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Cybercrime Prevention Act of 2012

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TheCybercrime Prevention Act of 2012,officially recorded asRepublic Act No. 10175,is alawin thePhilippinesthat was approved by PresidentBenigno Aquino IIIon September 12, 2012. It aims to address legal issues concerning online interactions and theInternet in the Philippines.Among the cybercrime offenses included in the bill arecybersquatting,cybersex,child pornography,identity theft,illegal access to data andlibel.[1]

Cybercrime Prevention Act of 2012
Congress of the Philippines
  • An Act Defining Cybercrime, Prevention, Investigation, Suppression and the Imposition of Penalties Therefor and for Other Purposes
CitationRepublic Act 10175
Territorial extentPhilippines
Enacted byHouse of Representatives
Enacted bySenate
Signed byBenigno Aquino III
SignedSeptember 12, 2012
CommencedOctober 3, 2012[note 1]
Legislative history
First chamber:House of Representatives
BilltitleSame title as final law
Bill citationHouse Bill 5808[note 2]
Introduced bySusan Yap(Tarlac 2nd District)
IntroducedFebruary 9, 2012
First readingFebruary 13, 2012
Second readingMay 9, 2012
Third readingMay 21, 2012
Committee reportJoint Explanation of the Conference Committee: 1323–1327 
Second chamber:Senate
Bill titleSame title as final law
Bill citationSenate Bill 2796
Received from theHouse of RepresentativesMay 3, 2011
Member(s) in chargeEdgardo Angara
First readingJune 27, 2011
Second readingJune 30, 2011
Third readingJuly 10, 2011
Final stages
Reported fromconference committeeMay 30, 2012
Conference committee bill passed byHouse of RepresentativesJune 4, 2012
Conference committee bill passed bySenateJune 26, 2011
Status:In force

While hailed for penalizing illegal acts done via the Internet that were not covered by old laws, the act has been criticized for its provision on criminalizing libel, which is perceived to be a curtailment of thefreedom of expression— "cyberauthoritarianism".[2]Its use against journalists likeMaria Ressa,ofRappler,has drawn international condemnation.[3][4]

On October 9, 2012, theSupreme Court of the Philippinesissued a temporary restraining order, stopping implementation of the Act for 120 days, and extended it on February 5, 2013 "until further orders from the court."[5][6]

On February 18, 2014, the Supreme Court upheld most of the sections of the law, including the controversial cyberlibel component.[7][note 1]

History

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The Cybercrime Prevention Act of 2012 is one of the first laws in the Philippines which specifically criminalizescomputer crime,which prior to the passage of the law had no strong legal precedent in Philippine jurisprudence. While laws such as the Electronic Commerce Act of 2000 (Republic Act No. 8792)[8]regulated certain computer-related activities, these laws did not provide a legal basis for criminalizing crimes committed on a computer in general: for example, Onel De Guzman, the computer programmer charged with purportedly writing the ILOVEYOUcomputer worm,was ultimately not prosecuted by Philippine authorities due to lack of legal basis to charge him under existing Philippine laws at the time of his arrest.[9]

The first drafts of the Anti-Cybercrime and Data Privacy Acts started in 2001 under the Legal and Regulatory Committee of the former Information Technology and eCommerce Council ([ITECC) which is the forerunner of the Commission on Information and Communication Technology (CICT) and now theDepartment of Information and Communications Technology(DICT) It was headed by former Secretary Virgilio "Ver" Peña, with the Legal and Regulatory Committee chaired by Atty. Claro Parlade. The creation of the laws was an initiative of the Information Security and Privacy Sub-Committee chaired by Albert P. dela Cruz who was then president of the Philippine Computer Emergency Response Team (PHCERT), together with Anti-Computer Crime and Fraud Division (ACCFD) Chief, Elfren Meneses of theNational Bureau of Investigation(NBI). The administrative and operational functions was provided by the Presidential Management Staff (PMS) acting as the CICT secretariat.[10]The initial version] of the law was communicated to various other organizations and special interest groups during that time.

This was superseded by several cybercrime-related bills filed in the14thand15th Congress.The Cybercrime Prevention Act ultimately was the product of House Bill No. 5808, authored by RepresentativeSusan Yap-Sulitof thesecond district of Tarlacand 36 other co-authors, and Senate Bill No. 2796, proposed by SenatorEdgardo Angara.Both bills were passed by their respective chambers within one day of each other on June 5 and 4, 2012, respectively, shortly after theimpeachment of Renato Corona,and the final version of the Act was signed into law by PresidentBenigno Aquino IIIon September 12.

Provisions

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The Act, divided into 31 sections split across eight chapters, criminalizes several types of offense, includingillegal access(hacking),data interference,device misuse,cybersquatting,computer-related offenses such ascomputer fraud,content-related offenses such ascybersexandspam,and other offenses. The law also reaffirms existing laws againstchild pornography,an offense under Republic Act No. 9775 (the Anti-Child Pornography Act of 2009), andlibel,an offense under Section 355 of theRevised Penal Code of the Philippines,also criminalizing them when committed using a computer system. Finally, the Act includes a "catch-all" clause, making all offenses currently punishable under the Revised Penal Code also punishable under the Act when committed using a computer, with more severe penalties than what was provided by the Revised Penal Code alone.

The Act hasuniversal jurisdiction:its provisions apply to all Filipino nationals regardless of the place of commission. Jurisdiction also lies when a punishable act is either committed within the Philippines, whether the erring device is wholly or partly situated in the Philippines, or whether damage was done to any natural or juridical person who at the time of commission was within the Philippines.Regional Trial Courtsshall have jurisdiction over cases involving violations of the Act.

A takedown clause is included in the Act, empowering theDepartment of Justiceto restrict and/or demand the removal of content found to be contrary to the provisions of the Act, without the need for a court order. This provision, originally not included in earlier iterations of the Act as it was being deliberated through Congress, was inserted duringSenatedeliberations on May 31, 2012.[11]Complementary to the takedown clause is a clause mandating the retention of data on computer servers for six months after the date of transaction, which may be extended for another six months should law enforcement authorities request it.

The Act also mandates theNational Bureau of Investigationand thePhilippine National Policeto organize a cybercrime unit staffed by special investigators whose responsibility will be to exclusively handle cases pertaining to violations of the Act, under the supervision of the Department of Justice. The unit is empowered to, among others, collect real-time traffic data from Internet service providers with due cause, require the disclosure of computer data within 72 hours after receipt of a court warrant from a service provider, and conduct searches and seizures of computer data and equipment.

The enactment of Republic Act 10867 (The National Bureau of Investigation Reorganization and Modernization Act) empowers the NBI to have the primary jurisdiction in investigating violations of Republic Act 10175 (Cybercrime Prevention Act 2012).

Reaction

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The new Act received mixed reactions from several sectors upon its enactment, particularly with how its provisions could potentially affect freedom of expression,freedom of speechanddata securityin the Philippines.

Thelocal business process outsourcing industryhas received the new law well, citing an increase in the confidence of investors due to measures for the protection of electronic devices and online data.[12]Media organizations and legal institutions though have criticized the Act for extending the definition of libel as defined in theRevised Penal Code of the Philippines,which has been criticized by international organizations as being outdated:[13]the United Nations for one has remarked that the current definition of libel as defined in the Revised Penal Code is inconsistent with theInternational Covenant on Civil and Political Rights,and therefore violates the respect of freedom of expression.[14]

SenatorEdgardo Angara,the main proponent of the Act, defended the law by saying that it is a legal framework to protect freedoms such as the freedom of expression. He asked the Act's critics to wait for the bill's implementing rules and regulations to see if the issues were addressed.[15]He also added that the new law is unlike the controversialStop Online Piracy ActandPROTECT IP Act.[16]However, SenatorTG Guingonacriticized the bill, calling it a prior restraint to the freedoms of speech and freedom of expression.[17]

TheElectronic Frontier Foundationhas also expressed concern about the Act,[18]supporting local media and journalist groups which are opposed to it. The Centre for Law and Democracy also published a detailed analysis criticizing the law from a freedom of expression perspective.[19]

Malacañanghas attempted to distance itself from the law; after the guilty verdict was rendered in theMaria Ressa cyberlibel case,presidential spokesmanHarry Roqueblamed President Duterte's predecessor,Noynoy Aquino,for any negative effects of the law.[20]

Constitutionality

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Several petitions were submitted to theSupreme Courtquestioning the constitutionality of the Act.[21]On October 2, the Supreme Court initially deferred action on the petitions, citing an absence of justices which prevented the Court from sittingen banc.[22]The initial lack of atemporary restraining ordermeant that the law went into effect as scheduled on October 3. In protest, Filipino netizens reacted by blacking out theirFacebookprofile pictures and trending thehashtag#NoToCybercrimeLaw onTwitter.[23]"Anonymous"also defaced government websites, including those of theBangko Sentral ng Pilipinas,theMetropolitan Waterworks and Sewerage Systemand theIntellectual Property Office.[24]

On October 8, 2012, theSupreme Courtdecided to issue atemporary restraining order,pausing implementation of the law for 120 days.[25]In early December 2012, the government requested the lifting of the TRO,[26]which was denied.[27]Over four hours oforal argumentsby petitioners were heard on January 15, 2013, followed by a three-hour rebuttal by theOffice of the Solicitor General,representing the government, on January 29, 2013.[28]This was the first time in Philippine history that oral arguments were uploaded online by the Supreme Court.[29]

Disini v. Secretary of Justice

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Main article:Disini v. Secretary of Justice

On February 18, 2014, the Supreme Court ruled that most of the law was constitutional, although it struck down other provisions, including the ones that violateddouble jeopardy.[7][30][note 1]Notably, likes and "retweets"of libelous content, originally themselves also criminalized as libel under the law, were found to be legal.[30]Only justiceMarvic Leonendissented from the ruling, writing that he believes the whole idea of criminal libel to be unconstitutional.[31]

Whilemotions for reconsiderationwere immediately filed by numerous petitioners, including theCenter for Media Freedom and Responsibility,they were all rejected on April 22, 2014.[32][33]However, justiceArturo Brion,who originally wrote a separate concurring opinion, changed his vote to dissent after reconsidering whether it was just to impose higher penalties for cyberlibel than for regular libel.[34]

Effects

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Cyberlibel

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On May 24, 2013, theDOJannounced they would seek to drop the online libel provisions of the law, as well as other provisions that "are punishable under other laws already", likechild pornographyandcybersquatting.The DOJ said it would endorse revising the law to the16th Congress of the Philippines,[35][36]but cyberlibel remains on the books as a crime in the Philippines, and has been charged by DOJ prosecutors multiple times since then.[37]SenatorTito Sottois primarily responsible for the cyberlibel provision, which he added after social media comments accusing him of plagiarism;[35]he has defended his authorship of the last minute amendment, asking reporters if it was fair that "just because [bloggers] are now accountable under the law, they are angry with me?"[38]While libel had been a crime in the Philippines since theAmerican imperial period,before cyberlibel it had a penalty of minimum or mediumprisión correccional(six months to four years and two months), but now has a penalty ofprisión mayor(six to twelve years).[39][40][1]

Online posts do not need to be public for cases to be filed by the DOJ.[41]As the act has universal jurisdiction, it is not required that an offender commit the offense in the Philippines; the DOJ brought up anOFWcaregiver who lived inTaiwanon charges for allegedly "posting nasty and malevolent materials against President Duterte on Facebook".[42]Insults that would be seen[tone]in other countries as minor have led to DOJ prosecutors filing cyberlibel charges: such as "crazy"; "asshole";[43]"senile"; and "incompetent".[44]

Journalists charged with cyberlibel since 2013 includeRamon Tulfo,[45]RJ Nieto,[46]andMaria Ressa.[4]Roman Catholicclergyhave also faced cyberlibel charges,[47]as with foreigners, who have also accused others of cyberlibel.[48][49]Duterte's administrationhas been accused of targeting journalists with the law, in particularRappler.[3]During theBongbong Marcos administration,SMNIand theDaily Tribunealso faced cyberlibel complaints from former SenatorAntonio Trillanesand Philippine Consul General in Milan Elmer Cato, respectively.[50][51]

On March 2, 2020, the first guilty verdict in a cyberlibel case was returned against a local politician, Archie Yongco, ofAurora,Zamboanga del Sur.[52]Yongco was found guilty of falsely accusing another local politician ofmurder-for-hirevia a Facebook post, which he deleted minutes later, but of which archives were made; the court was unconvinced by his denial that he posted the message, and he was sentenced to eight years in jail and ordered to pay damages of₱610,000 (US$12,175).[52]

AMagna Carta for Philippine Internet Freedomwascrowdsourcedby Filipino netizens with the intent of, among other things, repealing the Cybercrime Prevention Act of 2012;[53]it failed to pass.[54]Several organizations continue to fight for the decriminalization of all forms of libel in the Philippines, including theNational Union of Journalists of the Philippines[55]andVera Files.[56]

Cyberlibel vs. regular libel

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TheSupreme CourtSecond Division, in July 2023, ruled that "allegedly libelous" post insocial networking sitesmay be punished only under the cybercrime law and not under regular libel (Article 355, Revised Penal Code). The case originated from a petition of an individual, convicted in a libel case in connection with aFacebookpost made in 2011, who argued that such remarks should not be punishable with the case. Since the post was made a year prior to the passage of the law, the court decided that the accused cannot be charged of libel, emphasizing that without a law, no crime are to be punished.[57]

People vs. Luisa Pineda

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TheSupreme Court of the Philippinesin a judgment byJustice Mario Lopezin G.R. No. 262941 (People v. Luisa Pineda, February 2024) affirmed the lower courts' rulings that found Luisa Pineda guilty of violating theAnti-Child Pornography Act of 2009and the Cybercrime Prevention Act of 2012 qualified with the use of a computer system (violation of Sections 4(a), (b), and (c) of Republic Act No. (RA) 9775 or the Anti-Child Pornography Act of 2009, in relation to Section 4(c)(2) of RA 10175 or the Cybercrime Prevention Act of 2012). Pineda was thus sentenced to suffer the penalty of imprisonment ofreclusion perpetua,a fine of PHP 2,000,000 and PHP 300,000 in civil damages.[58][59]

See also

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Notes

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  1. ^abcThe law wastemporarily restrainedby theSupreme Courtfrom October 9, 2012, to February 18, 2014. Most of the law was in the end found constitutional, but sections 4(c)(3), 4(c)(4) [on onlinelibel;but only where it penalizes those who simply receive the post or react to it], 5 [only in relation to sections 4(c)(2), 4(c)(3), and 4(c)(4)], 7 [only in relation to sections 4(c)(2) and 4(c)(4)], 12, and 19 werestruck downby the Court for beingunconstitutionalinDisini v. Secretary of Justice.
  2. ^"Legislative History at the House of Representatives".Archived fromthe originalon February 23, 2014.RetrievedFebruary 18,2014.

References

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  1. ^abRepublic Act No. 10175 (September 12, 2012),Cybercrime Prevention Act of 2012,Official Gazette,archivedfrom the original on December 9, 2021,retrievedMay 22,2020
  2. ^Gonzales, Iris (November 2, 2012)."Filipino law is 'cyber authoritarianism'".New Internationalist.RetrievedJune 5,2020.
  3. ^abJennings, Ralph (April 24, 2020)."Rare Cyber Libel Case Tests Fragile Media Freedoms in Philippines".Voice of America.RetrievedJune 5,2020.
  4. ^abHammer, Joshua (October 15, 2019)."The Journalist vs. the President, With Life on the Line".The New York Times.ISSN0362-4331.RetrievedJune 5,2020.
  5. ^"SC extends TRO on cybercrime law".GMA News.February 5, 2013.RetrievedFebruary 5,2013.
  6. ^"SC won't lift TRO on cybercrime law".Sunstar.February 5, 2013. Archived fromthe originalon February 12, 2013.RetrievedFebruary 5,2013.
  7. ^abMerueñas, Mark (February 18, 2014)."Internet libel in cybercrime law constitutional – SC".GMA News.RetrievedMay 20,2016.
  8. ^Republic Act No. 8792 (June 14, 2000),Electronic Commerce Act,World Intellectual Property Organization,archivedfrom the original on September 30, 2014,retrievedAugust 9,2024
  9. ^Arnold, Wayne (August 22, 2000)."Technology; Philippines to Drop Charges on E-Mail Virus".The New York Times.RetrievedOctober 3,2012.
  10. ^[1]A Short History of the Development of Cybercrime Legislation in the Philippines - Geronimo L. Sy, Assistant Secretary - Manila, Department of Justice
  11. ^Reyes, Karl John C. (October 2, 2012)."Senate inserted Section 19: How the 'take-down' clause emerged in Cybercrime Law".TV5 News and Information.Archived fromthe originalon October 4, 2012.RetrievedOctober 3,2012.
  12. ^Agcaoili, Lawrence (September 20, 2012)."IT-BPO industry welcomes passage of Cybercrime Prevention Act".The Philippine Star.RetrievedSeptember 24,2012.
  13. ^Panela, Shaira (September 19, 2012)."Cybercrime Act extends reach of 'draconian', outdated libel laws".GMA News.GMA News and Public Affairs.RetrievedSeptember 24,2012.
  14. ^Tiongson, Frank Lloyd (January 30, 2012)."Libel law violates freedom of expression – UN rights panel".The Manila Times.RetrievedSeptember 24,2012.
  15. ^Sy, Marvin (September 23, 2012)."'Give Cybercrime Prevention Act a chance'".The Philippine Star.RetrievedApril 5,2013.
  16. ^Angara, Edgardo."Protecting our Cyberspace - The Cybercrime Prevention Act of 2012".EdAngara.com.RetrievedSeptember 24,2012.
  17. ^Mendes, Christina (September 22, 2012)."Guingona criticizes Cybercrime Prevention Act".The Philippine Star.RetrievedSeptember 25,2012.
  18. ^"Philippines' New Cybercrime Prevention Act Troubling for Free Expression".Electronic Frontier Foundation.September 18, 2012.RetrievedOctober 1,2012.
  19. ^"Philippines: Analysis Finds Major Problems in Cybercrime Law".Centre for Law and Democracy.November 22, 2012.RetrievedJanuary 1,2014.
  20. ^"Malacanang reminds critics: Cyberlibel Act passed under Aquino Administration - UNTV News".UNTV News.June 16, 2020.RetrievedJune 18,2020.
  21. ^Canlas, Jonas (September 27, 2012)."Suits pile up assailing anti-cybercrime law".The Manila Times.Archived fromthe originalon September 30, 2012.RetrievedSeptember 27,2012– viaPressReader.Alt URL
  22. ^Torres, Tetch (October 2, 2012)."SC defers action on petitions vs cybercrime law".Philippine Daily Inquirer.RetrievedOctober 2,2012.
  23. ^"#NoToCybercrimeLaw protest goes viral".Rappler.October 2, 2012.RetrievedJune 5,2020.
  24. ^"Websites hacked in protest vs new law".Rappler.September 26, 2012.RetrievedJune 5,2020.
  25. ^Torres, Tetch (October 9, 2012)."SC issues TRO vs cyber law".Philippine Daily Inquirer.Philippine Daily Inquirer, Inc.RetrievedOctober 9,2012.
  26. ^Phneah, Ellyne (December 11, 2012)."Philippine govt asks court to lift injunction on Cybercrime Law".ZDNet.ZDNet.RetrievedDecember 19,2012.
  27. ^Phneah, Ellyne (February 5, 2013)."Philippines extends suspension of cybercrime law".ZDNet.RetrievedJune 5,2020.
  28. ^"Petitions challenging Republic Act No. 10175".Supreme Court of the Philippines.Archived fromthe originalon April 20, 2013.
  29. ^2013 Judiciary Annual Report(PDF).Manila: Supreme Court of the Philippines. 2013. p. 46.Later on, the Court approved another first -- the uploading of the audio recording of the proceedings of the oral arguments of the cases starting with the cases on Cybercrime Law.
  30. ^abJose Disini, et al. v. Secretary of Justice, et al.,G.R. No. 203335 (Supreme Court of the Philippines February 11, 2014),Text.
  31. ^Disini v. Secretary of Justice,Opinion dissenting in part and concurring in part by Leonen,J.ArchivedJune 7, 2021, at theWayback Machine
  32. ^Judiciary Annual Report 2014(PDF).Manila: Supreme Court of the Philippines. 2014. p. 31.In a later signed resolution, the Court denied all the motions for reconsiderationof its decision dated February 18, 2014. (GR No. 203335, GR No. 203299, GR No.203306, GR No. 203359, GR No. 203378, GR No. 203391, GR No. 203407, GR No.203440, GR No. 203453, GR No. 203454, GR No. 203469, GR No. 203501, GR No.203509, GR No. 203515, and GR No. 203518, April 22, 2014)
  33. ^Jose Disini, et al. v. Secretary of Justice, et al. (Ruling on Motion for Reconsideration),G.R. No. 203335 (Supreme Court of the Philippines April 22, 2014),Text.
  34. ^Disini v. Secretary of Justice (Ruling on Motion for Reconsideration),Dissent by Brion,J.
  35. ^abMerueñas, Mark (May 23, 2013)."DOJ to drop online libel from revised cybercrime law".GMA News.RetrievedJune 5,2020.
  36. ^DOJ deletes libel from new anti-cybercrime billArchivedJune 16, 2013, atarchive.todayby Rene Acosta with InterAksyon.com, businessmirror.com.ph, May 23, 2013
  37. ^Tordesillas, Ellen T. (July 2, 2018)."OPINION: Trillanes vs Nieto case underscores need to decriminalize libel".ABS-CBN News.RetrievedJune 5,2020.
  38. ^Bordadora, Norman (September 23, 2012)."Sotto: What's wrong with having libel law in cyber space?".Philippine Daily Inquirer.RetrievedJune 5,2020.
  39. ^La Viña, Tony (March 4, 2014)."Ending criminal libel".Manila Standard.RetrievedJune 5,2020.[permanent dead link‍]
  40. ^Revised Penal Code of the Philippines,Act No. 3815,December 8, 1930, Title 13, Chapter One, Section One, "Crimes Against Honor"
  41. ^Delta Dyrecka Letigio (November 6, 2019)."Two women arrested after classmate files cyber libel charges".Philippine Daily Inquirer.RetrievedJune 5,2020.
  42. ^J. C. Gotinga (April 25, 2020)."DOLE asks Taiwan to deport OFW with Facebook posts criticizing Duterte".Rappler.RetrievedJune 6,2020.
  43. ^Buan, Lian (May 14, 2020)."Salesman arrested, jailed for calling Duterte 'crazy'".Rappler.RetrievedJune 5,2020.
  44. ^Gilbert, David (February 27, 2020)."The Philippines Wants to Arrest 8chan Founder Fredrick Brennan: 'It's Basically a Death Sentence'".Vice.RetrievedJune 5,2020.
  45. ^Gonzales, Cathrine (March 13, 2020)."Ramon Tulfo surrenders to police over cyberlibel cases".Philippine Daily Inquirer.RetrievedJune 5,2020.
  46. ^Movido, Angel (October 10, 2018)."'Thinking Pinoy' blogger pleads not guilty to libel ".ABS-CBN News.RetrievedJune 5,2020.
  47. ^Cullen, Shay (September 8, 2019)."Speaking the truth".The Manila Times.RetrievedJune 5,2020.
  48. ^Dalipe, Gerome M. (October 25, 2016)."BPO senior manager faces online libel case".Sunstar.RetrievedJune 5,2020.
  49. ^Victor, Daniel (February 27, 2020)."Founder of 8chan Faces Arrest on 'Cyberlibel' Charge".The New York Times.ISSN0362-4331.RetrievedJune 5,2020.
  50. ^Casilao, Joahna Lei (May 14, 2024)."Trillanes files cyberlibel complaint vs. Roque, SMNI, others".GMA News Online.Archived fromthe originalon May 15, 2024.RetrievedJuly 22,2024.
  51. ^CMS, Joann Manabat- (January 30, 2024)."Daily Tribune faces P10-M cyber libel complaint".Rappler.RetrievedJuly 22,2024.
  52. ^abSantiago, Salvador (March 2, 2020)."Court finds Zambo Sur town dad guilty of cyber libel".Philippine News Agency.RetrievedJune 5,2020.
  53. ^De Santos, Jonathan (January 21, 2013)."The Wisdom of Crowds: Crowdsourcing Net Freedom".Yahoo News Philippines.VERA Files.RetrievedJanuary 25,2014.
  54. ^"Freedom on the Net 2016 - Philippines".Freedom House.November 14, 2016.RetrievedJune 5,2020– via Refworld, UNHCR.
  55. ^Kristine Joy Patag (February 18, 2019)."Journalists reiterate call to decriminalize libel".The Philippine Star.RetrievedJune 5,2020.
  56. ^Ellen T. Tordesillas (July 2, 2018)."Trillanes vs Nieto case underscores need to decriminalize libel".Vera Files.RetrievedJune 5,2020.
  57. ^Bolledo, Jairo (July 11, 2023)."SC: Libelous Facebook post punishable under cybercrime law only, not libel".Rappler.RetrievedJuly 13,2023.
  58. ^Laqui, Ian (February 26, 2024)."SC imposes jail term, P2M fine on child 'pornographer'".The Philippine Star.RetrievedFebruary 26,2024.
  59. ^"SC Sentences Child Pornographer to Imprisonment and PHP2 Million Fine".Supreme Court of the Philippines.February 26, 2024.RetrievedFebruary 26,2024.
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