Legal implication of Database rights when introduced in the Philippines

Legal implication of Database rights when introduced in the Philippines

“So one begins to wonder what is going to happen to the human race. Technology keeps on advancing with greater and greater power, either for good or for destruction.”

David Bohm

I

INTRODUCTION

 

The day of celebration of independence   varied   throughout   the   nation’s   history.  The   earliest record was on April 12, 1895 when Andres Bonifacio, along with Emilio Jacinto and few other katipuneros initiate new   members   of   the   Katipunan.  Bonifacio   let   the   Cry of Pugad Lawin signals the beginning of Philippine Revolution. In 1896 the Philippine Revolution began and in December   1897   the   Pact   of   Biak   na   Bato,   an   agreement   between   the   Spanish   colonial government and the revolutionaries established a truce. Under its term, Emilio Aguinaldo and other revolutionary leaders went into exile in Hong Kong May 1, 1898 the U. S Navy defeated the Spanish in the Battle of Manila Bay, effectively putting the U.S in control of the Spanish colonial government. Later, the U.S. Navy transported Aguinaldo back to the Philippines. By June, Aguinaldo believed that a declaration of independence would inspire people to fight against the Spaniards and at the same time lead other nations to recognize the independence of the Philippines. On June 5, 1898, Aguinaldo issued a decree settling aside June 12, 1898 as the day of the proclamation of independence.1

During the revolution, Aguinaldo and other the revolutionary leaders only wanted to be freed from the Spaniards, other than that, they do not have a solid plan on how to run a country. In June 12, 1898 Philippines is not yet ready to be independent because technically speaking, the Philippines is not yet ready to be a state that time. We do not have laws of our own, because of this, we have been adopting laws and policies from other country. We are doing this to keep up with the world as it evolves.

An example law that we still need to adopt from neighboring country is the Database rights which aim to protect the collection of independent works, data or other materials which are arranged in a systematic or methodical way and are individually accessible by electronic means. This is a policy that is needed in our country because even though Philippines is far behind the other huge and power county, it is no surprise that our country can compete with them in terms of intellectual creations. The only problem is that our government fails to keep up with the pacing of the modern world.

 

 

II

DATABASE RIGHT

 

This is a new species of intellectual property which came into being on 1 Jan 1998. Database right protects investment in obtaining, verifying and presenting the contents of a database as distinct from the intellectual effort in creating it. Such intellectual effort continues to be protected by copyright. Thus, database right subsists independently, of but complementary to, copyright overlapping also with the law of confidence.

 

Database
A database is defined by reg. 6 of the Regulations as a collection of independent works, data or other materials which are arranged in a systematic or methodical way, and are individually accessible by electronic or other means. Database right can subsist in a database regardless of whether copyright also subsists. Unlike the law of confidence, there is no requirement that the database or its contents should have any commercial or other value. In C-444/02 Fixtures Marketing Limited v Organismos Prognostikon Agonon Pododfairou AE . [2004] BAILII C-444/02 the European Court of Justice held that the term “database” refers to “any collection of works, data or other materials, separable from one another without the value of their contents being affected, including a method or system of some sort for the retrieval of each of its constituent materials.” Accordingly, a fixture list for a football league such as that at issue in the case in the main proceedings constitutes a database within the meaning of that regulation.2 This is a wide definition which will cover traditional mailing lists and lists of customers as well as telephone directories, encyclopedias and card indexes, whether held electronically or in paper form. There is however a distinction to be drawn between a database and its individual components, which may or may not be protected in their own right separately from any protection afforded to the database as a whole.

Any software which is used in the making or operation of a database is specifically excluded from protection as a database, software instead generally being protected by copyright as a literary work.  Nevertheless, as software is often developed in modular form, it is possible that in some cases a collection of software modules may attract protection as a database.  Also, some elements of a computer program (for example, on screen look up tables which users may search in order to find information) may constitute a database.3

 

Subsistence

Database, like copyright, subsists automatically as soon as the database is made. There are no registration or other formalities. However, it is important to note that the qualification for database right is much narrower than for copyright. Nationality of, or residence, incorporation or having a principal basis in, an EEA state is required.

In C-203/02 British Horseracing Board and Others v William Hill Organization Ltd.[2004] ECR the European Court held that database right is intended to protect either investment in the resources used to seek out existing independent materials and collect them in the database or in those used, with a view to ensuring the reliability of the information contained in that database, to monitor the accuracy of the materials collected when the database was created and during its operation. It does not protect either the resources used for the creation of materials which make up the contents of a database or those used for verification during the stage of creation of materials which are subsequently collected in a database do not fall within that definition. On the specific issue that had been referred to the Court, namely whether resources used to draw up a list of horses in a race and to carry out checks in that connection constituted investment in obtaining and verification of the contents of a database, the Court held that it did not.

The Court reached similar conclusions in C-388/02 Fixtures Marketing Ltd v OY Veikkaus Ab {2004] BAILII C203/02, C-46/02 (a corresponding reference from Finland between the same parties) and Organismos Prognostikon Agonon Pododfairou. In the context of drawing up a fixture list for the purpose of organizing football league fixtures, which was the issue referred to the Court in that case, it held that the words “investment in … the obtaining … of the contents of a database” do not cover the resources used to establish the dates, times and the team pairings for the various matches in the league.

 

Copyright protection

Databases are treated as a class of literary works and may therefore receive copyright protection for the selection and/or arrangement of the contents under the terms of the Copyright, Designs and Patents Act 1988.

In order for copyright protection to arise the selection and/or arrangement of the contents of the database must be original. A special test of originality applies in relation to databases created after 27 March 1996. Such databases are original “if, and only if, by reason of the selection or arrangement of the contents of the database the database constitutes the author’s own intellectual creation”.

Copyright in databases therefore seeks to protect the intellectual creativity of the author. The author’s time, skill and labour must be directed to the selection and arrangement of the database, and not the mere gathering of information. Simply arranging a list of names in alphabetical order, for example, is unlikely to meet this standard.

Even if the set of data does not fall within the definition of a database, it may nonetheless attract copyright protection as a table or compilation depending on its nature. Tables and compilations are subject to the normal requirement of originality in that the author must have used his own skill and effort in creating the table or compilation.

If a database, table or compilation does attract copyright protection, this lasts for a period of 70 years from the end of the calendar year in which the author dies. Copyright protection gives a copyright owner the right to do various acts in relation to the work and the right to prevent others from doing so without permission, for example copying or adapting the work.

The copyright owner is generally the person who creates the work. This can sometimes cause confusion with commissioned works. For example a consultant will be the legal owner of copyright in a work created on behalf of the person or company commissioning it, unless ownership is dealt with contractually. However, if a copyright work is created by an employee it is the employer who is the first owner of the copyright provided the work was created in the course of the employee’s employment.

Database rights

Provided a set of data comes within the definition of a database, it will qualify for protection in its own right under the Regulations (irrespective of whether it benefits from protection under copyright) if there has been a “substantial investment” in obtaining, verifying or presenting the contents of the database.

Investment includes “any investment, whether of financial, human or technical resources” and substantial means “substantial in terms of quantity or quality or a combination of both”.

The maker of a database is defined as the person who “takes the initiative in obtaining, verifying or presenting the contents of a database and assumes the risk of investing in that obtaining, verification or presentation” and such person is the first owner of the database right. This definition is in contrast to that of an owner in copyright since where a database is commissioned, the commissioner will usually be the “maker” and first owner of the database right. If the database is made by an employee in the course of his employment, the employer will be regarded as the maker and therefore the owner of the database right subject to any agreement to the contrary.

A person infringes a database right if they extract or re-utilise all or a substantial part of the contents of a protected database without the consent of the owner. It should be noted, however, that extracting or re-utilising a substantial part of the contents can result from the repeated and systematic extraction or re-utilisation of insubstantial parts of the contents of a database.

There are a number of “permitted acts” set out in the Regulations. A database right in a database which has been made available to the public is not infringed by fair dealing with a substantial part of its content in certain defined circumstances, for example when someone with a right to use the database extracts data for teaching or research and not for any commercial purpose (provided they indicate the source of the material). Extraction and re-utilisation is also permitted when it is not possible by reasonable inquiry to ascertain the identity of the maker and it is reasonable to assume that the database right has expired.

Like copyright, a database right is an automatic right which exists as soon as the database exists in a recorded form. Database rights last for either 15 years from the end of the year in which the making of the database was completed or, if it was published during that period, 15 years from the end of the year in which the database was first made available to the public.

If there is a substantial change to the contents of the database then the 15 year protection period recommences. This includes a substantial change “resulting from the accumulation of successive additions, deletions or alterations, which would result in the database being considered to be a substantial new investment”.

 

Implementation in the UK

In the British Horseracing case, the European Court held that the words “extraction” and “re-utilisation” must be interpreted as referring to any unauthorized act of appropriation and distribution to the public of the whole or a part of the contents of a database and that they do not imply direct access to the database concerned. The fact that the contents of a database were made accessible to the public by its maker or with his consent does not affect the right of the maker to prevent acts of extraction and/or re-utilisation of the whole or a substantial part of the contents of a database. The expression ‘substantial part, evaluated … quantitatively, of the contents of [a] database’ refers to the volume of data extracted from the database and/or re-utilised and must be assessed in relation to the total volume of the contents of the database. The expression ‘substantial part, evaluated qualitatively … of the contents of [a] database’ refers to the scale of the investment in the obtaining, verification or presentation of the contents of the subject of the act of extraction and/or re-utilisation, regardless of whether that subject represents a quantitatively substantial part of the general contents of the protected database. Any part which does not fulfill the definition of a substantial part, evaluated both quantitatively and qualitatively, falls within the definition of an insubstantial part of the contents of a database. Accordingly, the prohibition laid down by the legislation refers to unauthorized acts of extraction or re-utilization the cumulative effect of which is to reconstitute and/or make available to the public, without the authorization of the maker of the database, the whole or a substantial part of the contents of that database and thereby seriously prejudice the investment by the maker.

 

III

 

CASE

William Hill and Fixtures Marketing cases

In November 2004, the European Court of Justice (ECJ) gave guidance on the application of the rules relating to database rights, significantly reducing the scope of protection given to the maker of a database under the Regulations. (Strictly speaking the ECJ considered database right principles under the EC Directive rather than the Regulations. However it is likely that the same principles will be applied to the interpretation of the UK legislation.)

The William Hill case involved a database operated by the British Horseracing Board (BHB) containing information relating to races, horses’ registration details, jockeys, fixture lists, race conditions, entries, runners etc. It cost BHB approximately £4 million a year to maintain. William Hill displayed a small, specific amount of information from BHB’s database on its website. BHB brought an action, alleging that William Hill’s use of the information infringed BHB database right.

The Court considered whether there had been “substantial investment” in obtaining or verifying the content of the database. The Court decided that the expression “investment” refers to the resources used to seek out existing independent materials and collect them in a database. The protection did not cover the investment involved in actually creating the data which made up the contents of the database. On the facts the Court found that the resources used by BHB in creating the database did not constitute substantial investment in either obtaining or verifying the contents of the database. BHB therefore had no protection under a database right.

The Court went on to consider the question of what constituted an extraction or re-utilisation of a “substantial part” of the contents of a database. The Court observed that the question could be addressed either quantitatively or qualitatively. In order to determine whether the data constituted a substantial part in the quantitative sense, the data extracted or re-utilised must be assessed in relation to the total volume of the content of the database. The use by William Hill of the information from the database represented a very small part of BHB’s whole database. There was therefore no extraction or re-utilisation of a substantial part in the quantitative sense.

In order to determine whether the data constituted a substantial part in the qualitative sense, the Court said that reference must be made to the scale of investment in the obtaining, verification or presentation of the contents of the database that are extracted and/or re-utilised. Since no separate effort had been employed to obtain, verify or present the particular part of the database used by William Hill, such part could not be substantial.

In the Fixtures Marketing cases, Fixtures Marketing Limited (“FML”) brought actions against three defendants, Oy Veikkaus AB from Finland, AB Svenska Spel from Sweden, and Organismos Prognostikon Agonon Pododfairou AE (OPAP) from Greece. FML alleged that all three organisations had extracted and/or re-utilised data from football fixture lists for the English premier league and its Scottish equivalent, which FML develops and administers at a cost of over £11.5 million a year.

As in the William Hill case, the Court ruled that only investment to seek out existing materials and collect them into a database will give rise to a database right. Resources used for the creation of materials that make up the database will not be sufficient to give rise to protection.

The Court held that neither the obtaining, verification, nor presentation of the contents of a football fixture list reflected substantial investment which could justify protection by a database right. FML could therefore not rely on a database right to prevent the use of its data by the defendants.

What should be taken from the ECJ’s ruling?

The following points should be noted following the ECJ ‘s decision:

  • Protection given to the maker of a database by a database right is not as wide as was previously thought.
  • Database rights only arise where the maker of the database has invested substantially in obtaining or verifying data from independent sources.
  • Investment in actually creating data which forms part of a database will not automatically result in a database right. Organizations creating data must make separate investment in the organization and arrangement of the database itself in order to gain protection.
  • Remember that a database can attract copyright as well as database rights. The reduction in the scope of protection under database rights may mean that the makers of databases seek to rely more on copyright in order to protect their investment

 

REFERENCES

https://en.wikipedia.org/wiki/Independence_Day_(Philippines)

https://niptech.wordpress.com/intellectual-property/intellectual-assets/technology-2/database-rights/

http://www.out-law.com/page-5698

Provision of the Revised Penal Code or Special Laws that can be aggravated by the use of a computer

“Now he has creatures to help him; stronger creatures than himself, more faithful, more useful, and absolutely devoted to him”

  • I robot (2004)

 

I

INTRODUCTION

 

In today’s world, everybody must keep up with the technology in order to conduct their daily lives. People are required to adapt to new knowledge and exciting discoveries that are changing the way they live and do business, even in looking for a job, the first requirement they are looking for is at least computer literate. Today, everything from saying hello to a friend in your neighbor to video chatting with someone around the world can be done electronically from home.

Technological advances now allow everyone to carry out the most mundane task, such as ordering food, buying tickets, enrolling to a class, even looking for destiny with the help of dating sites, up to the most complex activities such as performing complicated surgeries, all of there can be performed separately, or in a remote location as long as you are connected to the internet.

Humans invented the computer to help us in our daily lives, to assist people in many aspects of life and it is considered as a very helpful electronic device that gives us a beneficial tool in business dealings and in industrial sector, it improves the effectivity and productivity of work done, and it is convenient as well as to our personal lives.1 Now that we have established that the computer is a very power tool to help us in our daily lives, this also comes with the risk when the use of computer technology falls into the wrong hand.

This paper will show you that a simple act of crime can be aggravated with the use of computer. It shall be discussed in a series of chapters that focuses on crimes that the society is facing every day.

II

UNDERSTANDING CYBERCRIME

Computer crime, or cybercrime, is crime that involves a computer and a network. 2 The computer may have been used in the commission of a crime, or it may be the target.3 Debarati Halder and K. Jaishankar define cybercrimes as: “Offences that are committed against individuals or groups of individuals with a criminal motive to intentionally harm the reputation of the victim or cause physical or mental harm, or loss, to the victim directly or indirectly, , using modern telecommunication networks such as Internet (Chat rooms, emails, notice boards and groups) and mobile phones (SMS/MMS)”. Such crimes may threaten a nation’s security and financial health Issues surrounding these types of crimes have become high-profile, particularly those surrounding hacking, infringement, child, and child grooming. There are also problems of privacy when confidential information is intercepted or disclosed, lawfully or otherwise. Debarati Halder and K. Jaishankar further define cybercrime from the perspective of gender and defined ‘cybercrime against women’ as “Crimes targeted against women with a motive to intentionally harm the victim psychologically and physically, using modern telecommunication networks such as internet and mobile phones”.

III

CRIMES THAT CAN BE AGGRIVATED WITH THE USE OF A COMPUTER

UNDER REVICED PENAL CODE

Art. 8. Conspiracy and proposal to commit felony. — Conspiracy and proposal to commit felony are punishable only in the cases in which the law specially provides a penalty therefor.

A conspiracy exists when two or more persons come to an agreement concerning the commission of a felony and decide to commit it.

There is proposal when the person who has decided to commit a felony proposes its execution to some other person or persons.

Art. 115. Conspiracy and proposal to commit treason.

Art. 118. Inciting to war or giving motives for reprisals.

Art. 136. Conspiracy and proposal to commit coup d’etat, rebellion or insurrection.

Art. 138. Inciting a rebellion or insurrection.

Art. 141. Conspiracy to commit sedition.

Art. 142. Inciting to sedition.

Art. 146. Illegal assemblies.

Art. 147. Illegal associations.

These lists of crimes can be all tied up and be aggravated by the simple the use of group chat, emails, and text messages. By the use of this computer, anybody can now talk, incite, conspire, and discuss their plans. The beauty of this is that they can incite and conspire wherever and wherever they want by simply using their computers and cell phones. With the use of this technology, ordinary person can have a coordinated attack like militaries too.

ILLUSTRATION:

Joey and Pepe agreed and decided to rise publicly and take arms against the government. Thru facebook, they incited people by leaking secret government files and videos that light up there burning passion for the country. Using the group chat, emails, and text messages, they manage to perfect the plan without raising any suspicions against them because they rarely met each other and they are always few, but in fact there are 100 people participating. Having only little suspicions and perfectly coordinated attack, Joey and Pepe and the other 100 participants manage to execute their plan.

Art. 195. What acts are punishable in gambling. — (a) The penalty of arresto mayor or a fine not exceeding two hundred pesos, and, in case of recidivism, the penalty of arresto mayor or a fine ranging from two hundred or six thousand pesos, shall be imposed upon:

  1. Any person other than those referred to in subsections (b) and (c) who, in any manner shall directly, or indirectly take part in any game of monte, jueteng or any other form of lottery, policy, banking, or percentage game, dog races, or any other game of scheme the result of which depends wholly or chiefly upon chance or hazard; or wherein wagers consisting of money, articles of value or representative of value are made; or in the exploitation or use of any other mechanical invention or contrivance to determine by chance the loser or winner of money or any object or representative of value.
  2. Any person who shall knowingly permit any form of gambling referred to in the preceding subdivision to be carried on in any unhabited or uninhabited place of any building, vessel or other means of transportation owned or controlled by him. If the place where gambling is carried on has the reputation of a gambling place or that prohibited gambling is frequently carried on therein, the culprit shall be punished by the penalty provided for in this article in its maximum period.

(b) The penalty of prision correccional in its maximum degree shall be imposed upon the maintainer, conductor, or banker in a game of jueteng or any similar game.

(c) The penalty of prision correccional in its medium degree shall be imposed upon any person who shall, knowingly and without lawful purpose, have in his possession and lottery list, paper or other matter containing letters, figures, signs or symbols which pertain to or are in any manner used in the game of jueteng or any similar game which has taken place or about to take place.

Online gambling or e-games is no longer new to us because this is already rampant in our country, they are authorized to operate by the state provided that they have complied the requirements, licensed, and they are great source of tax.  Article 195 can be aggravated by the use of internet. Operators can now just simply make a website and conduct their operation via live feeds and people can bet online using the bit coin which they called the international currency or the internet currency. With this, a local operation can even be available for the whole country or even worldwide, given the power of the internet.

ILLUSTRATION:

Jojo has a secret barn where he operates an arena for dog fighting for the locals of Pangasinan (the system is just like Sabong). One day he decided to put up a website where you can watch the match and bet online.

Art. 248. Murder. — Any person who, not falling within the provisions of Article 246 shall kill another, shall be guilty of murder and shall be punished by reclusion temporal in its maximum period to death, if committed with any of the following attendant circumstances:

  1. With treachery, taking advantage of superior strength, with the aid of armed men, or employing means to weaken the defense or of means or persons to insure or afford impunity.
  2. In consideration of a price, reward, or promise.
  3. By means of inundation, fire, poison, explosion, shipwreck, stranding of a vessel, derailment or assault upon a street car or locomotive, fall of an airship, by means of motor vehicles, or with the use of any other means involving great waste and ruin.
  4. On occasion of any of the calamities enumerated in the preceding paragraph, or of an earthquake, eruption of a volcano, destructive cyclone, epidemic or other public calamity.
  5. With evident premeditation.
  6. With cruelty, by deliberately and inhumanly augmenting the suffering of the victim, or outraging or scoffing at his person or corpse.

Art. 249. Homicide.

 

Murder can be aggravated by the use of computer by using military drones. Military drone is an unmanned combat aerial vehicle (UCAV), also known as a combat drone or drone, is an unmanned aerial vehicle (UAV) that usually carries aircraft ordnance such as missiles. Aircraft of this type have no onboard human pilot.  These drones are usually under real-time human control, with varying levels of autonomy.4

A military drone can be use to commit a murder where by a person is controlling a drone to assassinate a person. With this, committing the crime makes it easier and more destructive.

ACTUAL CASE:

41 men targeted but 1,147 people killed: US drone strikes

 

Since 2004, the United States government has attacked thousands of targets in Northwest Pakistan using unmanned aerial vehicles (drones) controlled by the Central Intelligence Agency’s Special Activities Division. Most of these attacks are on targets in the Federally Administered Tribal Areas along the Afghan border in Northwest Pakistan.

These strikes began during the administration of United States President George W. Bush, and have increased substantially under his successor Barack Obama. Some in the media have referred to the attacks as a “drone war”. The George W. Bush administration officially denied the extent of its policy; in May 2013, the Obama administration acknowledged for the first time that four US citizens had been killed in the strikes. Surveys have shown that the strikes are deeply unpopular in Pakistan, where they have contributed to a negative perception of the United States

The US administration and Pakistani authorities have publicly claimed that civilian deaths from the attacks are minimal. Leaked military documents reveal that the vast majority of people killed have not been the intended targets, with approximately 13% of deaths being the intended targets, 81% being other militants, and 6% being civilians. The identities of collateral victims are usually not investigated by US forces, who systematically count each male military-age corpse as an “enemy killed in action” unless there is clear proof to the contrary, as long as the male was in a militant facility at the time. An estimated 158 to 965 civilians have been killed, including 172 to 207 children. Amnesty International found that a number of victims were unarmed and that some strikes could amount to war crimes.5

SPECIAL PENAL LAWS

“Comprehensive Dangerous Drugs Act of 2002”

ARTICLE I

Definition of terms

Section 3. Definitions. As used in this Act, the following terms shall mean:

(k) Deliver. – Any act of knowingly passing a dangerous drug to another, personally or otherwise, and by any means, with or without consideration.

(r) Illegal Trafficking. – The illegal cultivation, culture, delivery, administration, dispensation, manufacture, sale, trading, transportation, distribution, importation, exportation and possession of any dangerous drug and/or controlled precursor and essential chemical.

 

Since early 90’s before the internet was available to the Philippines, illegal drug trafficking by the used of remote controlled helicopters are already being practiced here in the country, but now that the technology is within our grasp, criminals/drugs lords are using this technology for drug trafficking in a higher scale.

ACTUAL CASE:

Mexico Drug Trafficking: Drone Carries 28 Pounds of Heroin Across Border To US

Two men have pleaded guilty to smuggling drugs by a drone, the Los Angeles Times has reported. This is the first cross-border drug seizure by U.S. law enforcement involving a drone, federal authorities said Wednesday.

Twenty-eight pounds of heroin were smuggled by the drone across the U.S. border near Calexico, near San Diego, in April. The two men who pleaded guilty were caught on Border Patrol cameras on April 28 retrieving the drugs near California Highway 98 in Imperial County, according to court records. U.S. law enforcement officials called drug-carrying drones an emerging threat but questioned how profitable the new method of smuggling can be, because drones are limited in how much they can carry.

“With border security tight, drug traffickers have thought of every conceivable method to move their drugs over, under and through the border,” said U.S. Attorney Laura Duffy in a statement, the Los Angeles Times reported. “We have found their tunnels, their Cessnas, their Jet Skis, their pangas, and now we have found their drones.”6

 

IV

CONCLUSION

The technology of computer and internet are created were created mainly to help us in our daily life, but as they say, there are two sides of the coin. And s technology is advancing and the crimes are also advancing, the law needs to be upgraded to meet the challenges of crimes out of this.

 

REFERENCE

iThe Importance Of Computers In Our Daily Lives, 2014, January 30, Available at http://www.pixuffle.net/the-importance-of-computers-in-our-daily-lives/.

 

ii Moore, R. (2005) “Cyber crime: Investigating High-Technology Computer Crime,” Cleveland, Mississippi: Anderson Publishing. Available athttps://en.wikipedia.org/wiki/Cybercrime

iiiHalder, D., & Jaishankar, K. (2011) Cyber crime and the Victimization of Women: Laws, Rights, and Regulations. Hershey, PA, USA: IGI Global. ISBN 978-1-60960-830-9 available at https://en.wikipedia.org/wiki/Cybercrime

ivDowd, Alan. “Drone wars: risks and warnings”. Retrieved 4 March 2014 available at https://en.wikipedia.org/wiki/Unmanned_combat_aerial_vehicle

vMonday, November 24, 2014

vihttps://www.theguardian.com/us-news/2014/nov/24/-sp-us-drone-strikes-kill-1147

The Revised Penal Code of the Philippines