supreme Court iin Rosembloom continued: "Whether the person involved is a famous large-scale magazine distributor or a "private" businessman running a corner newsstand has no relevance in ascertaining whether the public has an interest in the issue. We honor the commitment to robust debate on public issues, which is embodied in the First Amendment, by extending constitutional protection to all discussion and communication involving matters of public or general concern, without regard to whether the persons involved are famous or anonymous."
This ruling did not sit well with many quarters, including the Supreme Court.
That is why the ruling in Gertz v Welch (1974) becomes very significant. It laid down a different standard in deciding defamation cases when the case involves private individuals (those who are not public officials nor public figures)
In short, the Gertz ruling, the Supreme Court required a less demanding standard for plaintiffs who are private indivudals, in order to vindicate injury to reputation resulting from defamatory falsehoods.
I think it is fair to say that the Gertz ruling discarded the ever-expansive standard in Rosembloom v Metromedia Inc.
The Gertz v. Welch ruling is signifcant to Philippine law, because it allows a comparison as to how Philippine jurisprudence has dealt with defamation cases.
The Gertz decision also is quite instructive because it provides a graphic description of who a private individual is (in contrast to a public figure), in defamation cases.
Does Philippine jurisprudence follow the discarded Rosembloom (public interest) doctrine? Or does Philippine jurisprudence follow the Gertz standard?
This will be answer when we start comparing Philippine defamation cases with their American counterparts.
I will be posting my digest of the 1974 Elmer Gertz v. Robert Welch ruling subsequent to this.