Does the doctrine of libel per se apply to damages for false statements?

^8. Lutfi has also invoked the doctrine of libel per se, which allows for the recovery of general damages based on the intrinsically defamatory nature of the false statements. (Allard v. Church of Scientology (1976) 58 Cal.App.3d 439, 450 ["In matters of slander that are libelous per se, for example the charging of a crime, general damages have been presumed as a matter of law"].) Because Lutfi has set forth sufficient evidence to support a prima facie case of damages, we need not reach this issue.