Case Digest (G.R. No. 246332) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In AES Watch, Buklod Pamilya, et al. v. Commission on Elections (G.R. No. 246332, December 9, 2020), petitioners composed of various election‐reform and civic groups and individuals filed a petition for mandamus to compel the COMELEC (1) to enhance the Voter Verifiable Paper Audit Trail (VVPAT) auditability through a “camerambola” solution that would allow voters to photograph receipts after randomizing identity; (2) to adopt a different method of digitally signing electronic election results; and (3) to lift its prohibition on capturing devices inside polling places during voting. The petitioners grounded their demand on Republic Act No. 8436 (as amended by RA 9369), COMELEC’s implementing resolutions for the 2019 National and Local Elections (Resolutions Nos. 10460, 10458, 10525), and precedents such as Bagumbayan-VNP Movement, Inc. v. COMELEC (2016) and Capalla v. COMELEC (2012). COMELEC, through the OSG, opposed on grounds of lack of standing, mootness (as elections had conc Case Digest (G.R. No. 246332) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Legislative and Technological Background
- Republic Act (RA) No. 8436 (1997) authorized the Commission on Elections (COMELEC) to adopt an automated election system (AES).
- RA No. 9369 (2007) amended RA 8436 to permit either paper-based or direct recording electronic systems and prescribed minimum system capabilities:
- Voter Verified Paper Audit Trail (VVPAT) (Sec. 6(e))
- System auditability (Sec. 6(f))
- Authentication of electronically transmitted results (Sec. 30)
- Implementation of AES
- COMELEC used Precinct Count Optical Scan (PCOS) machines in 2010 and 2013, and Vote-Counting Machines (VCMs) in 2016 and 2019.
- Electoral board members employ personal iButton security keys and PINs to initiate machines and authenticate transmissions.
- Prior Jurisprudence
- Capalla v. COMELEC (2012) – Court held PCOS machines produce digitally signed transmissions via iButtons/PINs.
- Bagumbayan-VNP Movement, Inc. v. COMELEC (2016) – Court mandated enabling VCM vote verification feature (print voter receipts), clarified VVPAT distinct from ballots, and allowed COMELEC to issue guidelines on receipt disposal.
- COMELEC Guidelines and Subsequent Petition
- Resolution No. 10088 (2016) – Enabled VCM printing of receipts but prohibited use of capturing devices while voting.
- Resolution No. 10460 (2018) – Adopted VVPAT procedures for 2019 elections, removed “for whatever purpose” from device prohibition but retained ban during voting.
- Petition (April 24, 2019) by AES-WATCH, et al. sought:
- Review and auditability of VVPAT (“camerambola” proposal)
- Alternative digital signature method beyond iButtons/PINs
- Removal of prohibition on capturing devices in polling places
- Interventions:
- United Filipino Consumers & Commuters (UFCC) and individuals – supported petition, requested MAC/IP addresses list
- Bagumbayan-VNP Movement, Inc. – political party with poll watchers and candidates
- COMELEC/OSG Answer – raised mootness, lack of standing, said VVPAT enabled, random manual audit adequate, Section 179 Omnibus Election Code allows photos during counting, Capalla settled digital signature issue.
Issues:
- Do the petitioners and intervenors have legal standing?
- Does a writ of mandamus lie to compel COMELEC to:
- Enhance VVPAT auditability (“camerambola”)?
- Adopt another digital signing method?
- Remove the ban on capturing devices during voting?
- Has COMELEC unlawfully neglected a ministerial duty or abused its discretion?
- Is the prohibition on capturing devices in polling places unconstitutional under the Omnibus Election Code?
- Is the petition moot following the conclusion of the 2019 National Elections?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)