If you just make something up with no backup, and it turns out to be false, that's malice.
I am hesitant to argue law with an experienced lawyer, having only taken one class related to this, but I believe malice carries the additional implication of intent to harm someone. Newspapers can always fall back on the claim that they reported this horrible story, which they believed to be true, because they felt it was newsworthy. And if it's proven they were making it up, well, then they can say they were providing entertainment. It's very possible the Enquirer uses those lawyers to vet stories about private individuals or to make sure they don't cross some excessive line with celebrities, but almost anyone whose names in the Enquirer we'd recognize couldn't win a libel suit.