EN BANC

[ G.R. No. 246332, December 09, 2020 ]

AES WATCH, BUKLOD PAMILYA, CAPITOL CHRISTIAN

LEADERSHIP, CITIZENS' CRIME WATCH, CONNECTING
BUSINESSMEN IN THE MARKETPLACE TO CHRIST,
LATTER RAIN HARVEST MINISTRIES, ONE VOTE OUR
HOPE, UPPER ROOM BRETHREN CHURCH (PHILIPPINES),
BERNARD C. ROQUE, DIEGO L. MAGPANTAY, DOLORES V.
LAVADO, ERNESTO DELA ROSA DEL ROSARIO, JOSE
LAGUNZAD GONZALES, JUAN SANTOS PRING, MARIA
CORAZON MENDOZA AKOL, MELCHOR GRUELA
MAGDAMO, NELSON JAVA CELIS, PABLO O. OLMEDA,
TROADIO BENITEZ ABITONA, VICENTE ALEJO
MACATANGAY, WENDELL ANACAY UNLAYAO,
PETITIONERS, VS. COMMISSION ON ELECTIONS
(COMELEC), SMARTMATIC TOTAL INFORMATION
MANAGEMENT, RESPONDENTS.

UNITED FILIPINO CONSUMERS & COMMUTERS (UFCC), FROILAN M. DOLLENTE,

TEOFILO T. PARILLA MOVANT-INTERVENORS.

BAGUMBAYAN VNP MOVEMENT, INC. REPRESENTED BY CARISSA O.

COSCOLLUELA, PETITIONER-IN-INTERVENTION.[1]

RESOLUTION

LOPEZ, J.:

This is a petition for mandamus to compel the Commission on Elections

(COMELEC) to review the voter verifiable paper audit trail, to employ another
method of digitally signing the election results, and to remove the supposed
prohibition on capturing devices while inside the polling place.

ANTECEDENTS

In 1997, Republic Act (RA) No. 8436[2] authorized the COMELEC to adopt an
automated election system (AES) using appropriate technology for voting and
electronic devices to count votes and canvass or consolidate results. In 2007, RA
No. 9369[3] amended the provisions of RA No. 8436 allowing the COMELEC to use
a paper-based or a direct recording electronic election system as it may deem
appropriate and practical.[4] The changes also provided the minimum system
capabilities,[5] and required the authentication of electronically transmitted
election results.[6] Accordingly, the COMELEC implemented a paper-based AES
technology and utilized optical mark reader machines in the 2010,2013,2016, and
2019 National Elections. Specifically, the COMELEC used the Precinct Count Optical
Scan (PCOS) machines in 2010, and 2013, and the Vote-Counting Machines (VCM)
in 2016 and 2019.[7] In these national elections, the members of the electoral
board[8] are assigned with an iButton security key and a personal identification
number (PIN), which they must use in initiating the voting machines to accept the
paper ballots and in closing them to print and transmit elections results.[9]

Yet, several groups and individuals questioned the AES implementation and the
use of voting machines.[10] In Capalla v. COMELEC,[11] the petitioners raised
concerns about the alleged absence of digital signatures on the 2010 election
results. The Court held that the PCOS machines could produce digitally signed
transmissions.[12] In Bagumbayan-VNP Movement, Inc. v. COMELEC,[13] the
petitioner sought to compel the COMELEC to enable the VCM's voter verification
feature in the 2016 National Elections by printing the voter's receipts, which would
allow voters to verify whether their votes are registered. The petitioner added that
the COMELEC's position that the voter's receipts are not essential in a paper-based
AES, which utilized paper ballots, is non-compliant with the minimum system
capabilities under the law.[14] In that case, the Court ruled that the minimum
system capabilities are mandatory and that the ballots and voter verifiable paper
audit trail (VVPAT) are not the same:
The minimum functional capabilities enumerated under Section 6 of Republic Act
8436, as amended, are mandatory. These functions constitute the most basic
safeguards to ensure the transparency, credibility, fairness and accuracy of the
upcoming elections.

The law is clear. A "voter verified paper audit trail" requires the following:
(a) individual voters can verify whether the machines have been able to
count their votes; and (b) that the verification at minimum should be
paper based.
There appears to be no room for further interpretation of a "voter verified paper
audit trail." The paper audit trail cannot be considered the physical ballot,
because there may be instances where the machine may translate the ballot
differently, or the voter inadvertently spoils his or her ballot.

xxxx

The required system capabilities under Republic Act No. 8436, as amended, are
the minimum safeguards provided by law. Compliance with the minimum system
capabilities entails costs on the state and its taxpayers. If minimum system
capabilities are met but not utilized, these will be a waste of resources and an
affront to the citizens who paid for these capabilities.

It is true that the Commission on Elections is given ample discretion to administer

the elections, but certainly, its constitutional duty is to "enforce the law." The
Commission is not given the constitutional competence to amend or modify the
law it is sworn to uphold. Section 6 (e), (f), and (n) of Republic Act No. 8436, as
amended, is law. Should there be policy objections to it, the remedy is to have
Congress amend it.

The Commission on Elections cannot opt to breach the requirements of

the law to assuage its fears regarding the VVPAT. Vote-buying can be
averted by placing proper procedures. The Commission on Elections has
the power to choose the appropriate procedure in order to enforce the
VVPAT requirement under the law, and balance it with the constitutional
mandate to secure the secrecy and sanctity of the ballot.

We see no reason why voters should be denied the opportunity to read the voter's
receipt after casting his or her ballot. There is no legal prohibition for the
Commission on Elections to require that after the voter reads and verifies the
receipt, he or she is to leave it in a separate box, not take it out of the precinct.
Definitely, the availability of all the voters' receipts will make random manual
audits more accurate.[15] (Emphases and underscoring supplied; citations
omitted.)Thus, the Court ordered the COMELEC to enable the VCMs' vote
verification feature, which prints the voter's receipts showing the voter's choice.
The Court likewise clarified that the COMELEC could issue guidelines regulating
the release and disposal of the voter's receipts. On motion for reconsideration, the
Court explained that the VVPAT requirement is substantially complied with when
the voter's receipt is printed, and the voters can physically verify their votes. Also,
the COMELEC may add features to the VVPAT in future elections.[16]

The COMELEC complied with the Court's directive in Bagumbayan and issued
Resolution No. 10088[17] to serve as guidelines and regulations on election day.
The COMELEC enabled the VCMs printing capability of the voter's receipts and
provided the mechanism for objections on VVPAT discrepancies. However, the
COMELEC prohibited voters to "[u]se capturing devices, including, but not limited
to, digital cameras or cellular phones for whatever purpose while inside the
polling place" during the casting of votes.[18] In the 2019 National Elections, the
COMELEC issued Resolution No. 10460,[19] which adopted the procedures on the
implementation of VVPAT in Resolution No. 10088 with modification in that the
phrase "for whatever purpose" on the use of capturing devices was deleted.

On April 24, 2019 or days before the May 13, 2019 National Elections, AES-
WATCH, et al.,[20] filed a petition for mandamus seeking the COMELEC to faithfully
implement the directive in Bagumbayan case. They claimed that the COMELEC
had not adopted measures for the VVPAT's "auditability" and proposed a
"camerambola"[21] solution as follows:
V V P A T
VOTER VERIFIED PAPER AUDIT TRAIL
Each Voter may Verify the Paper that Audit Trail can be done at the
rolls out from the counting machine. The close of polls by shuffling the box
voter may not yet take any photograph ("karambola") and then allowing
of that paper until after deposit of that volunteers to use their own
paper into a box, to randomize voter cameras to take photos of each
identity, after which deposit the vote can VV P AT which by rule must
no longer be marketable for sale to any remain inside the precinct.
vote-buyer (if any ). Photos become the Audit Trail for
the People.[22]
Also, AES-WATCH, et al. asked to declare as unconstitutional the prohibition on
poll watchers to take photographs of the proceedings during the elections. They
claimed that the prohibition is inconsistent with Section 179 of the Omnibus
Election Code and that the phrase "for whatever purpose" was sweepingly broad
to include proceedings during the counting of votes, and the transmission and
printing of election returns. Moreover, AES-WATCH, et al. argued that the
COMELEC must comply with the method of digitally signing the election results
under Sections 22 and 30 of RA No. 8436, as amended. They alleged that the
iButtons and PINS were not personal to the members of the electoral boards but
are mere machine identifiers. Thus, the previous elections' electronically
transmitted results were not adequately authenticated because they lack the
members' electronic signatures. The pronouncement in Capalla case on the matter
of digital signature requirement was not categorical but a mere obiter dictum.[23]

On May 2, 2019, United Filipino Consumers & Commuters, Froilan M. Dollente,

and Teofilo Parilla intervened in the case. They supported AES-WATCH, et al., and
urged the COMELEC to submit a complete list of the Media Access Control (MAC)
and Internet Protocol (IP) addresses in the 2019 National Elections. On May 10,
2019, Bagumbayan-VNP Movement Inc. likewise intervened. It adopted the AES-
WATCH, et al.'s arguments and added that the prohibition against capturing
devices inside the polling place would make it difficult for poll watchers to record
any irregularity and for voters to object on the VVPAT discrepancies due to limited
time to verify their votes.

On May 22, 2019, the COMELEC, through the Office of the Solicitor General (OSG),
averred that the conclusion of the 2019 National Elections mooted the petition.
Alternatively, the OSG claimed that AES-WATCH, et al. have no legal standing to
file the petition for lack of material interest and that mandamus will not lie because
COMELEC had yet to respond to the letter/request on their queries.[24] On the
substantive issues, the OSG claimed that COMELEC had already implemented the
VVPAT capability and that no law expressly allows "camerambola." The proposed
solution is very tedious because it amounts to a manual audit of all the votes in
all precincts by taking a photograph of every VVPAT issued by the voting machine.
At any rate, the random manual audit under COMELEC Resolution Nos. 10458[25]
and 10525[26] sufficiently addressed the objective of testing the voting machines'
accuracy and reliability. Also, the OSG agreed that Section 179 of the Omnibus
Election Code allows poll watchers to take photographs during the counting of
votes, but not during the casting of votes. Lastly, the Capalla ruling already settled
the issue on digital signatures. On May 24, 2019 SMARTMATIC Total Information
Management filed a comment which essentially reiterated the OSG's
arguments. [27]

RULING

AES-WATCH, et
al. and
Bagumbayan-VN
P Movement,
Inc. have legal
standing but not
United Filipino
Consumers &
Commuters,
Froilan Dollente,
and Teojilo
Parilla.

Judicial review is not just a power but also a duty.[28] Yet, it does not repose upon
the courts a "self-starting capacity."[29] Specifically, judicial review may be
exercised only when the person challenging the act has the requisite legal standing
which refers to a personal and substantial interest in the case such that he has
sustained, or will sustain, direct injury as a result of its enforcement.[30] The party's
interest must also be material as distinguished from mere interest in the question
involved, or a mere incidental interest. It must be personal, and not based on a
desire to vindicate the constitutional right of some third and unrelated party.[31]

In private suits, standing is governed by the "real-parties-in interest" rule as

contained in the Rules of Civil Procedure.[32] The question as to real party in
interest is whether he is the party who would be benefited or injured by the
judgment, or the party entitled to the avails of the suit. It is important to note
that standing, because of its constitutional and public policy underpinnings, is
different from questions relating to whether a particular plaintiff is the real party
in interest or has capacity to sue. Standing is a special concern in constitutional
law because cases are brought not by parties who have been personally injured
by the operation of a law. The plaintiff who asserts a "public right" in assailing an
allegedly illegal official action, does so as a representative of the general public.
Hence, he has to make out a sufficient interest in the vindication of the public
order and the securing of relief.[33] The question in standing is whether such parties
have "allege[d] such a personal stake in the outcome of the controversy as to
assure that concrete adverseness which sharpens the presentation of issues upon
which the court [so largely] depends for illumination of difficult constitutional
questions."[34]
This Court has previously ruled that for suits filed by taxpayers, legislators, or
concerned citizens, they must still claim some kind of injury-in-fact and allege that
the continuing act has denied them some right or privilege to which they are
entitled.[35] These parties have no legal standing unless they sustained or are in
imminent danger of sustaining an injury as a result of the complained act.[36]

Here, AES-WATCH, et al. assail the constitutionality of the prohibition on poll

watchers from taking photographs of the proceedings during the elections as well
as the COMELEC's compliance with the Bagumbayan ruling. However, they did not
allege any material injury or claim that they are poll watchers, registered voters,
candidates, members of a political party, or members of an accredited citizens
group in the 2019 National Elections. Nevertheless, we deem it proper to relax the
requirement of legal standing given AES-WATCH, et al.'s allegation that they are
filing the petition as citizens.[37] Moreover, they raised questions relating to the
importance of having credible and informed elections such as the AES' minimum
system capability and the VVPAT requirement. Similarly, we grant
Bagumbayan-VNP Movement Inc.'s intervention because it has a material interest
in the case as a political party which tends to suffer injury if its poll watchers
cannot exercise their rights and duties under the Omnibus Election Code. Besides,
it has candidates in the 2019 National Elections and will be affected if there is non-
compliance with the VVPAT requirement.[38]

On the other hand, United Filipino Consumers & Commuters, Froilan Dollente, and
Teofilo Parilla failed to establish that they have the requisite personal and
substantial interest. They did not sustain any direct injury or is in danger of
suffering any damages from the assailed COMELEC actions. They were silent in
what capacity they are seeking for intervention. They claimed that the issues are
of "transcendental importance," but failed to allege any interest in the outcome of
the case.[39] Hence, their motion to intervene must be denied.

Mandamus will
not lie to control
the judgment of
an independent
constitutional
body over
matters which
the law gives it
the authority to
decide absent
grave abuse of
discretion.

Mandamus is a command requiring the performance of a specific duty resulting

from the party's official station to whom the writ is directed or from the operation
of law.[40] It is available when a tribunal, corporation, board, officer or person
unlawfully neglects the performance of an act which the law specifically enjoins as
a duty resulting from an office, trust, or station, or unlawfully excludes another
from the use and enjoyment of a right or office.[41] The remedy lies to compel the
performance of a ministerial duty.[42] It can only direct the tribunal, body, or official
to act, but not in a particular way.[43] It cannot direct the exercise of judgment[44]
unless there is grave abuse of discretion.[45]

A ministerial act is one which an officer or tribunal performs in a given state of

facts, in a prescribed manner, in obedience to the mandate of legal authority,
without regard to or the exercise of his own judgment upon the propriety or
impropriety of the act done. It is one as to which nothing is left to the discretion
of the person who must perform the act. On the other hand, a discretionary act
refers to the liberty to decide according to the principles of justice and one's idea
of what is right and proper under the circumstances, without willfulness or favor.
As applied to public functionaries, it means a power or right conferred upon them
by law of acting officially in certain circumstances, according to the dictates of
their own judgment and conscience, uncontrolled by the judgment or conscience
of others. If the law imposes a duty upon a public officer and gives him a right to
decide how or when the duty shall be performed, it is discretionary and not
ministerial.[46]

The following requirements must be present to warrant the issuance of a writ of

mandamus, to wit: (1) the petitioner has a clear and unmistakable legal right to
the act demanded;[47] (2) it is the duty of the respondent to perform the act
because it is required by law; (3) the respondent unlawfully neglects the duty
enjoined by law or unlawfully excludes the petitioner from the use or enjoyment
of the right or office; (4) the act to be performed is ministerial; and (5) there is
no plain, speedy, and adequate remedy in the ordinary course of law.[48] These
requirements are wanting in this case. The assailed COMELEC actions involve the
exercise of judgment. Moreover, there was no grave abuse of discretion.
Foremost, the COMELEC is vested with the constitutional power and function to
"[e]nforce and administer all laws and regulations relative to the conduct of an
election."[49] Among its powers is the promulgation of rules and regulations of
election laws.[50] It exercises discretion on how certain aspects of elections are
implemented. This is explicit in the following provisions of RA No. 8436, as
amended, by RA No. 9369, thus:
SEC. 13. Continuity Plan. - The AES shall be so designed to include a continuity
plan in case of a systems breakdown or any such eventuality which shall result in
the delay, obstruction or nonperformance of the electoral process. Activation of
such continuity and contingency measures shall be undertaken in the presence of
representatives of political parties and citizens' arm of the Commission who shall
be notified by the election officer of such activation.

All political parties and party-lists shall be furnished copies of said continuity plan
at their official addresses as submitted to the Commission. The list shall be
published in at least two newspapers of national circulation and shall be posted at
the website of the Commission at least fifteen (15) days prior to the electoral
activity concerned.

xxxx

SEC. 18. Procedure in voting. - The Commission shall prescribe the manner and
procedure of voting, which can be easily understood and followed by the voters,
taking into consideration, among other things, the secrecy of the voting.

SEC. 19. Closing of polls. - The Commission shall prescribe the time, manner and
procedure of closing the polls and the steps for the correct reporting of votes cast
and the proper conduct of counting for areas covered by the AES.

xxxx

SEC. 21. Counting Procedure. - The Commission shall prescribe the manner and
procedure of counting the votes under the automated system: Provided, That
apart from the electronically stored result, thirty (30) copies of the election return
are printed.

xxxx
SEC. 37. Rules and Regulations. - The Commission shall promulgate rules and
regulations for the implementation and enforcement of this Act. xxx.

xxxx
Here, the petitioners and intervenors failed to show that the COMELEC
unjustifiably neglects the performance of a duty enjoined by law. They maintain
that the COMELEC did not adhere to the Bagumbayan ruling on the matter of
VVPAT requirement. As a solution, they propose the "camerambola" method.
However, a comparison of the dispositive portion of the Bagumbayan case and the
COMELEC guidelines in the 2019 National Elections reveals the futility of their
theory. As held in the Bagumbayan, the VVPAT requirement is substantially
complied with when the voter's receipt is printed, and the voter can physically
verify his or her vote,[51] to wit:
WHEREFORE, the Petition for [Mandamus] is GRANTED. The Commission on
Elections is ORDERED to enable the vote verification feature of the vote-counting
machines, which prints the voter's choices without prejudice to the issuance of
guidelines to regulate the release and disposal of the issued receipts in order to
ensure a clean, honest, and orderly elections such as, but not limited to, ensuring
that after voter verification, receipts should be deposited in a separate ballot box
and not taken out of the precinct.

SO ORDERED.[52]The COMELEC implemented this directive and issued guidelines

that the VVPAT must be printed in the form of paper receipts and that the voters
can verify their votes through these receipts. The voters were also allowed to
register their objections in case of discrepancies with their actual votes. Apropos
is Section 73 of the COMELEC Resolution No. 10460, thus:
SEC. 73. Manner of Voting. -

a. The voter shall:

1. Using a ballot secrecy folder and the marking pen provided by the Commission,
accomplish the ballot by fully shading the oval appearing before the names of the
candidates and the organizations participating in the party-list system of
representation; and

2. After accomplishing the ballot, insert the ballot in the VCM's ballot entry slot,
after which the voter shall return the ballot secrecy folder and the marking pen to
the third member;

b. The EB third member shall position/stand beside the VCM without

being able to view the screen, but near enough to be able to perform the
following:

1. Monitor the VCM to ensure that the ballot is successfully accepted and
the VVPAT is printed. Every time the end-of-roll color indicator appears,
the third member shall replace the thermal paper;

2. Fold the VVPAT in such a way that its contents cannot be seen, and then
cut the end of the VVPAT using non-pointed scissors; and

3. Apply indelible ink to the voter's right forefinger nail or any other nail if
there be no forefinger nail, and give the VVPAT to the voter for review;

c. The EB shall ensure that only the voter can read the VVPAT and advise
the voter that bringing of the VVPAT outside the polling place shall
constitute as an election offense. For this purpose, the box containing the
Official Ballots shall serve as the VVPAT receptacle which shall be placed in an area
visible to the EB members/support staff/citizens' arm, watchers and other persons
allowed inside the polling place.

The EB shall ensure that all Official Ballots are removed from the box before the
same is used as a VVPAT receptacle. The VVPAT receptacle shall be properly sealed
using the packaging tape, on which the EB and watchers, if any, shall affix their
names and signatures.

d. The EB shall instruct the voter to go near the VVPAT receptacle located beside
the VCM, and verify the votes as appearing on the VVPAT, drop the same in the
VVPAT receptacle and leave the polling place.

e. In case an objection is raised by the voter on how the VCM reads the
ballot, the chairperson shall:

1. Instruct the voter to affix his signature at the back of the VVPAT;
2. Note the specific objection in the Minutes; and

3. Attach the VVPAT to the Minutes (copy for the Ballot Box).

The objection shall be raised before the VVPAT is dropped in the VVPAT
receptacle.

The filing of frivolous objections shall constitute an election offense

punishable under the Omnibus Election Code. For this purpose, the EB is
allowed to administer oaths so that if the protest is frivolous, falsification
or perjury charges may be filed.

f. At the close of polls, the EB shall then place the VVPAT receptacle inside the
ballot box. (Emphases supplied.)In stark contrast, the petitioners and intervenors
did not establish the legal basis of the proposed "camerambola" solution. They
merely want to audit all VVPATs immediately after the elections and
compare it with the election results but are silent on the intended purpose and
how COMELEC should mobilize the volunteers and watchers nationwide to conduct
this audit. On this score, the conduct of a random manual audit is sufficient to
determine whether there are discrepancies between the manual count and the
automated count, viz.:
SEC 29. Random Manual Audit. - Where the AES is used, there shall be a
random manual audit in one precinct per congressional district randomly
chosen by the Commission in each province and city. Any difference between
the automated and manual count will result in the determination of root cause and
initiate a manual count for those precincts affected by the computer or procedural
error.[53] (Emphasis supplied.)The COMELEC Resolution Nos. 10458 and 10525
provide that at least one clustered precinct in every legislative district shall be
randomly selected to determine whether there is a discrepancy between the
automated and manual count of votes and to determine the root cause of
discrepancies, if any. In this audit, VVPAT serves as an essential tool to reconcile
any discrepancies between the manual count and machine count, thus:
RESOLUTION No. 10525

SEC. 4. - Number Precincts to be Randomly Selected for the RMA. At least

one clustered precinct in every legislative district shall be randomly selected for
the RMA.
The actual number of precincts to be selected in a legislative district shall be
determined by proportional allocation, that is, based on the number of clustered
precincts a legislative district has in proportion to that of all the other legislative
districts in the country.

The COMELEC, upon the recommendation of the RMAC, shall decide on the
maximum total number of clustered precincts to be selected based on statistical
sampling principles and taking into consideration resources available.

For purposes of the 13 May 2019 National and Local Elections, the maximum total
number of clustered precincts to be selected shall not be more than seven hundred
and fifteen (715).

Once the maximum total number of clustered precincts to be selected is

determined, COMELEC shall approve the proportional allocation of the actual
number of clustered precincts to be selected in each legislative district based on
the recommendation of the PSA. The approval on the proportional allocation shall
be made not later than ninety (90) days before the election.

SEC. 15. Manner of Counting of Votes. - xxx

k. In case the RMA results do not match the AES results, the RMAT members shall
review all ballots and the corresponding entries in the Audit Returns for purposes
of excluding the possibility of human error.

After determination that human error was not committed as having

caused the discrepancy, the Chairman shall determine if the total number
of VVPAT receipts is equal to the total number of valid ballots. If so, the
RMAT members shall use the VVPAT receipts to count the votes counted
in favor of the candidate with the reported discrepancylies.

SEC. 18. - Discrepancy Between AES and RMA. In the event that the RMAT reports
a discrepancy between the AES and RMA results which exceeds the allowable
margin of an aggregate difference of ten (10) votes, the RMA-VT shall:

xxxx
e. In the event of a finding that the discrepancy exists or is not due to mere
mathematical error, the RMAC shall turn over the ballot box to the Technical
Evaluation Committee (TEC) for determination of the root cause in case the
finding is that the discrepancy is valid. (Emphases supplied.)Verily, the
random manual audit should have satisfied petitioners and intervenors' concern
about possible discrepancies between the machine and manual count of votes. If
they are apprehensive about the sample size of audited precincts in a legislative
district, then the recourse is not with COMELEC but with Congress to amend
Section 29 of RA No. 8436, as amended.

The petitioners and intervenors also failed to show that the prohibition of using
capturing devices in COMELEC Resolution No. 10460 is unlawful. It is true that
Section 179 of the Omnibus Election Code allows poll watchers to use capturing
devices at different stages of the election process except when voters are casting
their votes, to wit:
SEC. 179. Rights and duties of watchers. - xxx The watchers shall have the right
to stay in the space reserved for them inside the polling place. They shall have
the right to witness and inform themselves of the proceedings of the hoard of
election inspectors, including its proceedings during the registration of voters, to
take notes of what they may see or hear, to take photographs of the
proceedings and incidents, if any, during the counting of votes, as well as
of election returns, tally boards and ballot boxes, to file a protest against
any irregularity or violation of law which they believe may have been committed
by the board of election inspectors xxx (Emphasis supplied.)These rights and
duties are reiterated and clarified in Section 46 of COMELEC Resolution No. 10460
for the 2019 National Elections, thus:
SEC. 46. Rights and Duties of Watchers. - xxx

xxxx

The watchers shall have the right to:

a. Stay in the space reserved for them inside the polling place. except under
the last paragraph of Section 44 of this Resolution;

b. Witness and inform themselves of the proceedings of the EB;

c. Take note of what they may see or hear;

 d. Take picture, image or photo of the proceedings and incidents, if any,
during testing and sealing, counting of votes, transmission and
printing of election returns provided the secrecy of the ballot shall
be maintained at all times. In no case shall taking of pictures, images
or photos be allowed during casting of votes;

e. File a protest against any irregularity or violation of law which they

- believe may have been committed by the EB or by any person
present;

f. Obtain from the EB a certificate as to the filing of such protest and/or the
Resolution thereof; and

g. Position themselves behind the chairperson of the EB in such a way that they
can read the election returns while the chairperson is publicly announcing
the precinct results.

xxxx (Emphases supplied.)

Contrary to petitioners' claims, the poll watchers can still register their protest on
any irregularity and use capturing devices during the counting of votes and the
transmission and printing of election returns, which will help them record their
observations. However, they are prohibited from using these devices during the
casting of votes to observe the constitutional policy of securing ballots' secrecy
and sanctity.[54] The prohibition is consistent with the Omnibus Election Code,
which considers it unlawful for any person to avail of any scheme to discover the
contents of the ballots of a voter:
OMNIBUS ELECTION CODE

SEC. 261. Prohibited Acts. - The following shall be guilty of an election offense:

xxxx

(z) On voting:

xxxx
(5) Any person who avails himself of any means of scheme to discover the
contents of the ballot of a voter who is preparing or casting his vote or who has
just voted.Notably, the VVPAT reflects the votes of a voter. Allowing the poll
watcher or even the voters to take a picture of their VVPATs during the casting of
votes may run contrary to the constitutional policy of keeping the ballots' secrecy
and sanctity. The COMELEC may adopt measures to prevent this from happening.
In their attempt to show that poll watchers are prohibited from using capturing
devices even during the counting of votes, the petitioners and intervenors point
to the prohibition imposed on voters instead, which includes the phrase "for
whatever purpose." This claim is misleading because they are referring to
COMELEC Resolution No. 10088, which served as guidelines for the 2016 National
Elections. Yet, the COMELEC Resolution No. 10460 for the 2019 National Elections
already removed the phrase "for whatever purpose:"
Resolution No. 10088 Resolution No. 10460
(2016 NLE) (2019 NLE)
SEC. 2. Sections 20(a) and (f) of SEC. 64. Prohibitions on Voting. - It shall
Resolution No. 10057 are hereby amended be unlawful for a voter to:
to read as follows:
xxxx
"SEC. 20. Prohibitions on voting. - It shall
be unlawful for a voter to: (f) Use of capturing devices such as but
not limited to digital cameras, cellular
xxxx phones with camera, or other means to
copy the contents of the ballot, or
f) Use capturing devices, including, but not otherwise make use of any other
limited to, digital cameras or cellular scheme to identify his vote[.]
phones for whatever purpose while (Emphasis supplied.)
inside the polling place[.]" (Emphasis
supplied.)
More importantly, the Capalla ruling is clear that the PCOS machines are capable
of digitally-signed transmissions, as can be distilled from the clarificatory
questions of former Associate Justice Antonio Carpio and Atty. Lazatin's response.
A digital signature requires private and public keys. In the case of PCOS machines)
algorithms generate these keys and the method of comparing these keys. The
private key in the electronic transmission of results and the public key possessed
by COMELEC must match to consider the electronic transmission of results as an
official election return. The private key is generated when the members of the
electoral board use their respective iButtons and input their respective PINs on
the voting machines. Although Capalla discussed PCOS machines' capability, the
procedure concerning iButtons and PINs remains the same in the 2019 National
Elections using VCMs. As such, the authentication process of electronically
transmitted results is compliant with jurisprudence.

Yet, the petitioners and intervenors insist that Capalla was not categorical whether
the requirement of digital signatures was complied with using the iButtons and
PINs. The gist of their contention is that the iButtons and PINs should not be
considered as the electoral board members' electronic signatures because they
are machine identifiers and are not personal to the EB members. The recent case
of Bagumbayan-VNP Movement, Inc v. COMELEC[55] already addressed these
contentions in ruling that the iButtons and PINs are the functional equivalents of
the signatures of the members of the electoral board, to wit:
The Court rules that the electronic transmission through the method promulgated
by the COMELEC, as well as the authentication of the results, are valid under the
law. According to A.M. No. 01-7-01-SC, or the Rules on Electronic Evidence,
promulgated by the Court and alluded to with regard to the above mentioned
authentication process, a "digital signature" refers to an electronic signature
consisting of a transformation of an electronic document or an electronic data
message using an asymmetric or public cryptosystem such that a person having
the initial untransformed electronic document and the signer's public key can
accurately determine: (i) whether the transformation was created using the
private key that corresponds to the signer's public key; and (ii) whether the initial
electronic document had been altered after the transformation was made, and
that for purposes of the Rules, a digital signature is considered an electronic
signature.

An electronic signature is likewise defined as "any distinctive mark, characteristic

and/or sound in electronic form representing the identity of a person and attached
to or logically associated with the electronic data message or electronic document
or any methodology or procedure employed or adopted by a person and executed
or adopted by such person with the intention of authenticating, signing or
approving an electronic data message or electronic document."

As gleaned from the wording of the law, the signature may be any
distinctive mark or characteristic that represents the identity of a person.
Thus, a machine signature of a PCOS machine may validly be considered
the functional equivalent of the aforementioned "digital signature," as it
represents the identity of the individual, said signature naturally being
created specifically for the person him or herself inputting the details.

It is critical to note that the Court En Banc has already recognized that
the PCOS machines produce digital signatures. In Archbishop Capalla, the
Court clarified during the oral arguments that there is no infirmity as
regards the signature of a PCOS machine being the equivalent of a digital
signature. The Court, in that case, categorically stated that the PCOS
machines produce digitally-signed signatures, and the Court sees no need
to disturb that finding absent any compelling evidence to the contrary
adduced by the petitioners. (Emphases supplied; citations omitted.)Taken
together, the petitioners and intervenors failed to prove that the COMELEC
unlawfully neglected any duty enjoined by law. The adoption of the "camerambola"
solution, or another method to digitally sign the election results, or policies
regarding the use of capturing devices are all suggestions subject to the
COMELEC's sound judgment. The exercise of discretion on how to implement the
chosen AES must be accorded with the presumption of regularity and should be
respected.[56] In Sumulong v. COMELEC,[57] the Court highlighted COMELEC's role
as an independent constitutional body:
The Commission on Elections is a constitutional body. It is intended to play a
distinct and important part in our scheme of government. In the discharge of its
functions, it should not be hampered with restrictions that would be fully
warranted in the case of a less responsible organization. The Commission may
err, so may this court also. It should be allowed considerable latitude in
devising means and methods that will insure the accomplishment of the
great objective for which it was created - free, orderly and honest
elections. We may not agree fully with its choice of means, but unless
these are clearly illegal or constitute gross abuse of discretion, this court
should not interfere. Politics is a practical matter, and political questions must
be dealt with realistically - not from the standpoint of pure theory. The Commission
on Elections, because of its fact-finding facilities, its contacts with political
strategists, and its knowledge derived from actual experience in dealing with
political controversies, is in a peculiarly advantageous position to decide complex
political questions.

xxxx
There are no ready-made formulas for solving public problems. Time and
experience are necessary to evolve patterns that will serve the ends of good
government. In the matter of the administration of the laws relative to the conduct
of elections, as well as in the appointment of election inspectors, we must not by
any excessive zeal take away from the Commission on Elections the initiative
which by constitutional and legal mandates properly belongs to it. Due regard to
the independent character of the Commission, as ordained in the Constitution,
requires that the power of this court to review the acts of that body should, as a
general proposition, be used sparingly, but firmly in appropriate cases. We are not
satisfied that the present suit is one of such cases.[58] (Emphasis supplied.)
At any rate, the
petition for
mandamus is
dismissible for
being moot and
academic.

Lastly, the petition for mandamus is dismissible on the ground of mootness. A

case becomes "moot" when it ceases to present a justiciable controversy by
supervening events so that a declaration thereon would be of no practical use or
value.[59] Here, the conclusion of the 2019 National Elections rendered the petition
academic. The issues on the absence of digital signatures, prohibition on the use
of capturing devices, and adoption of the "camerambola" solution, are part of the
election day proceedings and refer to the chosen AES system implemented for
that particular election. The prayer to compel the COMELEC to make an inventory
of the list of MAC[60] and IP[61] addresses is likewise mooted. This relief will serve
no practical purpose because it was intended to be implemented during the
transmission of results in the 2019 National Elections to avoid data interception
and ensure that the COMELEC can only receive data from its recognized devices.
It will also be impractical to require the submission of the devices' MAC addresses
for purposes of future elections. The Court cannot preempt the COMELEC's choice
on which AES should be implemented and whether the same devices will be used
again in subsequent elections.[62] These data issues are impermanent as they can
change with technological progression dependent to the necessity at a given time.
In Vitangcol III v. COMELEC,[63] we dismissed similar petition for being moot and
academic after the 2016 National Elections, thus:
According to the petitioners, when polls close on May 9, 2016, the VCMs would
transmit the election returns to the Comelec central server, the transparency
server, and the server at the Joint Congressional Canvassing. Elections results
would also be transmitted to the appropriate municipal, provincial and national
canvassing centers. During such transmissions, however, data may be
compromised. Hackers could intercept (thru sniffing), alter, and send the altered
data to canvassing centers and Comelec servers without any traces that such data
had already been tampered. To prevent this, petitioners pray to compel the
Comelec to make an inventory of all the MAC and IP addresses of all its
electronic devices, as well as IMSI and IMEI of all its communication
devices, that would be used in the May 9, 2016 elections. That way, the
recipients of the data, particularly the Comelec, could crosscheck whether the data
they received actually carne from Comelec-recognized devices.

The conclusion of the May 9, 2016 elections, however, mooted the issues
raised in these Petitions. In addition, it should be noted that IP addresses
are not permanent. Internet Service Providers (ISP) can change it from
time to time. Connecting to the internet thru different ISPs also results in
the change of IP addresses. In other words, the IP addresses used
relative to the May 9, 2016 will no longer be the same IP addresses that
will be used in the subsequent elections. The same goes true for the MAC
address and IMEI. While these identifying codes are permanently
embedded on electronic devices, no one knows, at this point, whether the
Comelec will utilize the same electronic devices for the same precincts in
future elections.[64] (Emphases supplied; citation omitted.)On a final note, the
COMELEC exercised its judgment to ensure free, orderly and honest elections and
to protect the secrecy and sanctity of ballots without grave abuse of discretion. To
be sure, the Court will not hesitate to exercise its jurisdiction to compel the
performance of a duty provided by law in appropriate cases.[65]

FOR THESE REASONS, the petition is DISMISSED.

SO ORDERED.

Peralta, C. J., Perlas-Bernabe, Leonen, Caguioa, Gesmundo, Hernando,

Carandang, Lazaro-Javier, Inting, Zalameda, Delos Santos, Gaerlan, and Rosario,
JJ., concur.
 NOTICE OF JUDGMENT

Sirs/Mesdames:

Please take notice that on December 9, 2020 a Resolution, copy attached

herewith, was rendered by the Supreme Court in the above-entitled case, the
original of which was received by this Office on July 5, 2021 at 2:30 p.m.

Very truly yours,

EDGAR O. ARICHETA
Clerk of Court

By:

(SGD.) ANNA-LI R.
PAPA-GOMBIO
Deputy Clerk of Court En
Banc

[1]
The motion to intervene is granted as discussed in this Resolution.

[2]
AN ACT AUTHORIZING THE COMMISSION ON ELECTIONS TO USE AN
AUTOMATED ELECTION SYSTEM IN THE MAY 11, 1998 NATIONAL OR LOCAL
ELECTIONS AND IN SUBSEQUENT NATIONAL AND LOCAL ELECTORAL EXERCISES,
PROVIDING FUNDS THEREFOR AND FOR OTHER PURPOSES; approved on
December 22, 1997.

[3]
AN ACT AMENDING REPUBLIC ACT NO. 8436, ENTITLED "AN ACT AUTHORIZING
THE COMMISSION ON ELECTIONS TO USE AN AUTOMATED ELECTION SYSTEM IN
THE MAY 11, 1998 NATIONAL OR LOCAL ELECTIONS AND IN SUBSEQUENT
NATIONAL AND LOCAL ELECTORAL EXERCISES, TO ENCOURAGE TRANSPARENCY,
CREDIBILITY, FAIRNESS AND ACCURACY OF ELECTIONS, AMENDING FOR THE
PURPOSE BATAS PAMBANSA BLG. 881, AS AMENDED, REPUBLIC ACT NO. 7166
AND OTHER RELATED ELECTION LAWS, PROVIDING FUNDS THERFOR AND FOR
OTHER PURPOSES; approved on January 23, 2007; Republic Act (RA) No. 8436,
as amended will be used to refer to the amendments introduced by RA No. 9369
for consitency.

[4]
RA No. 8436, Sec. 5.

[5]
RA No. 8436, Sec. 6.

[6]
RA No. 8436, Sec. 30.

[7]
Bagumbayan-VNP Movement, Inc. v. COMELEC, 782 Phil. 1306, 1309-1310
(2016); The PCOS and VCM are optical mark readers machines but refer to
different models. See Commission on Elections, Resolution Nos. 8739 and 9640
(February 15, 2013), 10057 (February 11, 2016), 10460 (December 6, 2018).
These resolutions serve as the implementing guidelines on the process of voting,
counting and transmission of election results. A voter should accomplish the ballot
by fully shading the oval appearing before the names of his or her chosen
candidate. Thereafter, the voter shall insert the ballot to the voting machine's
entry slot.

[8]
See RA No. 10756 (April 8, 2016), Sec. 2 (c). Electoral board also refers to the
Board of Elections Inspectors.

[9]
See Commission on Elections, Revised General Instructions for the Board of
Elections Inspectors (BEI) on the Voting, Counting, and Transmission of Results
in Connection with the May 10, 2010, National and Local Elections, Resolution No.
8786 (March 4, 2010), Sections 34 and 40; Commission on Elections, Vote-
Counting Machine (VCM) Operation Procedures for Final Testing and Sealing
(FTS); Election Day and Transmission of Election Results in Connection with the
May 13, 2019 National and Local Elections, Resolution No. 10487 (January 23,
2019) Sec. 3. The procedure in using the iButtons and PINs are essentially the
same in the 2010, 2013, 2016 and 2019 National Elections.

[10]
Bagumbayan-VNP, Inc., v. COMELEC, supra note 7; Capalla v. COMELEC, 687
Phil. 617 (2012); Guingona Jr. v. COMELEC, 634 Phil. 516 (2010); Roque, Jr. v.
COMELEC, 615 Phil. 149 (2009).
[11]
Capalla v. COMELEC, supra.

[12]
The Court quoted the clarificatory questions of former Associate Justice Antonio
Carpio and Attorney Lazatin's response regarding the digital signature to explain
this capability and the process on how the election results are authenticated using
the digital signature. Id. at 681-688.

[13]
Supra note 7.

[14]
RA No. 8436, as amended by RA No. 9369, SEC. 6. Minimum System
Capabilities. - The automated election system must at least have the following
functional capabilities

xxxx

(e) Provision for voter verified paper audit trail;

(f) System auditability which provides supporting documentation fix verifying the
correctness of reported election results;

xxxx

(n) Provide the voter a system of verification to find out whether or not the
machine has registered his choice[.]

[15]
Bagumbayan-VNP Movement, Inc. v. COMELEC, supra note 7 at 1322-1323.

[16]
Bagumbayan-VNP Movement, Inc. v. COMELEC, G.R. No. 222731 (Notice),
March 17, 2016.

[17]
AMENDING CERTAIN PROVISIONS OF RESOLUTION NO. 10057 DATED
FEBRUARY 11, 2016 OR OTHERWISE KNOWN AS THE GENERAL INSTRUCTIONS
FOR THE BOARDS OF ELECTION INSPECTORS (BEI) ON THE TESTING AND
SEALING OF VOTE COUNTING MACHINES (VCMS), AND VOTING, COUNTING AND
TRANSMISSION OF ELECTION RESULTS IN CONNECTION WITH THE 09 MAY 2016
NATIONAL AND LOCAL ELECTIONS, RESOLUTION No. 10088; promulgated on
April 12, 2016.
[18]
See COMELEC Resolution No. 10088, Section 2.

[19]
COMMISSION ON ELECTIONS, GENERAL INSTRUCTIONS FOR THE ELECTORAL
BOARDS (EBs) ON THE PROCESS OF VOTING, COUNTING, AND TRANSMISSION
OF ELECTION RESULTS IN CONNECTION WITH THE 13 MAY 2019 NATIONAL AND
LOCAL ELECTIONS, RESOLUTION NO. 10460; promulgated on December 6, 2018.

[20]
Petitioners are composed of groups and individuals belonging to different
religious groups, election reform advocacy group, and anti-crime/corruption
groups. The individual petitioners are composed of church leaders and advocates
of election retorms and anti-crime and corruption; rollo, pp. 3-46.

[21]
Petitioners combined the words "camera" and "karambola" (to shuffle); id. at
7.

[22]
Id.

[23]
Rollo, p. 24.

[24]
Id. at 98-129.

[25]
IN THE MATTER OF THE GENERAL INSTRUCTIONS FOR THE CONDUCT OF
RANDOM MANUAL AUDIT (RMA) FOR THE 13 MAY 2019 AUTOMATED
SYNCHRONIZED NATIONAL AND LOCAL ELECTIONS AND SUBSEQUENT
ELECTIONS THEREAFTER, RESOLUTION No. 10458; promulgated on December 5,
2018.

[26]
COMMISSION ON ELECTIONS, IN THE MATTER OF THE AMENDMENTS TO THE
GENERAL INSTRUCTIONS FOR THE CONDUCT OF RANDOM MANUAL AUDIT (RMA)
FOR THE 13 MAY 2019 AUTOMATED SYNCHRONIZED NATIONAL AND LOCAL
ELECTIONS AND SUBSEQUENT ELECTIONS THEREAFTER, RESOLUTION NO.
10525, promulgated on April 11, 2019.

[27]
Rollo, pp. 136-179.

[28]
Judicial power refers to the duty and power "to settle actual controversies
involving rights which are legally demandable and enforceable, and to determine
whether or not there has been a grave abuse of discretion amounting to lack or
excess of jurisdiction on the part of any branch or instrumentality of the
Government." (CONSTITUTION, Art. VIII, Sec. 1).

[29]
The Court has no self-starting capacity and must await the action of some
litigant so aggrieved as to have a justiciable case. (Shapiro and Tresolini, American
Constitutional Law, Sixth Edition. 1983, p. 79).

[30]
Cruz, Philippine Political Law, 2002 Ed., p. 259. See also Angara v. Electoral
Commission, 63 Phil. 139, 158 (1936); Board of Optometry v. Hon. Colet, 328
Phil. 1187, 1196-1197 (1996); Police General Macasiano (Ret.) v. National
Housing Authority, 296 Phil 56, 63-64 (1993); Santos III v. Northwestern Orient
Airlines, 285 Phil. 734, 742-743 (1992); and Nat'l Economic Protectionism
Association v. Ongpin, 253 Phil. 643. 649 (1989).

[31]
Hon. Aguinaldo v. Pres. Benigno Simeon C. Aquino III, 801 Phil. 492, 522
(2016).

[32]
It provides that "every action must be prosecuted [or defended] in the name
of the real party in interest" Accordingly, the "real-party-in interest" is "the party
who stands to be benefited or injured by the judgment in the suit or "the party
entitled to the avails of the suit." Succinctly put, the plaintiffs standing is based
on his own right to the relief sought (Salonga v. Warner Barnes & Co. Ltd., 88
Phil. 125, 131 [1951]).

[33]
Prof. David v. Pres. Macapagal-Arroyo, 522 Phil. 705, 756 (2006).

[34]
J.G. Summit Holdings, Inc. v. CA, 490 Phil. 579 (2005).

[35]
Falcis III v. Civil Registrar General, G.R. No. 217910, September 3, 2019, citing
Francisco, Jr. v. House of Representatives, 460 Phil. 830 (2003).

[36]
Private Hospitals Association of the Philippines, Inc. (PHAPI) v. Medialdea, G.R.
No. 234448, November 6, 2018, 884 SCRA 350, 416.

[37]
See Guingona Jr. v. COMELEC, 634 Phil. 516 (2010); Roque, Jr. v. COMELEC,
615 Phil. 149 (2009); See also Integrated Bar of the Phils. v. Hon. Zamora, 392
Phil. 618 (2000).
[38]
Rollo, p. 78.

[39]
See Francisco Jr. v. The House of Representatives, 460 Phil. 830, 899 (2003).
In that case, the Court observed that it has "adopted a liberal attitude on the locus
standi of a petitioner where the petitioner is able to craft an issue of transcendental
significance to the people, as when the issues raised are of paramount importance
to the public. Such liberality does not, however, mean that the requirement
that a party should have an interest in the matter is totally eliminated. A
party must, at the very least, still plead the existence of such interest, it
not being one of which courts can take judicial notice." (Emphases and
italics supplied; citation omitted.)

[40]
See Justice Jose Feria, et al. Civil Procedure Annotated (2001 ed.), p. 486.

[41]
RULES OF COURT, Rule 65. Sec. 3.

[42]
See Quizon v. COMELEC, 569 Phil. 323. 329 (2008); Knecht v. Hon. Desierto,
353 Phil. 494, 503 (1998); Justice Jose Feria, et al. Civil Procedure Annotated
(2001 ed.), p. 486.

[43]
See Ampatuan, Jr. v. Sec. De Lima, 708 Phil. 153, 167 (2013).

[44]
See Quizon v. COMELEC, supra.

[45]
See Angchangco, Jr. v. Hon. Ombudsman, 335 Phil. 766, 772 (1997).

[46]
Lamb v. Phipps, 22 Phil. 456, 474 (1912).

[47]
See Justice Jose Feria, et al. Civil Procedure Annotated (2001 ed.), p. 488.

[48]
See Bagumbayan-VNP Movement, Inc. v. COMELEC, supra note 16.

[49]
CONSTITUTION, Art IX-C, SEC. 1; Batas Pambansa Bilang 881, SEC. 52 (c).

[50]
OMNIBUS ELECTIONS CODE, SEC. 52 (2).

[51]
Bagumbayan-VNP Movement, Inc, supra note 16.
[52]
Id. In resolving COMELEC's motion for reconsideration, this Court made its
directive to COMELEC clear:
WHEREFORE, the Commission on Elections' Motion for Reconsideration dated
March 11, 2016 filed by respondent Commission on Elections is DENIED WITH
FINALITY, the basic issues raised having previously been duly considered and
passed upon by this Court in its Resolution dated March 8, 2016.

The Writ of [Mandamus] issued in Resolution dated March 8, 2016 must be fully
implemented for the upcoming dections. The Commission on Elections is ordered
to enable the vote verification feature of the vote counting machines, which prints
the voter's choices without prejudice to the issuance of guidelines to regulate the
release and disposal of the issued receipt; as well as other measures that it deems
necessary to ensure clean, honest and orderly cieclions such as. but not limited
to, ensuring that after voter verification, receipts should be deposited in a separate
ballot box and not be taken out of the precinct. Id. at 10.[53] RA No. 8436, as
amended by RA No. 9369.

[54]
CONSTITUTION, Art. V, Sec. 2. This section provides that "[t]he Congress shall
provide a system for securing the secrecy and sanctity of the ballot as well as a
system for absentee voting by qualified Filipinos abroad;" See RA No. 8436, as
amended, Sec. 1.

[55]
G.R. Nos. 206719, 206784, and 207755, April 10, 2019.

[56]
See Aratuc v. COMELEC, 177 Phil. 205, 224 (1979).

[57]
73 Phil. 288 (1941).

[58]
Id. at 294-296.

[59]
So v. Hon. Tacla, Jr., 648 Phil. 149, 163 ( 2010), citing David v. Macapagal-
Arroyo, 522 Phil. 705, 753 (2006).

[60]
MAC or Media Access Control address refers to a unique identifier assigned to
a network device. It is made up of six two-digit hexadecimal numbers separated
by colons. It is permanently embedded on the device and assigned by the vendor
or manufacturer of the device. MAC Address, the Tech Terms Dictionary. Accessed
on August 25, 2020 at https://techterms.com/definition/macaddress.
[61]
IP or Internet Protocol address is a unique address that enables a network
device to communicate with and locate other devices within the same network. IP
Address, the Tech Terms Dictionary. Accessed on August 25, 2020 at
https://techterms.com/definition/ip_address.

[62]
See Republic Act No. 8436, Section 5.

[63]
(Notice), G.R. No. 224027, October 11, 2016.

[64]
Id.

[65]
See Bagumbayan VNP Movement, Inc., supra note 7, at 1319; Guingona, Jr.
v. COMELEC, supra note 37, at 530-531; Center for People Empowerment in
Government v. COMELEC, 645 Phil. 293 (2010).

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