Thursday, April 3, 2014

CYBER ISSUES: The Supreme Court rules on the constitutionality of the Cybercrime Prevention Act of 2012

By Siesta-friendly

The Cybercrime Prevention Act of 2012 (Republic Act No. 10175) has caught the attention of lawyers and netizens alike for its alleged over-reaching provisions.  Because petitions challenging the constitutionality of certain provisions of the law were filed with the SC, we shall deal not with the Act but with the SC ruling on the Act which was laid down in February 2014.   

To enumerate, the assailed provisions of the Act are:

  1. Section 4(a)(1) on Illegal Access;
  2. Section 4(a)(3) on Data Interference;
  3. Section 4(a)(6) on Cyber-squatting;
  4. Section 4(b)(3) on Identity Theft;
  5. Section 4(c)(1) on Cybersex;
  6. Section 4(c)(2) on Child Pornography;
  7. Section 4(c)(3) on Unsolicited Commercial Communications;
  8. Section 4(c)(4) on Libel;
  9. Section 5 on Aiding or Abetting and Attempt in the Commission of Cybercrimes;
  10. Section 6 on the Penalty of One Degree Higher;
  11. Section 7 on the Prosecution under both the Revised Penal Code (RPC) and R.A. 10175;
  12. Section 8 on Penalties;
  13. Section 12 on Real-Time Collection of Traffic Data;
  14. Section 13 on Preservation of Computer Data;
  15.  Section 14 on Disclosure of Computer Data;
  16.  Section 15 on Search, Seizure and Examination of Computer Data;
  17.  Section 17 on Destruction of Computer Data;
  18.  Section 19 on Restricting or Blocking Access to Computer Data;
  19.  Section 20 on Obstruction of Justice;
  20.  Section 24 on Cybercrime Investigation and Coordinating Center (CICC); and
  21.  Section 26(a) on CICC’s Powers and Functions.
Because they were connected with some petitioners’ issues with the Cybercrime Prevention Act in relation to libel, Articles 353, 354, 361, and 362 of the Revised Penal Code (on libel) were also assailed.

Of the 21 challenged provisions, the SC struck down 3 for being unconstitutional while the other 18 provisions were declared valid and constitutional.  2 provisions, however, were partially struck down and partially upheld:

1.      Section 4(c)(4) that penalizes online libel as VALID and CONSTITUTIONAL with respect to the original author of the post; but VOID and UNCONSTITUTIONAL with respect to others who simply receive the post and react to it; and

2.      Section 5 that penalizes aiding or abetting and attempt in the commission of cybercrimes as VALID and CONSTITUTIONAL only in relation to Section 4(a)(1) on Illegal Access, Section 4(a)(2) on Illegal Interception, Section 4(a)(3) on Data Interference, Section 4(a)(4) on System Interference, Section 4(a)(5) on Misuse of Devices, Section 4(a)(6) on Cyber-squatting, Section 4(b)(1) on Computer-related Forgery, Section 4(b)(2) on Computer-related Fraud, Section 4(b)(3) on Computer-related Identity Theft, and Section 4(c)(1) on Cybersex; but VOID and UNCONSTITUTIONAL with respect to Sections 4(c)(2) on Child Pornography, 4(c)(3) on Unsolicited Commercial Communications, and 4(c)(4) on online Libel.

For their guidance, Information and communications technology (ICT) users are encouraged to read the law and the SC decision.  Warning: the decision is 50 pages long and in single space.

Ponente Justice Abad tackled each assailed provision one by one. And so shall we.

On Illegal Access

“SEC. 4. Cybercrime Offenses. — The following acts constitute the offense of cybercrime punishable under this Act:
(a)    Offenses against the confidentiality, integrity and availability of computer data and systems:
(1)   Illegal Access. – The access to the whole or any part of a computer system without right.”

The SC ruled this provision is constitutional.  The petitioners claimed that the provision “fails to meet the strict scrutiny standard required of laws that interfere with the fundamental rights of the people”.  In upholding the provision, the SC ruled that “no fundamental freedom, like speech, is involved in punishing what is essentially a condemnable act – accessing the computer system of another without right.”

On Data Interference

SEC. 4. Cybercrime Offenses. — The following acts constitute the offense of cybercrime punishable under this Act:
(a)    Offenses against the confidentiality, integrity and availability of computer data and systems:
x x x
(2)   Data Interference. — The intentional or reckless alteration, damaging, deletion or deterioration of computer data, electronic document, or electronic data message, without right, including the introduction or transmission of viruses.

The SC ruled this provision is constitutional.  In response to petitioners’ claim that this provision “suffers from overbreadth in that, while it seeks to discourage data interference, it intrudes into the area of protected speech and expression, creating a chilling and deterrent effect on these guaranteed freedoms”, the SC held that the provision “does not encroach on these freedoms at all. It simply punishes what essentially is a form of vandalism, the act of willfully destroying without right the things that belong to others, in this case their computer data, electronic document, or electronic data message.  Such act has no connection to guaranteed freedoms.  There is no freedom to destroy other people’s computer systems and private documents.”

On Cyber-squatting

Section 4. Cybercrime Offenses. – The following acts constitute the offense of cybercrime punishable under this Act:

(a)    Offenses against the confidentiality, integrity and availability of computer data and systems:
x x x
(6)   Cyber-squatting. – The acquisition of domain name over the internet in bad faith to profit, mislead, destroy the reputation, and deprive others from registering the same, if such a domain name is:
(i)     Similar, identical, or confusingly similar to an existing trademark registered with the appropriate government agency at the time of the domain name registration;
(ii)   Identical or in any way similar with the name of a person other than the registrant, in case of a personal name; and
(iii) Acquired without right or with intellectual property interests in it.

The SC ruled this provision is constitutional.  Petitioners claimed that this provision “violates the equal protection clause in that, not being narrowly tailored, it will cause a user using his real name to suffer the same fate as those who use aliases or take the name of another in satire, parody, or any other literary device.”  The SC held that “it is the evil purpose for which [the alleged violator] uses the name that the law condemns.  The law is reasonable in penalizing him for acquiring the domain name in bad faith to profit, mislead, destroy reputation, or deprive others who are not ill-motivated of the rightful opportunity of registering the same.” [underscoring supplied]

On Computer-related Identity Theft

Section 4. Cybercrime Offenses. – The following acts constitute the offense of cybercrime punishable under this Act:
x x x
(b)   Computer-related Offenses:
x x x
(3)   Computer-related Identity Theft. – The intentional acquisition, use, misuse, transfer, possession, alteration, or deletion of identifying information belonging to another, whether natural or juridical, without right: Provided: that if no damage has yet been caused, the penalty imposable shall be one (1) degree lower.

The SC ruled this provision is constitutional.  Petitioners claimed that this provision “violates the constitutional rights to due process and to privacy and correspondence, and transgresses the freedom of the press.” 

In negating the right to privacy issue, the SC held that the provision “punishes those who acquire or use such identifying information without right, implicitly to cause damage. Petitioners simply fail to show how government effort to curb computer-related identity theft violates the right to privacy and correspondence as well as the right to due process of law.”

In negating the overbreadth issue, the SC held that “specific conducts proscribed do not intrude into guaranteed freedoms like speech. Clearly, what this section regulates are specific actions: the acquisition, use, misuse or deletion of personal identifying data of another. There is no fundamental right to acquire another’s personal data.”

In countering the freedom of the press issue that “journalists would be hindered from accessing the unrestricted user account of a person in the news to secure information about him that could be published,” the SC held that “this is not the essence of identity theft that the law seeks to prohibit and punish. Evidently, the theft of identity information must be intended for an illegitimate purpose. Moreover, acquiring and disseminating information made public by the user himself cannot be regarded as a form of theft.” Further, the SC said that since intent to gain is an essential element to fall within the provision’s scope, “the press, whether in quest of news reporting or social investigation, has nothing to fear since a special circumstance is present to negate intent to gain which is required by this Section.” [underscoring supplied]

On Cybersex

Sec. 4. Cybercrime Offenses. – The following acts constitute the offense of cybercrime punishable under this Act:
x x x
(c)    Content-related Offenses:
(1)    Cybersex. – The willful engagement, maintenance, control, or operation, directly or indirectly, of any lascivious exhibition of sexual organs or sexual activity, with the aid of a computer system, for favor or consideration.

The SC ruled this provision is constitutional.  In claiming that this provision violates the freedom of expression, petitioners alleged that “private communications of sexual character between husband and wife or consenting adults, which are not regarded as crimes under the penal code, would now be regarded as crimes when done “for favor” in cyberspace.”

The SC went back to the deliberations in Congress and found that the “deliberations show a lack of intent to penalize a “private showing x x x between and among two private persons x x x although that may be a form of obscenity to some.” The understanding of those who drew up the cybercrime law is that the element of “engaging in a business” is necessary to constitute the illegal cybersex. The Act actually seeks to punish cyber prostitution, white slave trade, and pornography for favor and consideration.” [underscoring supplied]

Okay, private non-profit exhibition of sexual organs or sexual activity may not be covered (no pun intended).  But what about public, for profit, but educational/artistic/informative (as in for medical purposes) - even if lascivious - exhibition of sexual organs or sexual activity? Since a museum would normally charge entrance fees, and it is not inconceivable that a museum will have an art exhibition showing sexual organs or sexual activity, the museum may unjustly be punished under this provision once it uses ICT in relation to its exhibition.

On Child Pornography

Sec. 4. Cybercrime Offenses. – The following acts constitute the offense of cybercrime punishable under this Act:
x x x
(c)    Content-related Offenses:
x x x
(2)    Child Pornography. — The unlawful or prohibited acts defined and punishable by Republic Act No. 9775 or the Anti-Child Pornography Act of 2009, committed through a computer system: Provided, That the penalty to be imposed shall be (1) one degree higher than that provided for in Republic Act No. 9775.

The SC ruled this provision is constitutional.  Petitioners feared “that a person who merely doodles on paper and imagines a sexual abuse of a 16-year-old is not criminally liable for producing child pornography but one who formulates the idea on his laptop would be. Further, if the author bounces off his ideas on Twitter, anyone who replies to the tweet could be considered aiding and abetting a cybercrime.” 

The SC held that this provision “merely expands the scope of the Anti-Child Pornography Act of 200931 (ACPA) to cover identical activities in cyberspace” and that “no one can complain since the intensity or duration of penalty is a legislative prerogative and there is rational basis for such higher penalty.  The potential for uncontrolled proliferation of a particular piece of child pornography when uploaded in the cyberspace is incalculable.”

Perhaps petitioners should have also challenged the constitutionality of the relevant provisions of the ACPA so that the SC could have tackled that issue as well.

On Unsolicited Commercial Communications

Sec. 4. Cybercrime Offenses. – The following acts constitute the offense of cybercrime punishable under this Act:
x x x
(c)    Content-related Offenses:
x x x
(3)    Unsolicited Commercial Communications. – The transmission of commercial electronic communication with the use of computer system which seeks to advertise, sell, or offer for sale products and services are prohibited unless:
(i)     There is prior affirmative consent from the recipient; or
(ii)   The primary intent of the communication is for service and/or administrative announcements from the sender to its existing users, subscribers or customers; or
(iii) The following conditions are present:
(aa)           The commercial electronic communication contains a simple, valid, and reliable way for the recipient to reject receipt of further commercial electronic messages (opt-out) from the same source;
(bb)           The commercial electronic communication does not purposely disguise the source of the electronic message; and
(cc)            The commercial electronic communication does not purposely include misleading information in any part of the message in order to induce the recipients to read the message.

The SC found this provision unconstitutional.  The SC that “[t]o prohibit the transmission of unsolicited ads would deny a person the right to read his emails, even unsolicited commercial ads addressed to him. Commercial speech is a separate category of speech which is not accorded the same level of protection as that given to other constitutionally guaranteed forms of expression but is nonetheless entitled to protection. The State cannot rob him of this right without violating the constitutionally guaranteed freedom of expression. Unsolicited advertisements are legitimate forms of expression.”

On Libel

In the Revised Penal Code (RPC)

Art. 353. Definition of libel. — A libel is public and malicious imputation of a crime, or of a vice or defect, real or imaginary, or any act, omission, condition, status, or circumstance tending to cause the dishonor, discredit, or contempt of a natural or juridical person, or to blacken the memory of one who is dead.

Art. 354. Requirement for publicity. — Every defamatory imputation is presumed to be malicious, even if it be true, if no good intention and justifiable motive for making it is shown, except in the following cases:

1.      A private communication made by any person to another in the performance of any legal, moral or social duty; and
2.      A fair and true report, made in good faith, without any comments or remarks, of any judicial, legislative or other official proceedings which are not of confidential nature, or of any statement, report or speech delivered in said proceedings, or of any other act performed by public officers in the exercise of their functions.

Art. 355. Libel means by writings or similar means. — A libel committed by means of writing, printing, lithography, engraving, radio, phonograph, painting, theatrical exhibition, cinematographic exhibition, or any similar means, shall be punished by prision correccional in its minimum and medium periods or a fine ranging from 200 to 6,000 pesos, or both, in addition to the civil action which may be brought by the offended party.

In the Cybercrime Prevention Act of 2012

Sec. 4. Cybercrime Offenses. — The following acts constitute the offense of cybercrime punishable under this Act:
x x x
(c)    Content-related Offenses:
x x x
(4)         Libel. — The unlawful or prohibited acts of libel as defined in Article 355 of the Revised Penal Code, as amended, committed through a computer system or any other similar means which may be devised in the future.

The SC upheld the constitutionality of the libel provisions in the RPC and the Cybercrime Prevention Act even as petitioners claimed that said provisions violate the right to freedom of expression because the provisions require “presumed malice” while the latest jurisprudence already replaces it with the higher standard of “actual malice” as a basis for conviction.”

The SC held that, although Art. 356 of the RPC states that “[e]very defamatory imputation is presumed to be malicious”, where the offended party is a public official or a public figure, the accused can claim absence of actual malice even when his/her statement turns out to be false.  But “where the offended party is a private individual, the prosecution need not prove the presence of malice [as it is presumed].  xxx  For his defense, the accused must show that he has a justifiable reason for the defamatory statement even if it was in fact true.”

When petitioners claimed that the provisions violated the Philippines’ obligations under the International Covenant of Civil and Political Rights (ICCPR), citing the UNHRC case “Adonis v. Republic of the Philippines” which held that “penal defamation laws should include the defense of truth”, the SC qualified this ruling by stating that the UNCHR did not hold “that the truth of the defamatory statement should constitute an all-encompassing defense.” The SC further cites Art. 361 of the RPC which “recognizes truth as a defense but under the condition that the accused has been prompted in making the statement by good motives and for justifiable ends.” 

When petitioners claimed that the UNCHR, in the Adonis case, enjoined the Philippines to decriminalize libel, the SC noted that the UNCHR merely “suggested that defamation laws be crafted with care to ensure that they do not stifle freedom of expression.”  It can be argued that it is in criminalizing libel that ensures freedom of expression is stifled – for who would dare speak freely if imprisonment is the consequence?  But, that is not how the SC sees it.

Aiding and Abetting Libel under the Cybercrime Prevention Act

Sec. 5. Other Offenses. — The following acts shall also constitute an offense:
(a)   Aiding or Abetting in the Commission of Cybercrime. – Any person who willfully abets or aids in the commission of any of the offenses enumerated in this Act shall be held liable.
(b)   Attempt in the Commission of Cybercrime. — Any person who willfully attempts to commit any of the offenses enumerated in this Act shall be held liable.

The SC made distinctions here and declared “Section 5, in relation to Section 4(c)(4) on Libel, Section 4(c)(3) on Unsolicited Commercial Communications, and Section 4(c)(2) on Child Pornography” is unconstitutional for its “chilling effect on the freedom of expression”.

The SC acknowledged that the “complex web of interaction on social media websites” - like pressing “Like”, “Comment” or “Share” in relation to, or re-tweeting, an alleged libelous statement or a statement relating to child pornography – creates many actors (potentially millions) who may be held liable under Sec. 5 thus giving “law enforcers such latitude that they could arbitrarily or selectively enforce the law” and giving the law a “broad sweep that generates chilling effect on those who express themselves through cyberspace posts, comments, and other messages.“

However, Section 5 in relation to “Section 4(a)(1) on Illegal Access, Section 4(a)(2) on Illegal Interception, Section 4(a)(3) on Data Interference, Section 4(a)(4) on System Interference, Section 4(a)(5) on Misuse of Devices, Section 4(a)(6) on Cyber-squatting, Section 4(b)(1) on Computer-related Forgery, Section 4(b)(2) on Computer-related Fraud, Section 4(b)(3) on Computer-related Identity Theft, and Section 4(c)(1) on Cybersex is constitutional.  The SC determined that “none of these offenses borders on the exercise of the freedom of expression” and the “crime of willfully attempting to commit any of these offenses is for the same reason not objectionable.”

On the Penalty for Committing a Crime through the use of ICT

Sec. 6.  All crimes defined and penalized by the Revised Penal Code, as amended, and special laws, if committed by, through and with the use of information and communications technologies shall be covered by the relevant provisions of this Act: Provided, That the penalty to be imposed shall be one (1) degree higher than that provided for by the Revised Penal Code, as amended, and special laws, as the case may be.

In upholding this provision, he SC held that “Section 6 merely makes commission of existing crimes through the internet a qualifying circumstance   x x x  In using the technology in question, the offender often evades identification and is able to reach far more victims or cause greater harm.  The distinction, therefore, creates a basis for higher penalties for cybercrimes.” 

The increase in penalty by one full degree, with no opportunity to mitigate the same, seems unjustifiably harsh, especially when it comes to libel where the threat of a higher penalty may deter free speech and which act, in a more  enlightened world, would not be criminal in the first place.

Liability under Other Laws

Sec. 7. Liability under Other Laws. — A prosecution under this Act shall be without prejudice to any liability for violation of any provision of the Revised Penal Code, as amended, or special laws.

This is about double jeopardy and the SC made distinctions on this provision’s application.  In cases of online libel and online child pornography, the SC held that double jeopardy applies such that one can’t be separately prosecuted for the same online libel under the RPC and under the Cybercrime Prevention Act nor can one be separately prosecuted for the same online libel under the ACPA and the Cybercrime Prevention Act.

However, as regards all other cases, the SC held that it “would rather leave the determination of the correct application of Section 7 to actual cases”.

On the Penalties

Sec. 8. Penalties. — Any person found guilty of any of the punishable acts enumerated in Sections 4(a) and 4(b) of this Act shall be punished with imprisonment of prision mayor or a fine of at least Two hundred thousand pesos (PhP200,000.00) up to a maximum amount commensurate to the damage incurred or both.

Any person found guilty of the punishable act under Section 4(a)(5) shall be punished with imprisonment of prision mayor or a fine of not more than Five hundred thousand pesos (PhP500,000.00) or both.

If punishable acts in Section 4(a) are committed against critical infrastructure, the penalty of reclusion temporal or a fine of at least Five hundred thousand pesos (PhP500,000.00) up to maximum amount commensurate to the damage incurred or both, shall be imposed.

Any person found guilty of any of the punishable acts enumerated in Section 4(c)(1) of this Act shall be punished with imprisonment of prision mayor or a fine of at least Two hundred thousand pesos (PhP200,000.00) but not exceeding One million pesos (PhP1,000,000.00) or both.

Any person found guilty of any of the punishable acts enumerated in Section 4(c)(2) of this Act shall be punished with the penalties as enumerated in Republic Act No. 9775 or the “Anti-Child Pornography Act of 2009:” Provided, That the penalty to be imposed shall be one (1) degree higher than that provided for in Republic Act No. 9775, if committed through a computer system.

Any person found guilty of any of the punishable acts enumerated in Section 4(c)(3) shall be punished with imprisonment of arresto mayor or a fine of at least Fifty thousand pesos (PhP50,000.00) but not exceeding Two hundred fifty thousand pesos (PhP250,000.00) or both.

Any person found guilty of any of the punishable acts enumerated in Section 5 shall be punished with imprisonment one (1) degree lower than that of the prescribed penalty for the offense or a fine of at least One hundred thousand pesos (PhP100,000.00) but not exceeding Five hundred thousand pesos (PhP500,000.00) or both.

The SC found this provision constitutional and held that “[t]he matter of fixing penalties for the commission of crimes is as a rule a legislative prerogative. xxx Judges and magistrates can only interpret and apply them and have no authority to modify or revise their range as determined by the legislative department. The courts should not encroach on this prerogative of the lawmaking body.”

On Real-time Collection of Data

Sec. 12. Real-Time Collection of Traffic Data. — Law enforcement authorities, with due cause, shall be authorized to collect or record by technical or electronic means traffic data in real-time associated with specified communications transmitted by means of a computer system.

Traffic data refer only to the communication’s origin, destination, route, time, date, size, duration, or type of underlying service, but not content, nor identities.

All other data to be collected or seized or disclosed will require a court warrant.

Service providers are required to cooperate and assist law enforcement authorities in the collection or recording of the above-stated information.

The court warrant required under this section shall only be issued or granted upon written application and the examination under oath or affirmation of the applicant and the witnesses he may produce and the showing: (1) that there are reasonable grounds to believe that any of the crimes enumerated hereinabove has been committed, or is being committed, or is about to be committed; (2) that there are reasonable grounds to believe that evidence that will be obtained is essential to the conviction of any person for, or to the solution of, or to the prevention of, any such crimes; and (3) that there are no other means readily available for obtaining such evidence.

The SC found this provision unconstitutional for violating the right to privacy.  The SC said that “[I]n assessing regulations affecting privacy rights, courts should balance the legitimate concerns of the State against constitutional guarantees.”  To be upheld, a law requiring the disclosure of private matters must show that 1) “the requirement has a rational relation to the purpose of the law”, 2) “there is a compelling State interest behind the law”, and 3) “the provision itself is narrowly drawn”.

The SC held that the provision failed the “narrowly drawn” element.  A crucial term in the challenged provision is in the opening sentence: “Law enforcement authorities, with due cause, shall be authorized …”.   ‘Due cause’ was deemed vague in this instance as it justifies “a general gathering of data … akin to the use of a general search warrant that the Constitution prohibits.”  Due Cause was also deemed “not descriptive of the purpose for which data collection will be used” and gave law enforcement agencies authority that is “too sweeping and without restraint”.  The Court stated that laws that allow the use of technology to monitor individuals must be “written with specificity and definiteness as to ensure respect for the rights that the Constitution guarantees”. 

The SC further noted that while the provision says “that traffic data collection should not disclose identities or content data, such restraint is but an illusion.  Admittedly, nothing can prevent law enforcement agencies holding these data in their hands from looking into the identity of their sender or receiver and what the data contains. This will unnecessarily expose the citizenry to leaked information or, worse, to extortion from certain bad elements in these agencies.”

On Preservation of Computer Data

Sec. 13. Preservation of Computer Data. — The integrity of traffic data and subscriber information relating to communication services provided by a service provider shall be preserved for a minimum period of six (6) months from the date of the transaction. Content data shall be similarly preserved for six (6) months from the date of receipt of the order from law enforcement authorities requiring its preservation.

Law enforcement authorities may order a one-time extension for another six (6) months: Provided, That once computer data preserved, transmitted or stored by a service provider is used as evidence in a case, the mere furnishing to such service provider of the transmittal document to the Office of the Prosecutor shall be deemed a notification to preserve the computer data until the termination of the case.

The service provider ordered to preserve computer data shall keep confidential the order and its compliance.

The SC found this provision constitutional. Petitioners claimed that “Section 13 constitutes an undue deprivation of the right to property. They liken the data preservation order that law enforcement authorities are to issue as a form of garnishment of personal property in civil forfeiture proceedings. Such order prevents internet users from accessing and disposing of traffic data that essentially belong to them.”

While not denying that “the contents of materials sent or received through the internet belong to their authors or recipients and are to be considered private communications”, and despite the petitioners’ claim that ICT users have the right to access and dispose “of traffic data that essentially belong to them”, the SC upheld this provision while only addressing ICT users’ right to access their data.  The SC ruled that “the data that service providers preserve on orders of law enforcement authorities are not made inaccessible to users by reason of the issuance of such orders. The process of preserving data will not unduly hamper the normal transmission or use of the same.”  No mention of ICT users’ right to dispose data that belong to them.

Disclosure of Computer Data

Sec. 14. Disclosure of Computer Data. — Law enforcement authorities, upon securing a court warrant, shall issue an order requiring any person or service provider to disclose or submit subscriber’s information, traffic data or relevant data in his/its possession or control within seventy-two (72) hours from receipt of the order in relation to a valid complaint officially docketed and assigned for investigation and the disclosure is necessary and relevant for the purpose of investigation.

The SC found this provision constitutional and ruled that “what Section 14 envisions is merely the enforcement of a duly issued court warrant, a function usually lodged in the hands of law enforcers to enable them to carry out their executive functions. The prescribed procedure for disclosure would not constitute an unlawful search or seizure nor would it violate the privacy of communications and correspondence. Disclosure can be made only after judicial intervention.”

On the Search, Seizure and Examination of Computer Data

Sec. 15. Search, Seizure and Examination of Computer Data. — Where a search and seizure warrant is properly issued, the law enforcement authorities shall likewise have the following powers and duties.

Within the time period specified in the warrant, to conduct interception, as defined in this Act, and:

(a)   To secure a computer system or a computer data storage medium;
(b)   To make and retain a copy of those computer data secured;
(c)    To maintain the integrity of the relevant stored computer data;
(d)   To conduct forensic analysis or examination of the computer data storage medium; and
(e)   To render inaccessible or remove those computer data in the accessed computer or computer and communications network.

Pursuant thereof, the law enforcement authorities may order any person who has knowledge about the functioning of the computer system and the measures to protect and preserve the computer data therein to provide, as is reasonable, the necessary information, to enable the undertaking of the search, seizure and examination.

Law enforcement authorities may request for an extension of time to complete the examination of the computer data storage medium and to make a return thereon but in no case for a period longer than thirty (30) days from date of approval by the court.

The SC found this provision constitutional. While petitioners claim this provision “will supplant established search and seizure procedures, the SC ruled that the law “merely enumerates the duties of law enforcement authorities that would ensure the proper collection, preservation, and use of computer system or data that have been seized by virtue of a court warrant.  The exercise of these duties do not pose any threat on the rights of the person from whom they were taken. Section 15 does not appear to supersede existing search and seizure rules but merely supplements them.”

On the Destruction of Computer Data

Sec. 17. Destruction of Computer Data. — Upon expiration of the periods as provided in Sections 13 and 15, service providers and law enforcement authorities, as the case may be, shall immediately and completely destroy the computer data subject of a preservation and examination.

The SC found this provision constitutional.  In denying petitioners’ claim that “such destruction of computer data subject of previous preservation or examination violates the user’s right against deprivation of property without due process of law,” the SC held that “it is unclear that the user has a demandable right to require the service provider to have that copy of the data saved indefinitely for him in its storage system. If he wanted them preserved, he should have saved them in his computer when he generated the data or received it. He could also request the service provider for a copy before it is deleted.”

On Restricting or Blocking Access to Computer Data

Sec. 19. Restricting or Blocking Access to Computer Data.— When a computer data is prima facie found to be in violation of the provisions of this Act, the DOJ shall issue an order to restrict or block access to such computer data.

The SC found this provision unconstitutional “for being violative of the constitutional guarantees to freedom of expression and against unreasonable searches and seizures.”

The SC held that “it is indisputable that computer data, produced or created by their writers or authors may constitute personal property. Consequently, they are protected from unreasonable searches and seizures, whether while stored in their personal computers or in the service provider’s systems.”

Because the government, pursuant to this provision, will “seize[s] and place[s] the computer data under its control and disposition without a warrant,” the provision violates “Section 2, Article III of the 1987 Constitution which provides “the right to be secure in one’s papers and effects against unreasonable searches and seizures of whatever nature and for any purpose shall be inviolable” and that “no search warrant shall issue except upon probable cause to be determined personally by the judge.”

Plus, the SC held that “content of the computer data can also constitute speech. In such a case, Section 19 operates as a restriction on the freedom of expression over cyberspace” if the restriction is 1) done without judicial warrant, 2) fails the dangerous tendency doctrine, 3)   the balancing of interest test, or 4) the clear and present danger rule.  Section 19’s requirement that the “computer data is prima facie found to be in violation of the provisions of this Act” is insufficient justification for the restriction

On Noncompliance with the Enforcement and Implementation of the Act

Sec. 20. Noncompliance. — Failure to comply with the provisions of Chapter IV hereof specifically the orders from law enforcement authorities shall be punished as a violation of Presidential Decree No. 1829 with imprisonment of prision correctional in its maximum period or a fine of One hundred thousand pesos (Php100,000.00) or both, for each and every noncompliance with an order issued by law enforcement authorities.

The SC found this provision constitutional despite petitioners’ claim that it is a bill of attainder[1].  The SC reasoned that “since the non-compliance would be punished as a violation of Presidential Decree (P.D.) 1829, Section 20 necessarily incorporates elements of the offense which are defined therein.  If Congress had intended for Section 20 to constitute an offense in and of itself, it would not have had to make reference to any other statue or provision.”  So violation of Section 20, in relation to P.D. No. 1829, must still be done by “any person who knowingly or willfully obstructs, impedes, frustrates or delays the apprehension of suspects and the investigation and prosecution of criminal cases” in the manner provided under P.D. 1829.

On the Powers of the Cybercrime Investigation and Coordinating Center

Sec. 24. Cybercrime Investigation and Coordinating Center.– There is hereby created, within thirty (30) days from the effectivity of this Act, an inter-agency body to be known as the Cybercrime Investigation and Coordinating Center (CICC), under the administrative supervision of the Office of the President, for policy coordination among concerned agencies and for the formulation and enforcement of the national cybersecurity plan.

Sec. 26. Powers and Functions.– The CICC shall have the following powers and functions:

(c)    To formulate a national cybersecurity plan and extend immediate assistance of real time commission of cybercrime offenses through a computer emergency response team (CERT); x x x.

The SC found this provision constitutional. Petitioners claimed that the authority given the CICC to formulate a “national cybersecurity plan without any sufficient standards or parameters for it to follow” was an undue delegation of legislative power by the Congress to the CICC.  The SC cited the 2 tests to determine undue delegation of legislative power: 1)  the completeness test, i.e,  “the law must be complete in all its terms and conditions when it leaves the legislature such that when it reaches the delegate, the only thing he will have to do is to enforce it”; and 2) the sufficient standard test which “mandates adequate guidelines or limitations in the law to determine the boundaries of the delegate’s authority and prevent the delegation from running riot.”

The SC found the Act is complete and gave “sufficient standards for the CICC to follow when it provided a definition of cybersecurity.”  Under Sec. 3 (k), cybersecurity “refers to the collection of tools, policies, risk management approaches, actions, training, best practices, assurance and technologies that can be used to protect cyber environment and organization and user’s assets.”  THE SC found that this “definition serves as the parameters within which CICC should work in formulating the cybersecurity plan.”

The SC also found that since “the formulation of the cybersecurity plan is consistent with the policy of the law” stated in Sec. 2 of the Act which is to “prevent and combat such [cyber] offenses by facilitating their detection, investigation, and prosecution at both the domestic and international levels, and by providing arrangements for fast and reliable international cooperation”, and because “the policy is clearly adopted in the interest of law and order, which has been considered as sufficient standard”, then the 2 provisions are valid.

Because of the multifaceted connections/transactions/relations in the realm of ITC and the nature of ITC to evolve fast, the Cybercrime Prevention Act of 2012 will likely be subject of numerous challenges filed with the courts, if not proposed amendments filed with the legislature, to jibe with the times. Changes may come sooner than we think as appeals to the decision have already been filed.


[1]  bill of attainder = a legislative act that imposes punishment without a trial. Merriam-Webster.  http://www.merriam-webster.com/dictionary/bill%20of%20attainder


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