XAVIER UNIVERSITY – COLLEGE OF LAW

CONSTITUTIONAL LAW 2

2nd Semester | A.Y. 2018-2019

Legal Memorandum: Moot Court on Hate Speech

Submitted to:

DEAN ANTONIO GABRIEL M. LA VIÑA

COUNSELS OF MOCHA USON, ET AL

Threjann Ace L. Noli

Kariza Kyle Briones

Simon Peter Zagado

Lilet Zamora

COUNSELS OF RAPPLER

Bianca Andrea Bince

Ma. Theresa Cadiz

Jane Mordeno

Rikha Sabio

Charisse Tiosen

COUNSELS OF FACEBOOK AND TWITTER

Franchette Abalde
Flomar Candole
Maria Princess Biton
 Alyssa Catalan
Republic of the Philippines
SUPREME COURT
Manila
EN BANC

Mocha Uson, Sass Sagot,

Thinking PNoy, Pinoy
Ako Blog, The
Professional Heckler,
Rappler, and Facebook
and Twitter,​ petitioners

-versus​-

National Security
Communications
Commission and Social
Media Registration and
Regulatory Board, et. al,
respondents

----------------------------------------------------

MEMORANDUM

STATEMENT OF RELEVANT FACTS

Have you read or heard somebody being killed because of hate speech about
exchanges on online platform?

According to PNP, Theft, physical assault, and robbery were among the most
common crimes reported to local authorities in 2017. Other common criminal activity
included pickpocketing, confidence schemes, and credit card fraud. Carjacking, robberies,
and violent assaults also occur sporadically throughout the country. These crimes
jeopardize individuals and put them in disadvantage.

PNP data recorded none of these crimes were committed because of fake news and
disinformation attributed to the petitioners. And petitioners never put anybody at the
disadvantage position because of their blogs.

Rappler is an online news platform first founded in 2012 by former CNN journalist
Maria Ressa, operating with a small team of 12 young reporters and developers. While it
was initially seen as a site primarily for young readers, through the power of social media, it
has grown a reputation for its hard-hitting, investigative journalism. However, it was only
after Duterte’s election in 2016, when Rappler began reporting critically on the extrajudicial
killings, human rights violations and fast-rising death toll from Duterte’s brutal war on drugs,
with stories demonstrating that the abuses were being carried out by the police with
Duterte’s approval.

In addition to these laws, a third law was issued making Facebook, Twitter,
WhatsApp, Instagram, and other internet/social media platforms subject to pecuniary
sanctions if any posts it allowed in its platforms caused social conflict and in particular
result in death and defamation of individuals. They can also be summarily shut down as
decided by the government.

Technology now allows us to work in ways never before possible to create

connected communities and to tap “the wisdom of crowds,” the process of harnessing a
group’s collective answer which, under the right conditions, have proven to be better than
1
any single expert opinion.

Our Constitution promotes freedom of the press, of speech, and of expression as a

right of every Filipino; and inconsequent to the right to freely report on and criticize (on the
freedom of expression and speech). With that given freedom, everyone has the liberty to
say, write, argue, criticize, disseminate and publish freely whatever one pleases without
interference and fear of subsequent prosecution or punishment. Restricting such rights by
statutes when they are actually and expressly provided by the Constitution, is alarming and
critical point.

ISSUES:

To hear the petitioners in this court, we allege on the following issues

1. Does the police power of the state include the power to address hate speech
and take measures to prevent it?
2. Does RA 123456 violate the Bill of Rights?
3. Does RA 234567 violate the Bill of Rights?
4. Does the third law on internet and social media platforms violate the Bill of
Rights?
5. Are these three laws unconstitutional?

THE ARGUMENTS

I. DOES THE POLICE POWER OF THE STATE INCLUDE THE POWER TO

ADDRESS HATE SPEECH AND TAKE MEASURES TO PREVENT IT?

1
https://www.rappler.com/about-rappler/about-us/385-about-rappler.
 No. ​It is a prior restraint of freedom as espoused in Section 4, Article III of the 1987
Constitution. ​What is suppressed is the content based or censorship of petitioners’
blogs.​ What the laws are misplaced and are wanting of what really their purposes.

Content-based regulations can either be based on the viewpoint of the speaker or

2
the subject of the expression and not on the part of the audience. The hate speech violent
effects can only be measured against the reactions of the audience and not on the
substance and viewpoint of the speakers. This is where the problem lies.

Definition of hate speech is problematic, susceptible to subjective interpretation, and

pre-motivated violent reactions, hence, a paramount threat to freedom of speech.

Hate Speech ​as defined in this assailed Act refer to a communication that carries no
meaning other than the expression of hatred for some group, especially in circumstances in
which it is likely to provoke violence. This definition is vague on its face. Netizens in social
media platforms may interpret simple posts, which are not intended to provoke violence,
like hate speech. The law fails to specify those speeches that within the ambit of hate
speech.

A democracy needs a healthy public sphere where the people can exchange ideas,
acquire knowledge and information, confront public issues, or ​discuss matters of public
interest, without fear of reprisals.

The ideas that may be expressed under this freedom are confined not only to those
that are conventional or acceptable to the majority. ​To be truly meaningful, freedom of
speech and of the press should allow and even encourage the articulation of the
unorthodox view, though it hostile to or derided by others; or though such view
induces a condition of unrest, creates dissatisfaction with conditions as they are, or
3
even stirs people to anger .

Free speech must be protected ​so that the people can engage in the discussion
and deliberation necessary for the successful operation of democratic institutions. During
discourse, emotions are high in defending one’s cause. Inevitably, a heated discussion may
arise, and may result to cursing or hate speech. ​Thus, no less than our Constitution
4
mandates full protection to freedom of speech, of expression, and of the press .
Corollary, to no person shall be detained solely by reason of his political beliefs and
5
aspirations , invites a wider scope of political discourse without restraints.

What alarmed the petitioners is words meant by them may receive by the
audience in subjective meaning and may impute negative meaning unto it, and no
less than, the Commission is one of those​. Without crystal clear parameters of what are
hate speeches, the Commission has wide latitude of power to tag a genuine speech to be a
hate speech. This law is a roving commission. Petitioners questioned the basis of the

2
Chavez v. Gonzales, G.R. No. 168338
3
Citing ​Terminiello V. City Of Chicago​, 337 US 1, 4 (1949)
4
Constitution, Article III, Section 4.
5
Constitution, Article VI, Section 24 (1).
Commission of tagging the contents of their blog as hate speeches, even though netizens
who viewed and read their blogs were never incited to violence.

On the other hand, a pre-motivated and pre-determined violent reaction is on

deck as immediate response to hate speech. Instead of a subconscious reaction
by audience, conscious violent reactions are conveyed. It becomes a surreal and
sham one. Malice is present. Hence, an opposition or anybody may abuse this
law to impute and indict somebody against their positions to politics. Imagine
what will be the consequence of this, unless, otherwise, this will be used to
silence anybody who wants to critic those who are in positions.

The word “prevent” in the title of this act equates to prohibition and suppression, a
clear violation of free speech, expression or of the press.

Prevent as defined means ​to deprive of power or hope of acting or succeeding​; ​to
keep from happening or existing​; ​to hold or keep back; ​HINDER​, ​STOP​; ​means to deal with
6
beforehand . This is a censorship of petitioners’ blogs, thereby depriving them of their rights
of speech. A clear intention of opposition members in Congress to silence a Filipino who
wants to exercise his fundamental freedom of free speech, of expression or of the press.
7
The Court discussed exhaustively in ​Gonzales v. Commission on Elections :

At the very least, free speech and free press may be identified with the liberty to
discuss publicly and truthfully any matter of public interest without censorship
and punishment. There is to be no previous restraint on the communication of
views or subsequent liability whether in libel suits, prosecution for sedition, or
action for damages, or contempt proceedings ​unless there be a clear and
present danger of substantive evil​ that Congress has a right to prevent.

There is nothing to be called as hate speech for the law in the first place,
prevents hate speech from its conveying to audience, a clear and tantamount
suppression and prohibition of petitioners’ freedom of speech.

Granting however, that the intention of Congress is to regulate hate speech, still,
the law is of wanting in terms of its entirety of purpose. The subject law seeks to
legislate regulations on hate speech but it fails to define on what constitutes hate
speech in its unambiguous terms. These laws might have a compelling goal in
preventing and regulating the circulation of hate speech and fake news, but the danger
it offers far outweighs the danger it want to prevent. The regulation might be of public
interest but it must not be to the detriment of free speech, which is sacred, premium and
a blessing of democracy.

Clear and present danger rule: the well-settled yardstick of curtailing the freedom of
speech, of expression, or of the press.

6
https://www.merriam-webster.com/dictionary/prevent. February 12, 2019
7
137 Phil. 471, 492 (1969)
 It has been settled in many Philippine jurisprudence that police power is so
extensive and all pervading, that the courts refuse to lay down a general rule defining it,
8
but decide each specific case on its merits .

Vast as the power is, however, it must be exercised within the limits set by the
Constitution. In US vs. Toribio, the Court settled that “to justify the State in thus
interposing its authority in behalf of the public, it must appear:

First​, that the interests of the public generally, as distinguished from those of a
particular class, require such interference; and,

Second​, that the means are reasonably necessary for the accomplishment of the
purpose, and not unduly oppressive upon individuals.

The legislature may not, under the guise of protecting the public interests,
arbitrarily interfere with private business, or impose unusual and unnecessary
restrictions upon lawful occupations. In other words, its determination as to what
is a proper exercise of its police powers is not final or conclusive, but is subject to
9
the supervision of the court .

It is well settled that the test for limitations on freedom of expression continues to be
the clear and present danger rule, ​that words are used in such circumstances and are of
such a nature as to create a clear and present danger that they will bring about the
10
substantive evils that the lawmaker has a right to prevent .

Given that deeply ensconced in our fundamental law is the hostility against all prior
11
restraints on speech, and any act that restrains speech is presumed invalid .

Section 2, of Act 123456 “​To prevent Disinformation, Social Conflict and Hate
12
Language” is wanting of what clear and present danger rule it would prevent. It
provides:

It is hereby declared the policy of the State to guarantee people’s right

to know truthful information as anchored in our fundamental rights.
Towards this end, it is likewise declared the policy of the State to
prevent disinformation and misinformation by prohibiting the
proliferation of fake news, fake information, and hate speech on all
media as defined in Section 3 of this Act to guarantee people’s right to
know truthful information as anchored in our fundamental rights.
Towards this end, it is likewise declared the policy of the State to
prevent disinformation and misinformation by prohibiting the

8
Harding vs. People, 32 L.R.A., 445.
9
US vs. Toribio
10
Eastern Broadcasting Corporation (DYRE) v. Dans, G.R. No. L-59329, July 19, 1985, 137 SCRA 628
11
Gonzales V. COMELEC, 137 Phil. 471 (1969); ABS-CBN Broadcasting Corp. V. COMELEC, 380 Phil. 780, 795
(2000)
12
Act 123456
 proliferation of fake news, fake information, and hate speech on all
media as defined in Section 3 of this Act.

Hence, petitioners assail the legislated act being an enforcement of State’s Police
Power has no power to address hate speech and take measures to prevent it for it failed
to overcome the clear and present danger test of a substantive evil.

III. DOES RA 123456 “AN ACT TO PREVENT DISINFORMATION, SOCIAL CONFLICT

AND HATE LANGUAGE” VIOLATES THE BILL OF RIGHTS?

A limited democratic discourse ultimately leads to a less effective democracy, hence,

13
RA 123456 violate the Bill of Rights. Section 4, of Article III provides:

“No law shall be passed abridging the freedom of speech, of

expression, or of the press, or the right of the people peaceably to
assemble and petition the government for redress of grievances”​.

Journalists report and investigate, and this makes accountability possible and
protects society against the abuse of power. Petitioners need to be able to freely report on
all issues and to scrutinize public institutions or those who exercise power. This helps the
greater people to be well-informed and to participate and demand accountability in society’s
14
democratic processes. Corollary to Section 7 of Article III provides :

“the right of people to information on matters of public concern shall

be recognized. Access to official records, and to documents and
papers pertaining to official acts, transactions, or decisions, as well
as to government research data used as basis for policy
development, shall be afforded the citizen, subject to such
limitations as may provided by the law”

Petitioners assail the constitutionality of the enacted laws on the following grounds:

Title of the act is a result of “hodgepodge or logrolling” – Too many subjects and
vague such as social conflict and hate language” an over breadth.

The Constitution is clear about a possible abuse of power by the Congress on

hodgepodge or log-rolling legislation defined as “any act containing several subjects
dealing with the main objects dealing with unrelated matters representing diverse interest,
the main object such combination being to unite the members of the legislature who favor
15
anyone of the subjects in support of the whole act” . This is to prevent surprise or fraud
16
upon legislature .

Paragraph 1, section 26, Article VI provides: ​“Every bill passed by Congress shall
embrace only one subject which shall be expressed in the title thereof”.

13
1987 Constitution
14
​Id.
15
Cruz, I. and Cruz, C. Philippine Political Law, 2014 Edition. Central Book Supple Inc. p.279
16
​Id.
 Petitioners are victims of this log-rolling legislation when hate speech, fake news and
disinformation are lumped together in one legislative act. Clearly, the Opposition to gain its
force to enact the law collated all these 3 distinct subject matters as if these are intertwined
and interrelated, a clear contravention of Paragraph 1, Section 26, Article VI of the 1987
Constitution.

Being a special penal law, making the act as criminal, requires proof beyond
reasonable doubt for an accused to be convicted which cannot be done by summary
proceedings, but an essential full trial proceedings.
17
Paragraph Section 14, of Article III states that no person shall be held to answer for
a criminal offense without due process of law. Corollary to Section 1, of the same article
provides that no person shall be deprived of life, liberty, or property without due process of
18
law, nor shall any person be denied the equal protection of the laws .

By enacting the laws, it has violated the freedom of expression

The petitioners have promised uncompromised journalism that hopefully inspires

smart conversation and change but to be limited and even penalized, pursuant to RA
123456, in providing truthful information in the articles or posts we made when we only
provide the other side of the story about the 2019 elections is, for us, without merit.

Section 2 of the said Act states that it is the policy of the State to guarantee people’s
right to know truthful information as an anchored in our fundamental rights. Rappler is
committed to provide people with truthful information. Truthful information, however, will be
viewed by some group or class differently and such will even spur conflict. Undeniably, it is
not only the circulation of hate speech and fake news which affect social order but even the
truthful information.

We do agree with the pressing need to regulate disinformation and social conflict. It
is legal to ban disinformation for it can cause unnecessary fear and alarm to people. It may
affect public interest in general. Same is given to social conflict for it may affect the national
peace and order - that is being protected and established by the police power of state and
statutes for its maintenance. These are the values upheld by the petitioner when they post
news on their website.

In this Act however, the State’s aim to maintain national security and safety by
mandating the social media platforms to filter post which are considered fake news and
hate speech is not justified. It is therefore submitted before the Honorable Court that there
is no compelling reason to impose such ban. The social conflict we experience is not based
what journalists post on their website. It is not the intention of the petitioners to induce hate
and violence. As submitted by the first counsel, none of the crimes were committed
because of fake news and disinformation attributed to the petitioners. Petitioners did not
deny the public of the truth. What the petitioners submit and post on their official website is

17
1987 Constitution.
18
​Id.
a product of a well-researched, well- grounded, and factual basis and through current
events in the country.

Moreover, this Honourable Court stated that, “Freedom of speech and of the press
means something more than the right to approve existing political beliefs or economic
arrangements, to lend support to official measures, and to take refuge in the existing
climate of opinion on any matter of public consequence. When atrophied, the right
becomes meaningless. The right belongs as well -- if not more to those who question, who
do not conform, and who differ. The ideas that may be expressed under this freedom are
19
confined not only to those that are conventional or acceptable to the majority.

Petitioners have the right of freedom from censorship

Censorship is that officious functionary of the repressive government who tells the
citizen that he may speak only if allowed to do so, and no more and no less than what he is
20
permitted to say on pain of punishment should he be so rash as to disobey. ​Censorship
may come in the form of ​prior restraint​ or ​subsequent punishment​.​

Prior restraint​ means official governmental restrictions on the press or other forms
21
of expression in advance of actual publication or dissemination. On the other hand,
subsequent punishment is the imposition of liability to the individual exercising his freedom.
It may be in any form, such as penal, civil or administrative penalty. Settled is the doctrine
that any system of prior restraint of expression comes to this Court bearing a presumption
22
against its constitutional validity. ​The Government thus carries a heavy burden of showing
23
justification for the enforcement of such a restraint.

It is submitted that what the government is prior restraint. Though the intention of the
government is to regulate hate speech, the government is not regulating but controlling
hate speech.

24
In the case of Chavez v. Gonzales , this Honorable Court defined two types of
restraint upon freedom of expression: (1) content-based restraint or censorship, i.e., the
restriction is based on the subject matter of the utterance or speech; and (2)
​ erely concerned with the incidents of the
content-neutral restraint or censorship ​i.e., m
speech, or one that merely controls the time, place or manner, and under well-defined
standards. In the same case, we find a content-based regulation “will pass constitutional
muster only if justified by a ​compelling reason, and the restrictions imposed are neither
overbroad nor vague. It has been held that under this rule, the evil consequences sought to
be prevented must be ​substantive, extremely serious, and the degree of imminence
extremely high.​ ”

19
Supra.
20
​ .R. No.
Separate Opinion of Chief Justice Hilario G. Davide Jr. (ret.), in ​Kapisanan ng mga Brodkasters sa Pilipinas, G
102983. March 5, 1992.
21
Bernas, The 1987 Constitution of the Republic of the Philippines, A Commentary, 2003 ed., p. 225.
22
Bantam Books, Inc. vs. Sullivan, 372 U.S. 58 (1963).
23
Bernas, ​The 1987 Constitution of the Republic of the Philippines, A Commentary,​ 2003 ed., p. 228.
24
G.R. No. 168338, February 15, 2008
 25
In this connection, Justice Sandoval Gutierrez in her concurring opinion ​cited the
26
ruling in ​American Communication​ ​Association v. Douds ​that when a particular conduct
is regulated in the interest of public order, and the regulation results in an indirect,
conditional, partial abridgement of speech, the duty of the courts is to determine
which of these two conflicting interests demand the greater protection under the
circumstances presented.

Rampant spreading of disinformation, clearly, is not part of what the law provides. If
such is allowed, then someone spreading it - has threatened the peace and security of not
the just the public, but as well as to nation's integrity. The law limit's one's right as to not
encroach other's right; so as the government's capacity to act. And the degradation of trust
of to the government is a serious issue. But what if such trust reposed in the government is
taken for granted causing an adverse effect to the people; and such people happened to be
where sovereign resides and where government's authority emanates (art. 2, sec 1). Such
may be a form of a compelling reason where boundary of "censorship" is exempted; when
the government's act is no longer within the sphere of what the law provides. When a
government's act is causing threat to national integrity; or is shaking the public confidence;
or is only for territorial integrity or political identity.

If those are important to the government most, where do its constituent stand then?
When these constituents are only fighting for their own survival; for their security; and for
their own life?

Then, the people's voice must be heard through these different platforms. We are no
longer just "spreading information" but rather more, asking help to be heard, not by the
government, but by the humanity around the world. Our individual and fundamental rights,
are trembling in our own land.

In the present case, perched at the one hand of the scale is the government’s
interest to maintain public order, while on the other hand is the interest of the public to
know the truth about the last national election and to be fully informed. Which of these
interests should be advanced? We believe the interests to be advanced should be that of
the people.

To be truly meaningful, freedom of speech and of the press should allow and even
encourage the articulation of the unorthodox view, though it be hostile to or derided by
others; or though such view induces a condition of unrest, creates dissatisfaction with
conditions as they are, or even stirs people to anger. To paraphrase Justice Holmes, it is
freedom for the thought that we hate, no less than for the thought that agrees with us.

IV. DOES THE THIRD LAW ON INTERNET AND SOCIAL MEDIA PLATFORMS
VIOLATE THE BILL OF RIGHTS?

To answer the issue on the constitutionality of the law on internet and social media
platforms, it is submitted that the law does violate the Bill of Rights.

25
G.R. NO. 168338, February 15, 2008.
26
339 U.S. 382 (1950).
 Section 7, Article III of the 1987 Constitution provides that the right of the people to
information on matters of public concern shall be recognized. We cannot deny the
importance of the access to internet and social media platforms for Filipino people to be
aware and actively participate or get involve in matters relating to politics and
socio-economic.

The right of the people to know matters pertaining to the integrity of the election
process is of paramount importance. It cannot be sideswiped by the mere speculation that
a public disturbance will ensue. Election is a sacred instrument of democracy. Through it,
we choose the people who will govern us. We entrust to them our businesses, our welfare,
our children, our lives.

In a democratic republic, like the Philippines, it should be noted that “there is a direct
link between freedom of speech and vibrant democracy. Free speech is an indispensable
tool of self-governance in a democratic society. It enables people to obtain information from
a diversity of sources, make decisions, and communicate those decisions to the
government. Rather than having the government establish and dictate the truth, freedom of
27
speech enables the truth to emerge from diverse opinions.”

The law gives us an assertion that the intention of the government is to create a fear
psychosis among journalists and media. The threat of penalizing, and the possibility of
eventual imprisonment/shutting down of the media, exercise a deep and pervasive chilling
effect upon would-be speakers which would then delimit their freedom to express.

It is an infringement of the fundamental rights provided by the Constitution itself to its

constituents. What the Constitution, New Civil Code and the Revised Penal Code provides
are limitations of an individual's right or freedom not affecting other's right and freedom that
causes them (unjust vexation).

Such sanction may affect specifically the following sections under Art. 3:
● Sec. 2 (secure in their persons. ie, your work- being an influencer through
those platforms);
● Sec. 3 (privacy of communication and correspondence);
● Sec. 4 ( freedom of speech, expression); and
● Sec. 7 (people's right to information; ie, your so-called "status," "tweets," and
"posts" are informative about security and peace, and your only means are
these platforms).

According to Forbes, important conversations happen on social media everyday.

Again, almost every business is on social media these days, starting conversations,
connecting with fans and promoting their products or services. A lot of these conversations
do draw in divergent opinions.

Those against strong regulation often state that regulation won’t prevent any harm.
Instead, they believe it will simply stifle the exchange of ideas. There’s also the argument

27
Retrieved from​ http://www.lincoln.edu/criminaljustice/hr/Speech.htm
that enforcement will only benefit those in power, whether that power is held by government
or corporations. In the case of the United States Senate, the ​Federalist argued​ that the
entity that would write those regulations is largely unqualified to do so. The Federalist isn’t
alone in their criticism. Publications of all political and social stripes roundly criticized
lawmakers for their arrogantly clueless attempts to shame and attack Mark Zuckerberg.

While there may be reasonable concern about abuse of social media, there’s also
reasonable concern that too much regulation could prevent important conversations about
topics such abortion, ​online education​ and reforms in traditional schools, foreign policy,
healthcare, immigration, gun control and ​emerging firearms technology​. The creation and
enforcement of these regulations that could have negative impacts on any side of any
issue.

V. ARE THESE THREE LAWS UNCONSTITUTIONAL?

We submit that what the government is doing is no longer regulation but limit what
should be posted online. If the respondents would not be able to follow the rules, subject to
how the government perceives a piece of information is already control of the people’s
freedom of expression and of the press. People are being oppressed of their right to
express and the result is we are not living anymore in democracy. We are in the state of
digital authoritarianism.

We live in an age where information is readily accessible for the general public.
Recent events has made the people resort to other forms of medium aside from traditional
journalism. The internet/social media/social news media have the important role of bringing
information into public discourse. They shed light on essential issues that affect us all, and
ensure transparency across different sectors of society.

Giving penalties or shutting down media companies because of publishing

contents/writings that may cause death or defamation is a violation of the fundamental
rights provided by the Constitution as it tries to terminate dissenting voices and free
speeches. These rights are important as it is for the development of the country’s economy,
for fighting corruption and abuse of power, and for securing its citizens’ human rights.

The excessive regulation will serve to discourage innovation. After all, if existing
social media platforms aren’t serving the public, isn’t the best solution for someone to
disrupt that model? If entrepreneurs are faced with a bunch of regulations limiting their
ability to grow and be profitable, something the current batch of social media founders
didn’t face, why would they bother?

We also know what tight control of social media looks like elsewhere. It isn’t the
most liberty-minded governments in the world that are acting to control social media.
Authoritarian regimes such as China heavily limit what their citizens can see and do online.

The laws clearly violate fundamental rights such as freedom of speech, of

expression, or of the press; freedom to access information; right to due process; right
against cruel and degrading punishment as protected by our Constitution. Declaring these
Acts as unconstitutional will not only vindicate the Petitioners, but the entire Filipino
community who that rely heavily to online platforms to be updated and engaged in the
political conversations of this country. In general, the striking of it unconstitutionality is a
true act of our democracy and resuscitates its life to continue in the discourse of free
speech.

WHEREFORE​, Petitioners are praying to this Court that (1) RA 123456 - AN ACT
TO PREVENT DISINFORMATION, SOCIAL CONFLICT, AND HATE LANGUAGE, (2) RA
234567 AN ACT CREATING AND EMPOWERING THE SOCIAL MEDIA REGISTRATION
AND REGULATORY BOARD, and (3) RA 345678 – AN ACT TO REGULATE THE USE OF
SOCIAL MEDIA PLATFORMS AND THE INTERNET be declared ​UNCONSTITUTIONAL
and the other declaratory relief be afforded to them that the laws of this land may grant
them.