Capalla v. Commissions on Elections, G.R. No. 201112, 13 June 2012.

31 Jul

[FACTS: on issue of digital signatures; based on transcription in the case]

During the oral arguments of the case in the Supreme Court, it was challenged that PCOS machines do not comply with the requirement of the law on automated elections that electronic transmissions must be digitally signed. Contrary to the belief of Justice Carpio, Atty. Lazatin explained that the 2010 automated elections already used digital signatures. According to Atty. Lazatin, such digital signatures were contained in iButtons (gadget). Justice Carpio asked how were it possible if Board of Election Inspectors (BEIs) did not input their private keys because allegedly there was no time and it would require five (5) months. Atty. Lazatin clarified that it was not a customized or personal digital signature but assigned by the COMELEC.


Whether or not the PCOS machines are capable of producing digitally signed-transmissions as required by law.



The Rules of Court, defines digital signature as the first one it is electronic signature consisting of a transformation of an electronic document or an electronic data message using an asymmetric or public cryptosystem such that a person having the initial untransformed electronic document and the signers public key can accurately determine: (i) whether the transformation was created using the private key that corresponds to the signers public key; and (ii) whether the initial electronic document has been altered after the transformation was made.

Digital signature requires private key and public key generated by an algorithm. There is another algorithm (second) which, if you match if you put together the private key and the message, will generate the signature.  The third algorithm, that if you put together the public key and the signature it will accept or reject the message.

In the 2010 elections for example, the private key is embedded in the iButtons which are used to start the PCOS machines. For authentication, all of the three BEIs are required. Each of them has an 8-digit PIN given to them in a sealed envelope. The COMELEC on the other hand controls the public key. Whoever in possession of the iButton and in possession of the set of PINs can send a transmission. Whoever wants to send transmission, he will have to get the private key from the BEI Chairman and the PIN numbers from the other members. If they can send an electronic transmission that’s digitally signed and when received by the COMELEC and matched with the public key will result with an official election return. Hence the statutory requirement of digital signature is complied accordingly.

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Posted by on July 31, 2015 in Case Digests, Evidence, Remedial Law


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