13th NELSON MANDELA WORLD HUMAN RIGHTS MOOT COURT COMPETITION

GENEVA, SWITZERLAND (12-16 JULY 2021)

IN THE INTERNATIONAL COURT OF JUSTICE

AT THE PEACE PALACE
THE HAGUE, NETHERLANDS

______________________________________________________________________________

IN THE MATTER OF
PAPA TOMMY TOMATO & 43 OTHERS
(APPLICANT)

AND

THE REPUBLIC OF RHAKATAH

(RESPONDENT)

______________________________________________________________________________

MEMORIAL FOR APPLICANT

______________________________________________________________________________

RIZAL MEMORIAL COLLEGES, INC.

School of Law
 THE CASE CONCERNING ADMINISTRATIVE JUSTICE
FOR HUMAN RIGHTS VIOLATION

I. STATEMENT OF JURISDICTION
II. QUESTIONS PRESENTED TO THE COURT
III. STATEMENT OF THE FACT
IV. SUMMARY OF THE PLEADINGS
V. PLEADINGS
VI. PRAYER FOR RELIEF
VII. INDEX OF AUTHORITIES

I. STATEMENT OF JURISDICTION

The applicant and respondent have agreed to submit the Case Concerning question for the
application of administrative justice for human rights violation to ICJ pursuant to Art.36(1) of the
Statute of the ICJ which states that, “The jurisdiction of the Court comprises all cases which the
parties refer to it and all matters specially provided for in the Charter of the United Nations or in
treaties and conventions in force”. The jurisdiction of the Court has not been qualified or contested.
There is no dispute as to the jurisdiction of the Court.

II. QUESTIONS PRESENTED TO COURT

Applicant asks the Court:

I. Whether or not the recalling of Democratic Angels of Faith Alliance’s Members of

Parliament violates the Kanthiyeyu Charter on Human Rights and other relevant human
rights treaties?
II. Whether or not the deletion of tweets from @papatommytomato and @SiyaInRhakatah,
and the ban of Papa Tommy Tomato from Twitter by the Rhakatah Government violate the
Kanthiyeyu Charter on Human Rights and other relevant human rights treaties?
III. Whether or not the lockdown measures of 13 February 2020 and 15 July 2020 violate the
Kanthiyeyu Charter on Human Rights and other relevant human rights treaties?

Team members: Abellana, Michelle Rose C., Ampatuan, Mustapha Simeon E., Jayson, Sardony V.,
Lagnayo, Ryan M., Manacio, Mialyn C., Millado, Nathaniel S., Neri, Milyn E., and Sescon, Ronan Alvin
E.
 III. STATEMENT OF THE FACTS

1. The Republic of Rhakatah is a developing coastal state on the Continent of Kanthiyeyu

(pronounced can’t-hear-you). Rhakatah gained its independence from Siya-something in
1979 with a population of about 6 million people. Siya-something is a developed state.
Both Rhakatah and Siya-something are members of the United Nations (UN). Rhakatah is
a member of the Union of Kanthiyeyu (UK) whose functions are similar to those of the
European Union. UK’s human rights system consists of the Kanthiyeyu Charter on Human
Rights (KCHR), the Commission of Kanthiyeyu (CK) and the Kanthiyeyu Human Rights
Tribunal (KHRT). The rights provided for in KCHR are similar in substance to those
provided for in the International Covenant on Civil and Political Rights (ICCPR) and the
International Covenant on Economic, Social and Cultural Rights (ICESCR). KHRT has
jurisdiction to decide complaints that allege violations of KCHR and any other relevant
human rights treaties ratified by the state concerned. KHRT rules on legal standing and
admissibility of claims are similar to those of the European Court of Human Rights.

2. Rhakatah accepted the jurisdiction of KHRT in 1992 and has ratified KCHR and all the
UN human rights treaties. The Constitution of Rhakatah’s Bill of Rights is similar in
substance to the ICCPR and ICESCR. Rhakatah has Magistrates’ Courts, High Courts and
a Supreme Court. The Magistrates’ Courts are the lowest courts and the Supreme Court is
the highest court of appeal on all issues other than constitutional matters. The
Constitutional Court of Rhakatah has jurisdiction over human rights matters. It may be
approached directly “in cases of urgency or exceptional importance”. When a party raises
a human rights-related matter before the Magistrates’ Courts, High Courts or the Supreme
Court, the relevant court has a discretion to refer the matter to the Constitutional Court if
the court considers it to be “a human rights matter that is likely to affect the outcome of the
matter”. On 13 November 2019, the Government of Rhakatah passed the Rhakatah Cyber
Security and Data Protection Act (CSDP Act) addressing increased challenges of cyber
security and protection of data of citizens. The CSDP Act provides that a Magistrates’ and
High Court of Rhakatah may be designated to act as a Court for Cyber Security and Data
Protection (Cyber Court).

3. The Rhakatah Liberation Front (RLF) has been in power since 1979. In all the successive
elections since 1979, RLF faced little opposition until the formation of the Democratic
Angels of Faith (DAF) in 2009 under the leadership of the charismatic prophet, Papa
Tommy Tomato, the founder of Tomato Faith Ministries. Members of Tomato Faith
Ministries do not tolerate anyone who criticises their Papa and, on many occasions, they

Team members: Abellana, Michelle Rose C., Ampatuan, Mustapha Simeon E., Jayson, Sardony V.,
Lagnayo, Ryan M., Manacio, Mialyn C., Millado, Nathaniel S., Neri, Milyn E., and Sescon, Ronan Alvin
E.
 have resorted to violence to promote their cause. On a regular basis, there are violent and
fatal clashes between Papa Tommy Tomato’s followers and those of other beliefs.

4. Tommy Tomato, or simply “Papa” as he is affectionately called by his followers, is among

the richest people on the Continent of Kanthiyeyu. He is the Founder of Hello-Jah, one of
the biggest telecommunication networks company on the Continent of Kanthiyeyu. It is
amongst the world companies that are in the 5G race and other emerging AI technologies.

5. Some women who are members of TFM live under life-time vows of chastity and are
known as Tomato Sisters. As a co-founder of DAF, Sister Betina is a famous Tomato
Sister. She also played a critical role in the drafting of the DAF Constitution. Section 2 of
DAF Constitution, known as the “relay leadership clause”, provides as follows: “In line
with the national presidential term limit, all DAF presidents shall lead the party for two
terms only. Subject to their availability and unless disqualified under this Constitution or
national laws, DAF shall contest in the 2010 and 2015 national elections under the
presidency of Tommy Tomato and in the 2020 and 2025 national elections under the
presidency of Sister Betina.”

6. While Rhakatah and Siya-something have maintained diplomatic and consular relations
since 1980, politicians from the ruling party, RLF, constantly accuse Siya-something of
“neo-colonialism and of having an imperialist agenda geared towards subverting the
revolutionary gains of Rhakatah.” Siya-something maintains sanctions on a number of RLF
politicians for alleged human rights violations. Nevertheless, Siya-something companies
continuously invest in Rhakatah, particularly in areas of emerging technologies. Recently,
following an unprecedented hike in cases of online hate and harmful speech in the form of
Sinophobia, racial slurs, misogyny, xenophobia and incitement to hatred against religious
minorities that worsened with the outbreak of the Covid-19 pandemic and many people
spending their time online, SiyaTech Cloud, a Siya-something artificial intelligence (AI)
Company, sold the Government of Rhakatah an algorithm that is designed to automatically
detect and delete certain hate speech online. While many people have raised concerns about
violations of freedom of expression through such an algorithm, Rhakatah scientists have
moreover also criticised the algorithm as a tool that was developed and trained using data
sets that are more specific to the context of Siya-something than that of Rhakatah.

7. In the 2010 and 2015 national elections, DAF won a parliamentary majority although it
lost the national presidency to RLF. This has made it difficult for Mr Bosha, President of
Rhakatah and leader of RLF, who has resorted to rule by decree, passing presidential
statutory instruments instead of waiting for Acts of Parliament. One of the Bosha
Government’s initiatives that has been resisted by DAF parliamentarians is the adoption
Team members: Abellana, Michelle Rose C., Ampatuan, Mustapha Simeon E., Jayson, Sardony V.,
Lagnayo, Ryan M., Manacio, Mialyn C., Millado, Nathaniel S., Neri, Milyn E., and Sescon, Ronan Alvin
E.
 and use of mass surveillance AI monitoring technologies from SiyaTech Cloud. On many
occasions, Bosha has referred to his Government’s lack of majority in the Rhakatah
Parliament as “a pebble in the shoe that makes him wish to walk barefoot”.

8. In March 2019, there was a huge political fall-out between Sister Betina and Papa after the
latter insisted that DAF should hold a plebiscite to decide, through votes of DAF members,
whether he should continue as the presidential candidate of DAF in the 2020 national
elections regardless of Section 2 of the DAF Constitution. Sister Betina, on the other hand,
argued that there was no need for such a plebiscite since the DAF Constitution is clear on
the matter. Papa went ahead to hold a plebiscite which resoundingly decided in his favour.

9. In October 2019, Sister Betina approached the High Court of Rhakatah with a case against
Papa (Sister Betina v Papa & DAF) in which she asked the High Court for an order
compelling Papa and DAF to recognise her as the legitimate leader of DAF as provided for
in DAF Constitution. While the case was still pending at the High Court, Sister Betina
registered for the 2020 elections in terms of the Rhakatah Electoral Act (REA) and the
procedures of Rhakatah Electoral Commission (REC). Her party was identified as DAF-B,
the “B” standing for Betina. REC is provided for in terms of the Rhakatah Constitution and
is a nominally independent Commission which controls elections at all levels of Rhakatah
politics.

10. DAF’s criticism of the RLF Government has intensified since 13 February 2020 when
President Bosha announced lockdown measures and policies following cases of Covid-19
in Rhakatah. In the morning of 12 February 2020, Rhakatah recorded its first case of Covid-
19. By the evening of the same day, 11 more cases had been recorded in Chi-Town, the
capital city of Rhakatah. In the evening of 13 February 2020, President Bosha appeared on
Rhakatah National Television (RNT) and announced as follows:

My fellow Rhakatians, it is a sad moment to announce that 12 cases of Coronavirus

infections have been recorded in our beloved nation. Our country is now confronted
with a severe threat that demands an extraordinary response and much sacrifice.
We have seen how the coronavirus pandemic has taken a heavy toll on our
neighbours. We do not have to wait for fatalities to do the right thing. As such, the
following measures have been put into place from 14 February 2020:

• All non-essential travel is banned.

• Any gathering of more than 20 people is prohibited.
• All political gatherings and in-person political campaigns for the 2020
elections are hereby suspended.

Team members: Abellana, Michelle Rose C., Ampatuan, Mustapha Simeon E., Jayson, Sardony V.,
Lagnayo, Ryan M., Manacio, Mialyn C., Millado, Nathaniel S., Neri, Milyn E., and Sescon, Ronan Alvin
E.
 • Opening of accommodation, hospitality venues, churches, restaurants, bars,
taverns and tours is prohibited.
• Family and social visits are banned.
• Social distancing, wearing Covid-19-approved-face-masks and good
hygiene must be observed.

11. These lockdown measures were greeted with different reactions by the citizens of
Rhakatah. While some applauded them as legitimate measures for public health, others
condemned them as “disproportionate measures on a day when people are supposed to go
out to celebrate love”. Sister Betina was one of the politicians who commended the
measures as something good for the nation as a whole. Her political rival, Papa, commented
as follows:

12. In the early morning of the Valentine’s Day, while many prepared and adjusted to celebrate
their love in their homes, twar – “twitter war” – between Sister Betina and Papa continued.
In one of her tweets, Sister Betina noted as follows:

Team members: Abellana, Michelle Rose C., Ampatuan, Mustapha Simeon E., Jayson, Sardony V.,
Lagnayo, Ryan M., Manacio, Mialyn C., Millado, Nathaniel S., Neri, Milyn E., and Sescon, Ronan Alvin
E.
 13. Papa responded within six minutes. His response was something that would convert twar
into “lawfare” before the courts of Rhakatah. He responded as follows:

14. The above tweet was neither flagged nor deleted by Rhakatah’s AI that detects and deletes
various forms of online hate speech. Nevertheless, after Sister Betina replied on 14
February 2020 that “The tweets by @Papatommytomato are dangerous misogyny and also
contravene the 18 commitments on #Faith4Rights!” and tagged Rhakatah’s Ministry of
Information, the latter took Papa to the relevant High Court sitting as Cyber Court, alleging
violations of Sections 13 of CSDP Act. Section 13 provides that “any person who
Team members: Abellana, Michelle Rose C., Ampatuan, Mustapha Simeon E., Jayson, Sardony V.,
Lagnayo, Ryan M., Manacio, Mialyn C., Millado, Nathaniel S., Neri, Milyn E., and Sescon, Ronan Alvin
E.
 unlawfully and intentionally through a computer, digital platform or information system
uses language that incites to hatred or tends to lower the reputation or feelings of persons
for the reason that they belong to a group of persons distinguished on the grounds set out
in Section 75(5) of the Rhakatah Constitution or any other grounds whatsoever shall be
guilty of an offence”. Section 75(5) of the Rhakatah Constitution provides that “every
person has the right not to be treated unfairly in a discriminatory manner on such grounds
as their nationality, race, colour, tribe, place of birth, ethnic or social origin, language,
class, religion or belief, political affiliation, opinion, custom, culture, sex, gender, marital
status, age, pregnancy, disability or economic or social status, or birth”. In terms of Section
39 of CSDP Act, the Cyber Courts are empowered to sanction the deletion of tweets,
suspension of Twitter handles and ban offenders from using Twitter or other digital
platforms for a specified period of time.

15. The Cyber Court found Papa’s tweets to be in violation of Section 13 of CSDP Act. The
Court ordered the deletion of Papa’s offending tweets and imposed a one-year ban on him
from Twitter, Instagram and Facebook. Following the ruling and outside the court house,
a journalist asked Papa how he felt about the ruling to which he responded: “I do not
understand how those judges arrogated to themselves the right to attach secondary
meanings to emojis and what I mean when I use certain emojis. I feel violated, not only as
a political and spiritual leader but also as a human being. My rights have been violated.
But since the Court only banned me on Twitter, Instagram and Facebook, I have created a
TikTok account.”

16. Between 14 February 2020 and 29 April 2020, President Bosha and the First Lady were
seen on various occasions distributing food packages to hundreds of people – including
those in DAF strongholds – while encouraging them to vote for RLF. Responding to many
political players who complained about this, President Bosha responded: “You have to
understand that my obligations as the leader of this country are not the same as yours. I am
alive to the fact that the lockdown measures have adversely affected our people and they
face starvation. We are risking our own lives to make sure that everyone, including your
own supporters, are cushioned during these difficult times. An appreciation of our efforts
will go a long way. We need not politick every good deed.”

17. On 26 February 2020, Siya-Pharm Inc., a Siya-something pharmaceutical company,

announced that it had made a breakthrough and found a Covid-19 vaccine which it named
Muto. Siya-something’s Department of Health approved Muto attesting that it is effective
and safe. Nevertheless, tabloids in Siya-something criticised the move noting that the Muto
was approved while still under a phase I trial, having been used only on 94 people and
without published results. The tabloids relied on an open letter that was written by some
scientists in the region noting that Siya-Pharm Inc. had used some “questionable” data in
Team members: Abellana, Michelle Rose C., Ampatuan, Mustapha Simeon E., Jayson, Sardony V.,
Lagnayo, Ryan M., Manacio, Mialyn C., Millado, Nathaniel S., Neri, Milyn E., and Sescon, Ronan Alvin
E.
 its clinical trials. When reached for comment, an unnamed scientist from Siya-Pharm Inc.
said that phase IV of Muto will be done outside Siya-something and the company had its
eyes on the Continent of Kanthiyeyu.

18. Meanwhile, the faction of DAF led by Papa coalesced with other opposition political
parties and called itself the DAF-Alliance. The DAF Alliance Agreement provides that
parties have the option of leaving or remaining part of the Alliance after the 2020 national
election. The DAF-Alliance was recognised as a political party by REC for purposes of the
2020 national elections. Nevertheless, because DAF-B used the original logo of DAF,
DAF-Alliance was asked to choose another logo, with which it complied. Since the DAF
faction led by Papa was the biggest in the DAF-Alliance, there was agreement in terms of
the DAF Alliance Agreement that the DAF faction led by Papa should provide 80% of the
candidates to contest in the parliamentary elections and that Papa should be the leader of
DAF Alliance. These candidates were chosen through an internal election. The national
elections were scheduled for 30 April 2020 and lockdown measures were relaxed to allow
millions to vote. A system of postal voters was also put in place. Since the first Covid-19
infection cases in February 2020, infection rates have remained steady and very low in
March, April and May. Medical and pandemic management experts have attributed this
feat to president Bosha’s comprehensive lockdown measures.

19. Notwithstanding the ban on Twitter and the inability to hold in-person public campaigns
as per the 13 February lockdown measures, Papa’s DAF Alliance won 68% of
parliamentary seats in the national elections that were held on 30 April 2020. Papa narrowly
lost the presidential election, getting 3 607 514 votes while President Bosha got 3 700 260
votes. Papa claimed that Bosha rigged the presidential election. Sister Betina received 36
928 votes in the presidential election and DAF-B won 3 parliamentary seats – less than 2
percent of the total votes. In a bid to facilitate peace in Rhakatah, Bosha invited all political
parties for a political dialogue that was scheduled for 2 June 2020. Papa called Bosha’s
initiative an attempt to pacify real opposition and create a one-party state. On 2 June 2020,
the day that the leaders of opposition political parties met with Bosha, Papa did not attend.
He chose, instead, to meet with the Ambassador of Siya-something, Ms. Ally Gator, who
has become his close friend in recent years. There are rumours that Papa and the
Ambassador of Siya-something are in a romantic relationship. Some local newspapers and
RNT carried a story that Bosha was thoroughly dismayed and felt disrespected by Papa’s
snub of his proposed political dialogue and vowed to decimate the DAF-Alliance. When
asked how he planned to do that, President Bosha replied: “We must be respected. We are
the ruling party. We are the Government. We are the police. We are the army. We are the
intelligence officers. We are the courts. We are the law. We are everything you can think
of.”

Team members: Abellana, Michelle Rose C., Ampatuan, Mustapha Simeon E., Jayson, Sardony V.,
Lagnayo, Ryan M., Manacio, Mialyn C., Millado, Nathaniel S., Neri, Milyn E., and Sescon, Ronan Alvin
E.
 20. On 10 June 2020, the High Court of Rhakatah delivered its judgment in the case of Sister
Betina v Papa & DAF. It held that Papa and the leadership of DAF had violated DAF
Constitution by holding a plebiscite to extend the presidency of Papa. It further held that
the rightful leader of DAF is Sister Betina, and ordered Papa to vacate the headquarters of
DAF and surrender assets of DAF to Sister Betina. The High Court emphasised that
political parties play a fundamental role in strengthening constitutionalism at the national
level and as such must respect their own constitutions as charity begins at home. The High
Court judgment was strongly criticised by local legal experts and political commentators
who argued that the judge failed to take judicial notice of the political reality of the case.
On 12 June 2020, the DAF Alliance appealed to the Supreme Court of Rhakatah.

21. On 13 June, Hello-Jah announced its breakthrough on one of its projects on 5G holographic
augmented reality. To showcase the product, Hello-Jah created a 5G holographic
augmented reality of Papa dancing all evening on top of Chi-Town City Council Buildings.
While dancing, he sang:
“If you believe in the virus-corona
I crown you the moron-ah
Come get your corona (crown)”
While some drones projected the show, some recorded it. Papa posted the recorded video
on his TikTok account and it immediately went viral under the hashtag
#FakeCovidDanceChallenge. Thousands of people participated in the
#FakeCovidDanceChallenge. On 14 June 2020, TikTok deleted Papa’s
#FakeCovidDanceChallenge as part of its rules against misinformation on Covid-19. The
video was, however, reposted by the Embassy of Siya-something in Rhakatah
(@SiyaInRhakatah) on Twitter with the comment: “We disagree with this but we should
all be free to express ourselves. In any event, this video entertained many in this lockdown.”

22. Meanwhile, on 15 June 2020, the Government of Rhakatah, reasoning that Sister Betina
was the legally recognised and legitimate leader of DAF, allocated funds to Sister Betina’s
DAF faction, funds that are disbursed in terms of the Rhakatah Political Finances Act
(APFA). In terms of Section 4 of APFA on state financing of political parties, political
parties whose candidates received at least five percent of the total number of votes cast in
the most recent national election are entitled to the same proportion of the total monies
allocated to qualifying political parties in terms of the APFA.

23. On 14 July, there was an uproar in Rhakatah following the tweets below from Bosha’s
Presidential Spokesperson, Mr Cayman Lacoste who tweets from @Woolishcroco and
from the Permanent Secretary in the Rhakatah Ministry of Information, Mr Mick Bafana,
Team members: Abellana, Michelle Rose C., Ampatuan, Mustapha Simeon E., Jayson, Sardony V.,
Lagnayo, Ryan M., Manacio, Mialyn C., Millado, Nathaniel S., Neri, Milyn E., and Sescon, Ronan Alvin
E.
 who tweets from @TheBigRat. Regional and international inter-governmental
organisations to which Rhakatah is a party were concerned about the tweets and contacted
Rhakatah Government seeking clarifications. The Ministry of Information held a press
conference that was aired live on RNT and emphasised that the issue was an internal matter
which the Government was looking into, “to get to the bottom of what transpired regarding
the tweets”. The tweets in question read as follows:

24. In the morning of 15 July 2020, the Supreme Court of Rhakatah dismissed with costs,
Papa’s appeal in Papa & DAF v Sister Betina. In the afternoon of 15 July 2020, President
Bosha officially recognised Sister Betina as the Leader of Opposition in Rhakatah
Parliament, a role that is provided for in the Constitution of Rhakatah. In the evening of 15
July 2020 and on the basis of the Supreme Court decision in Papa & DAF v Sister Betina,
Sister Betina, invoking Section 75 of Rhakatah Constitution and Section 44 of Rhakatah
Electoral Act (REA), recalled 43 DAF Parliamentarians who were elected under the ticket
of the DAF Alliance and had publicly announced their allegiance to Papa.

Team members: Abellana, Michelle Rose C., Ampatuan, Mustapha Simeon E., Jayson, Sardony V.,
Lagnayo, Ryan M., Manacio, Mialyn C., Millado, Nathaniel S., Neri, Milyn E., and Sescon, Ronan Alvin
E.
 25. Section 75 of Rhakatah Constitution provides for the tenure of Seat of Member of
Parliament. In Section 75(3), it provides that “the seat of a Member of Parliament becomes
vacant if the Member has ceased to belong to the political party of which he or she was a
member when elected to Parliament and the political party concerned, by written notice to
the Speaker or the President of the Senate, as the case may be, has declared that the Member
has ceased to belong to it.” When the 43 named DAF-Alliance Parliamentarians heard that
Sister Betina had submitted a notice in terms of Section 75, they approached the High
Court, seeking an injunction against Sister Betina whom they claimed had no authority to
recall them.

26. While the High Court was still to make its determination in regard to the recalls, REC
announced in Rhakatah Gazette that vacancies had arisen in Parliament in terms of Section
44(5) of REA, which provides as follows: “In the event of a vacancy occurring in terms of
Section 75 of the Rhakatah Constitution, the President of the Senate or the Speaker, as the
case may be, shall notify Rhakatah Electoral Commission (REC) of the vacancy, in writing,
as soon as possible after he or she becomes aware of it. Upon being notified of a vacancy,
REC shall, without delay, notify the public of the vacancy by notice in the Rhakatah
Gazette and invite the political party in writing to submit the name of a qualified person to
fill the vacancy, for which purpose the political party must lodge with REC a nomination
paper that is countersigned by any two of the designated national office-bearers of the
political party.” Sister Betina submitted a list of replacements drawn from politicians from
DAF-B faction. She also included her own name. Following the parliamentary recalls,
various supporters of DAF Alliance and voters sought to demonstrate against what they
perceived as a clamp down on their fundamental human rights but were arrested for
violating lockdown measures.

27. Late in the evening of 15 July 2020 and following the Ministry of Health’s report of 2717
new cases of Covid-19, a hike from the 722 cases that had been recorded since February
2020, President Bosha made another national address and stated as follows:

Fellow Rhakatians, once again, I come back to you in these difficult times of covid-
19. I am aware that since the announcement of the first lockdown measures, we
managed, until recently, to keep infection rates very low. This was not an easy feat
and I am aware that this has been very difficult for all of us. Now we are confronted
with a terrible increase in the number of infections. We are, indeed, faced with
difficult choices. The choice between the right to freedom of movement and the
right to privacy; the choice between the right to freedom of association and the right
to health; the choice between the right to freedom of speech and irresponsible
information sharing that affect the right to health; the choice between the right to
privacy and the right to health. But I can assure you, the right to health is

Team members: Abellana, Michelle Rose C., Ampatuan, Mustapha Simeon E., Jayson, Sardony V.,
Lagnayo, Ryan M., Manacio, Mialyn C., Millado, Nathaniel S., Neri, Milyn E., and Sescon, Ronan Alvin
E.
 intrinsically linked to the right to life. We are only able to exercise all these other
rights because we are alive. It is, therefore, a necessary evil. A necessary sacrifice.
Yes, we may have the lowest infections at the moment but we have seen a number
of people who are not respecting the lockdown measures and it is difficult to
monitor such people or track those they may have potentially infected. The slightest
lapse in our alertness or efforts can lead to catastrophic fatalities. Don’t listen to
DAFT PROPHETS and their fake news campaign against vaccination! We have all
seen what have been happening in neighbouring countries because they failed to
see that sometimes what may be seen as evil is for the greater good. The
Government of Rhakatah has procured essential technologies from SiyaTech Cloud
and a vaccine from Siya-Pharm Inc. that will make a difference in the fight against
the deadly virus. Through SI/15/07/2020, I am announcing the following new and
additional measures:

• The installation of mass surveillance and facial recognition technology

across Rhakatah to enable the Government to monitor people, identify and
punish those who break lockdown rules.
• The use of AI algorithms to monitor people’s smart-phones for purposes of
checking people’s body temperature, medical condition, identifying
suspected coronavirus carriers, and tracking their movements and those they
may have infected.
• In the interest of public health, there will be compulsory mutowenyemba
vaccination.
• Hello-Jah’s 5G license is hereby suspended pending conclusions on corona-
related investigations.
• We are aware that these measures will anger some politicians whose
supporters are known for violence and have already exhibited their violent
intentions to spread covid-19. As such, all political assemblies are hereby
prohibited for the next three months.
• Rhakatah soldiers are henceforth deployed to help Rhakatah Police in
enforcing lockdown measures and helping with compulsory vaccinations.

28. Following these developments, there were various online protests from different
stakeholders in Rhakatah, from citizens and human rights non-governmental organisations.
On 16 July 2020, the Embassy of Siya-something in Rhakatah which was closely following
the developments also tweeted as follows:

Team members: Abellana, Michelle Rose C., Ampatuan, Mustapha Simeon E., Jayson, Sardony V.,
Lagnayo, Ryan M., Manacio, Mialyn C., Millado, Nathaniel S., Neri, Milyn E., and Sescon, Ronan Alvin
E.
 29. Thirteen minutes after the tweet from the Embassy of Siya-something, the Government of
Rhakatah responded through the Ministry of Information. It noted as follows:

30. A week later, on 23 July 2020, to celebrate the 22nd anniversary of Tomato Faith Ministries
and address various instances of police brutality in enforcement of lockdown measures,
Papa went to Tomato Faith Ministries in Chi-Town to make a virtual address. The event
was livestreamed on Twitter through @SiyaInRhakatah Twitter handle. In his opening
address, Papa said:
We have always maintained that covid-19 is a political and capitalist excuse to
exploit the vulnerable of this earth. For a long time, DAF has resisted these AI
technologies that are unnecessarily intrusive and violate our people’s fundamental
rights. Now, Bosha’s Government, knowing that it does not have a parliamentary
majority, is now using covid-19 as an excuse to normalise the deployment of mass

Team members: Abellana, Michelle Rose C., Ampatuan, Mustapha Simeon E., Jayson, Sardony V.,
Lagnayo, Ryan M., Manacio, Mialyn C., Millado, Nathaniel S., Neri, Milyn E., and Sescon, Ronan Alvin
E.
 surveillance technologies that the people have rejected for a long time. As a man of
faith, the hidden has been revealed to me by the sacred spirits: Covid-19 is the work
of the devil; the devil is using capitalist governments of this world who engineered
and orchestrated this fake pandemic in order to suck us dry. Even if one was to get
sick, one can take hydroxychloroquine. Medical research by our esteemed medical
doctors has shown that if you take hydroxychloroquine, you will totally be fine.
There is no need to hide in your houses like rats afraid of cats or vampires afraid of
the sunlight. Yet, Bosha’s Government refuses to listen to us; it prefers to continue
pandering fear. Medical evidence which it presents on covid-19 is neither
unanimous nor conclusive. Yet, Bosha’s Government unjustifiably prefers one
medical evidence to another. Medical research that does not support their narrative
of fear is demonised and branded as fake news. To this Government and its cabals,
fear is profit. We hear that Bosha’s wife has shares in SiyaTech Cloud. Bosha’s two
daughters have shares in Siya-pharm Inc. He has not denied it. It is corruption that
stinks to the highest level, risking our health. All these measures that are being
taken are not only disproportionate but unnecessary. Why should I be forced to
wear a mask? If you think a mask works, then good for you, it means I won’t be
able to infect you if I have the fake virus, so why do you worry about whether or
not I am wearing a mask myself? It is my choice. If you insist that muto works and
prevents infections, why should you be worried about me not getting the
vaccination? If it simply means you can’t be infected if you get a muto shot, surely,
you shouldn’t be bothered by those who don’t get it. We must refuse to be anyone’s
guinea pigs! This is a watershed moment that if we do not resist these intrusions,
they will forever alter – if not destroy – the human rights project as we know it
today. It is the poor who continue to be hit hard by these lockdown measures; losing
their jobs, their trade and failing to feed their families, their health compromised
while dictatorial governments like that of Bosha are taking it as an opportunity to
invade our rights en-masse. I say let us end this now. Go out there and live your
life. We only live once after all.

31. As he continued his address, over 500 people streaked to Tomato Faith Ministries – the
majority of them not wearing masks – and started cheering Papa. Many were met with the
brutal force of Rhakatah Police and Army. Armed with a search warrant, special squads of
Rhakatah Police were immediately dispatched to Tomato Faith Ministries where, upon
arrival, they seized an iPad device from which the event was being livestreamed. During
the livestream, the iPad was pitched on a stand. As the police seized it, the Ambassador of
Siya-something who was attending the event protested that the iPad was hers and thus
covered under diplomatic privileges and immunities. Citing violations of lockdown rules
and Article 7 of CSDP Act, the Police stopped the livestreaming and deleted all the videos
and press-statements of Papa that were posted on @SiyaInRhakatah’s timeline. Article 7
of CSDP Act provides that “any person who unlawfully and intentionally through a
computer, digital platform or information system misinform or disinform the public in a
Team members: Abellana, Michelle Rose C., Ampatuan, Mustapha Simeon E., Jayson, Sardony V.,
Lagnayo, Ryan M., Manacio, Mialyn C., Millado, Nathaniel S., Neri, Milyn E., and Sescon, Ronan Alvin
E.
 manner that menace public health, public order and national security shall be guilty of an
offence”. The videos that were deleted concerned Papa’s consistent views on the Covid-19
pandemic. The Police also used the AI algorithms to track through their smart-phones the
movement of 834 people, mostly supporters of DAF Alliance, in order to identify those
who were close to Tomato Faith Ministries on 23 July 2020 and charged them with
violating the measures under SI/15/07/2020. During the first appearance of the 843 accused
persons before the Magistrates’ Court, a week later, their lawyers requested that the
constitutionality of the lockdown measures be referred to the Constitutional Court. The
Magistrate declined the request on the basis that “no court is likely to find the measures to
be unjustified”.

32. The incident at Tomato Faith Ministries resulted in a diplomatic fall out between Siya-
something and Rhakatah who are now before the International Court of Justice to
adjudicate the dispute. Papa approached the Constitutional Court of Rhakatah arguing that
the Police actions on 23 July 2020 violated his right to administrative justice. The
Constitutional Court ruled in favour of the State noting that public health takes precedence
in the matter. Meanwhile, two weeks after the incident of 23 July 2020, Rhakatah’s
Ministry of Health reported a shocking 4 420 new cases of Covid-19 infections.

33. On 16 November 2020, Papa and 43 recalled Parliamentarians approached the Kanthiyeyu
Human Rights Tribunal alleging the following:

a. The recalling of Democratic Angels of Faith Alliance’s Members of Parliament

does violate the Kanthiyeyu Charter on Human Rights and other relevant human
rights treaties.
b. The deletion of tweets from @papatommytomato and @SiyaInRhakatah, and the
ban of Papa Tommy Tomato from Twitter by the Rhakatah Government violate the
Kanthiyeyu Charter on Human Rights and other relevant human rights treaties.
c. The lockdown measures of 13 February 2020 and 15 July 2020 violate the
Kanthiyeyu Charter on Human Rights and other relevant human rights treaties.

IV. SUMMARY OF PLEADINGS

I. The recalling of the Democratic Angels of Faith Alliance’s Members of Parliament is

violative of the rights concerning Human Rights law and other Human Rights treaties
particularly those relating to the right to take part in the government of one’s country,
directly or through freely chosen representatives. Everyone has the right of equal access
to public service in his country. This right is enshrined in no less than the Universal
Declaration of Human Rights.
Team members: Abellana, Michelle Rose C., Ampatuan, Mustapha Simeon E., Jayson, Sardony V.,
Lagnayo, Ryan M., Manacio, Mialyn C., Millado, Nathaniel S., Neri, Milyn E., and Sescon, Ronan Alvin
E.
 II. The deletion of tweets from @papatommytomato and @SiyaInRhakatah, and the ban
of Papa Tommy Tomato from Twitter by the Rhakatah Government violates the
Kanthiyeyu Charter on Human Rights and other relevant human rights treaties.
III. The lockdown measures of 13 February 2020 and 15 July 2020 does not violate the
Kanthiyeyu Charter on Human Rights and other relevant human rights treaties.

V. PLEADINGS

I. Papa Tomato and the Forty-Three others request the Court to declare that,
notwithstanding the Decision of the Supreme Court of Rhakatah to dismiss Papa’s
appeal in Papa &DAF v. Sister Betina, the crux of the matter at hand is essentially that
of a violation of the Kanthiyeyu Charter on Human Rights and other relevant human
rights treaties, which not only make said violation outside the jurisdictional purview of
the Supreme Court of Rakatah, but also takes precedence over Constitutional Laws and
issues such as the prohibition by the Constitution of the DAF against the holding of a
plebiscite to extend the term of one sitting President.

Recall paragraphs 1, 2, and 3 of Section 21 of the Universal Declaration of Human

Rights, to wit:
i. Everyone has the right to take part in the government of his country, directly
or through freely chosen representatives.
ii. Everyone has the right to equal access to public service in his country.
iii. The will of the people shall be the basis of the authority of government; this
will shall be expressed in periodic and genuine elections which shall be by
universal and equal suffrage and shall be held by secret vote or by
equivalent free voting procedures.

Apparent are the aforementioned provisions in holding the will of the people to be
the basis of authority of government. The electing of representatives by the people
is an extension of their will imposed and a proper practice of their fundamental
right to self-governance.

Furthermore, the recall of the 43 Parliamentarians was only made operative by

virtue of Section 75 of Rhakatah Constitution, which was discussed under Fact
Slide #25 in that, “the seat of a Member of Parliament becomes vacant if the
Member has ceased to belong to the political party of which he or she was a member
when elected to Parliament and the political party concerned, by written notice to
the Speaker or the President of the Senate, as the case may be, has declared that the
Member has ceased to belong to it.”

Team members: Abellana, Michelle Rose C., Ampatuan, Mustapha Simeon E., Jayson, Sardony V.,
Lagnayo, Ryan M., Manacio, Mialyn C., Millado, Nathaniel S., Neri, Milyn E., and Sescon, Ronan Alvin
E.
 So, in order for Section 75 to operate, a vacancy has to be made first in any one of
the Parliamentary Seats, which is exactly the case here resulting from Sister
Betina’s challenge against Papa Tomato’s term-extension. The same was decided
in her favor by the High Court, followed by the denial of Papa’s appeal in the
Supreme Court. And much like falling dominos, as soon as it was declared that
Papa’s Political Party was no longer valid, the Parliamentary Seats afforded to his
alliances were also rendered vacant.

Thus, it cannot be gainsaid that in recalling the 43 Parliamentarians, the State of

Rhakatah is essentially sanctioning the violation of the people’s right to suffrage
and self-governance. The people have chosen who they wanted to govern them, but
Rakatah was simply not having it, despite the overwhelming preference by the
people (at 68% to be exact) over the now recalled DAF Alliance members. Human
rights take precedence over procedural provisions, and certainly over the less
resilient Constitution of the DAF.

II. The deletion of tweets from @papatommytomato and @SiyaInRhakatah, and the ban
of Papa Tommy Tomato from Twitter by the Rhakatah Government constitute as
violations of the Kanthiyeyu Charter on Human Rights and other relevant human rights
treaties as these acts are essentially geared towards the infringement and the running
afoul of the Fundamental Right to Freedom and Expression.
Applicants submit that the Republic of Rakhata violated their right to freedom of
expression when it ordered the deletion of a number of Tweets and imposed a one-
year ban on Papa Tomato on Twitter, Instagram and Facebook due to his opposite
stand on the lockdown.
Recall Fact Slides # 11, 13, and 14. Readily apparent on its face, the tweets coming
from Papa were merely an exercise of expression and discussion. While the Twitter
exchanges Papa had with Sister Betina were indeed heated, it was to be expected
as free people can hardly blame one another for having different inclinations and
political ideologies. To be able to express freely without the fear of having to be
shut down by forces who do not concede or agree to one’s thoughts is the
quintessential practice of Freedom of Expression and Opinion. Otherwise, the same
right would not have been included in the Universal Declaration of Human Rights.
There is no question that the heated exchange between Papa and Sister Betina which
led to Papa Tomato’s ban on many social media platforms arose from a difference
of political views. Papa Tomato did not agree with the lockdown protocols that the
government of Rakatah had been imposing, which in of itself, is not really a crime.
What prompted the ban was the ruling of the Hight Court sitting as the Cyber Court
in enforcing Section 13 of the CSDP Act, to wit, “any person who unlawfully and
intentionally through a computer, digital platform or information system uses

Team members: Abellana, Michelle Rose C., Ampatuan, Mustapha Simeon E., Jayson, Sardony V.,
Lagnayo, Ryan M., Manacio, Mialyn C., Millado, Nathaniel S., Neri, Milyn E., and Sescon, Ronan Alvin
E.
 language that incites to hatred or tends to lower the reputation or feelings of persons
for the reason that they belong to a group of persons distinguished on the grounds
set out in Section 75(5) of the Rhakatah Constitution or any other grounds
whatsoever shall be guilty of an offence”.
The alleged misogynistic claims by Papa and his tweets against Sister Betina which
led to the ruling of the Cyber Court involved the use of a range of emojis. Emojis
have become indispensable tools in expressing oneself in today’s digital era. They
are the splash of color in black and white communication, conveying things mere
words often cannot. Emojis are used to improve upon, even expand, one’s words
and bring emotion to the conversation. However, emojis cannot be the sole basis
for arrests or convictions. Evidence, arrests, and prosecutions are far more
complicated than that. They can be important evidence for law enforcement, but
only to a certain degree in which they are not derided or ignored.
To serve as a reminder, recall the incident of one Osiris Aristy. On Jan. 15, 2015,
Osiris Aristy opened up Facebook, posted a photo of a gun and wrote, “feel like
katxhin a body right now.” Later that night, he added, “Nigga run up on me, he
gunna get blown down” and followed that with an emoji of a police officer and
three-gun emoji pointing at it. After an hour, he posted another similar message.
Three days later, Aristy, 17, was arrested by New York City police at his home in
Brooklyn. According to a criminal complaint, the teen was charged with making a
terroristic threat, along with charges of weapon and marijuana possession. His
posts, the complaint argued, constituted a threat against police. Basically, Osiris
was arrested based solely on his use of emojis which authorities somehow
perceived as a threat. Note how easily emojis can be taken out of context and
complicate things for the user.
In regards to Papa’s tweets, his use of emojis in them were ruled upon as
contentious and misogynistic, but such cannot entirely be the case, much like that
of Osiris’. While emojis may be used as a form of expression or to clarify a context,
it is really anyone’s guess as to how they are used in any given context. Simply put,
any expression or post that incorporates emojis can have varying meanings
depending on who is reading it. One might take Papa’s tweets as jokes; others might
take them as serious and offensive narratives. As they are, there really is no clear-
cut method of deciphering whether the incorporation of the emojis in Papa’s tweets
were used for nefarious reasons or not. They are simply ambiguous and the Cyber
Court should not have put so much weight on them merely on their face value, lest
they risk dragging others like Papa or Osiris into more degrading faux convictions.
The result on the ruling of Papa’s case in the Cyber Court is essentially an
infringement on his fundamental right to freedom of expression. Recall Article 19
of the International Covenant on Civil and Political Rights:
1. Everyone shall have the right to hold opinions without interference.

Team members: Abellana, Michelle Rose C., Ampatuan, Mustapha Simeon E., Jayson, Sardony V.,
Lagnayo, Ryan M., Manacio, Mialyn C., Millado, Nathaniel S., Neri, Milyn E., and Sescon, Ronan Alvin
E.
 2. Everyone shall have the right to freedom of expression; this right shall
include freedom to seek, receive and impart information and ideas of all
kinds, regardless of frontiers, either orally, in writing or in print, in the form
of art, or through any other media of his choice.
3. The exercise of the rights provided for in paragraph 2 of this article carries
with it special duties and responsibilities. It may therefore be subject to
certain restrictions, but these shall only be such as are provided by law and
are necessary:
a. For respect of the rights or reputations of others;
b. For the protection of national security or of public order (ordre
public), or of public health or morals.
The upholding of the right to freedom of expression should be ingrained in all
democratic societies. It is a precondition to the enjoyment of other fundamental
rights such as the right to vote, free assembly and freedom of association, and is
essential to ensure press freedom. The curtailment of such a rights limits civilized
discussion and interaction accruing to the damage and detriment of any democratic
society. Noteworthy is the case at bench since the curtailment was passed and ruled
in the visage of protecting the right of another—that of Sister Betina’s. However,
the scarcity of validity in ruling that Papa’s tweets were in violation of the
Kanthiyeyu Charter on Human Rights and other relevant human rights treaties
should have proven fatal to the proceedings from the beginning, especially as they
were anchored on pure conjectures.

III. The lockdown protocols initiated by the Republic of Rakatah on the 13 th February 2020
and the 15th July 2020 violate the Kanthiyeyu Charter on Human Rights and other
relevant human rights treaties as they were in the design to undermine the People’s
Right to Protest, Peaceably Assemble, Express Grievances, as well as, their Right to
Privacy relative to the imposition of AI technologies in the Orwellian monitoring of the
constituents of the Republic of Rakatah.
While the lockdown was premised on the prevention of the spread of the COVID-
19 pandemic, there were certain provisions in them that were on their face,
capricious towards some of the most basic human rights. For example, recalling
Fact Slide # 14, under the February 13 lockdown, President Bosha implemented,
among other directives, that “All political gatherings and in-person political
campaigns for the 2020 elections are hereby suspended.” This prohibition, if not to
put a rein on the unprecedented spreading of the COVID-19 outbreak in the country
which was still on the safe-low at that point, served only to control the likes of Papa
Tomato who has continuously been in opposition to the policies of the State, which
is not only violative of the right of the people to Peaceably Assemble, but also to
practice self-governance. This, notwithstanding of course the explicit nemesis type
of relationship between President Bosha and Papa Tomato which stemmed long
Team members: Abellana, Michelle Rose C., Ampatuan, Mustapha Simeon E., Jayson, Sardony V.,
Lagnayo, Ryan M., Manacio, Mialyn C., Millado, Nathaniel S., Neri, Milyn E., and Sescon, Ronan Alvin
E.
 since the beginning of their political run against each other for the Presidential Seat
of the Republic of Ratakah. It can be inferred from the directive in question then
that President Mosha’s intention behind the same may not have been as
humanitarian as he had led his people to believe.
Note further that in Fact Slide # 27, in addition to the protocols put forward during
the initial lockdown, President Bosha announced on the 15th of July that:
1. The installation of mass surveillance and facial recognition technology
across Rhakatah to enable the Government to monitor people, identify and
punish those who break lockdown rules.
2. The use of AI algorithms to monitor people’s smart-phones for purposes of
checking people’s body temperature, medical condition, identifying
suspected coronavirus carriers, and tracking their movements and those they
may have infected.
3. In the interest of public health, there will be compulsory mutowenyemba
vaccination.
4. Hello-Jah’s 5G license is hereby suspended pending conclusions on corona-
related investigations.
5. We are aware that these measures will anger some politicians whose
supporters are known for violence and have already exhibited their violent
intentions to spread covid-19. As such, all political assemblies are hereby
prohibited for the next three months.
6. As such, all political assemblies are hereby prohibited for the next three
months.
Pay attention to the first two additional protocols. It is fairly easy to pass off health
pandemic measures as necessary save for those instances wherein the wanton
disregard of fundamental rights is readily apparent. To enlist the help of technology
in order to be able to monitor, identify, and punish people, even in the comforts of
their own homes is simply ridiculous. It violates the fundamental right to privacy.
Add to that the use of AI algorithms to monitor people even through their mobile
phones. To put this into perspective, it is as if the government has full observational
control over any person, wherever they may be, whatever activities they are
involved in at any given time, even going so far as being able to count a person’s
heartbeat. As George Orwell would have it in his dystopian novella, 1984, “Big
Brother is Watching You.”
Even as the directives above render the very sanctity of one’s own privacy non-
existent, there were other events that had transpired which also point to negligence
by the Republic of Ratakah in enforcing its COVID-19 outbreak protocols.
Specifically, when Papa Tomato addressed his supporters on the 22nd anniversary
of Tomato Faith Ministries which resulted in a brutal police action. The collective
treatment demonstrated by the respondent Republic of Rhakatah showed a

Team members: Abellana, Michelle Rose C., Ampatuan, Mustapha Simeon E., Jayson, Sardony V.,
Lagnayo, Ryan M., Manacio, Mialyn C., Millado, Nathaniel S., Neri, Milyn E., and Sescon, Ronan Alvin
E.
 systematic policy of wanton disregard of the fundamental rights to Free Expression,
Due Process of Law, and the Equal Protection of Laws.
Even the Constitutional Courts failed to nuance properly what had transpired,
sheltering under the seemingly unsympathetic notion of public health taking
precedence over the brutal mishandling of those involved in the gathering, which
was bereft of any violent demonstration from the get-go. In fact, it was wholly
imbued with national patriotism as speaker Papa Tomato espoused for the
protection of the people from neocolonialism, and that there is an ongoing attempt
by the State to take advantage of the people through COVID-19. Papa Tomato’s
harping on the exertion of political and economic interest by the State to control the
rest of the country was not founded on baseless, flimsy grounds so as to regard it
as merely a capricious exercise of Freedom of Expression. The collective act of
Papa Tomato and those involved in the gathering did not warrant state intervention,
no less brutal police action.

VI. PRAYER OF RELIEF

May it therefore please the Court to:

1. Declare that the recalling of the Democratic Angels of Faith Alliance’s Members of
Parliament is violative of the rights concerning Human Rights law and other Human Rights
treaties particularly those relating to the right to take part in the government of one’s
country, directly or through freely chosen representatives.
2. Declare that the deletion of tweets from @papatommytomato and @SiyaInRhakatah,
and the ban of Papa Tommy Tomato from Twitter by the Rhakatah Government constitute
as violations of the Kanthiyeyu Charter on Human Rights and other relevant human rights
treaties as these acts are essentially geared towards the infringement and the running afoul
of the Fundamental Right to Freedom and Expression.
3. The lockdown protocols initiated by the Republic of Rakatah on the 13th February 2020
and the 15th July 2020 violate the Kanthiyeyu Charter on Human Rights and other relevant
human rights treaties as they were in the design to undermine the People’s Right to Protest,
Peaceably Assemble, Express Grievances, as well as, their Right to Privacy relative to the
imposition of AI technologies in the Orwellian monitoring of the constituents of the
Republic of Rakatah.

Team members: Abellana, Michelle Rose C., Ampatuan, Mustapha Simeon E., Jayson, Sardony V.,
Lagnayo, Ryan M., Manacio, Mialyn C., Millado, Nathaniel S., Neri, Milyn E., and Sescon, Ronan Alvin
E.
 VII. INDEX OF AUTHORITIES

• International Covenant on Civil and Political Rights- Adopted and opened for
signature, ratification and accession by General Assembly resolution 2200A (XXI) of 16
December 1966 entry into force 23 March 1976, in accordance with Article 49.
• International Covenant on Economic, Social and Cultural Rights- Adopted and opened
for signature, ratification and accession by General Assembly resolution 2200A (XXI) of
16 December 1966 entry into force 3 January 1976, in accordance with article 27.
• Universal Declaration of Human Rights
• Economic and Social Council- General Comment No. 14 (2000)

Team members: Abellana, Michelle Rose C., Ampatuan, Mustapha Simeon E., Jayson, Sardony V.,
Lagnayo, Ryan M., Manacio, Mialyn C., Millado, Nathaniel S., Neri, Milyn E., and Sescon, Ronan Alvin
E.