44 Dictating the Internet: Before looking at laws and cases from Myanmar, Thailand, Indonesia and Singapore, it is informative to consider the assessment and denunciation by the UN Human Rights Committee of the criminalization of defamation and imposition of imprisonment as punishment for defamation in the Philippines. While the case covered below does not involve communication of information through an online medium, it is relevant for its precedential value. Philippines In the Philippines, defamation is classified as a “crime against honour” under the Revised Penal Code, where article 353 specifically criminalizes the offence of libel and article 355 imposes a maximum penalty of imprisonment of six years for the offence.116 In October 2011, the UN Human Rights Committee determined that provisions under the Revised Penal Code criminalizing defamation were incompatible with Philippines’ obligations under article 19 of the ICCPR. The Committee indicated that the prosecution and imposition of a prison sentence on Alexander Adonis, a radio broadcast journalist, for alleged defamation, constituted a violation of his rights. Adonis had been convicted by the Regional Trial Court of Davao City under articles 353 and 355 of the Revised Penal Code, for reporting in his professional capacity on an alleged relationship between a congressman and a married television personality.117 The court had further ordered that Adonis pay PHP 100,000 (approx. USD 1,935) as “compensation for moral damages” to the congressman and an extra PHP 100,000 as “exemplary damages” to set “an example for notorious display of irresponsible reporting”.118 In its review of Adonis’ case, the Committee also called upon the Philippine government to provide Adonis with effective remedy and adequate compensation for his imprisonment term, and called for the libel law to be reviewed to “prevent similar violations occurring in the future”.119 Committee Members Fabían Salvioli and Rajsoomer Lallah further expressed the view that the Philippines had failed to meet its obligations under article 2(2) of 116 Revised Penal Code of the Philippines, Act No. 3815 (‘Revised Penal Code’), Available at: https:// www.un.org/Depts/los/LEGISLATIONANDTREATIES/PDFFILES/PHL_revised_penal_code.pdf 117 The congressman filed criminal complaints against Adonis and his radio manager, following which charges against the manager were dropped. 118 UN Human Rights Committee, Communication No. 1815/2008, CCPR/C/103/D/1815/2008 (‘CCPR/ C/103/D/1815/2008’), pp. 2 to 3, paras 2.1 to 2.3, , Available at: http://www.bayefsky.com/pdf/ philippines_t5_ccpr_1815_2008_scan.pdf 119 CCPR/C/103/D/1815/2008, paras 9, 10. In December 2008, Adonis was released after nearly two years in prison. Centre for Media Freedom and Responsibility, ‘Jailed broadcaster released’, 28 December 2008, Available at: https://cmfr-phil.org/uncategorized/jailed-broadcaster-released/