6/7/2020 E-Library - Information At Your Fingertips: Printer Friendly suspension for a period to be determined by the Congress, if the invasion or rebellion shall persist and public safety requires it."] (Emphasis supplied) [33] It is not farfetched to link election laws with public safety. The European Court of Human Rights considers the forced abolition of a political party espousing violent and extreme views as permissible in the interest of public safety, even though this impairs the party members' right to association. See Refah Partisi v. Turkey, 13 February 2003, Application Nos. 41340/98, 41342/98, 41343/98 and 41344/9837. (www.echr.coe.int/Documents/Reports_Recueil_2003-II.pdf, accessed on 18 January 2018) SEPARATE CONCURRING OPINION VELASCO,JR., J.: I concur with the ponencia of my esteemed colleague, Justice Andres B. Reyes, Jr. That the right to travel and to freedom of movement are guaranteed protection by no less than the fundamental law of our land brooks no argument. While these rights are not absolute, the delimitation thereof must rest on specific circumstances that would warrant the intrusion of the State. As mandated by Section 6 of the Bill of Rights, any curtailment of the people's freedom of movement must indispensably be grounded on an intrinsically valid law, and only whenever necessary to protect national security, public safety, or public health, thus: SEC. 6. The liberty of abode and of changing the same within the limits prescribed by law shall not be impaired except upon lawful order of the court. Neither shall the right to travel be impaired except in the interest of national security, public safety, or public health, as may be provided by law. (Emphasis and underscoring supplied) The Department of Justice (DOJ) Circular No. 41 cannot be the law pertained to in the provision. As pointed out in the ponencia, it is but an administrative issuance that requires an enabling law to be valid.[1] Jurisprudence dictates that the validity of an administrative issuance is hinged on compliance with the following requirements: 1) its promulgation is authorized by the legislature; 2) it is promulgated in accordance with the prescribed procedure; 3) it is within the scope of the authority given by the legislature; and 4) it is reasonable.[2] The DOJ, thus, exceeded its jurisdiction when it assumed to wield the power to issue hold departure orders (HDOs) and watchlist orders (WLOs), and allow department orders which unduly infringe on the people's right to travel absent any specific legislation expressly vesting it with authority to do so. I, therefore, concur that DOJ Circular No. 41 is without basis in law and is, accordingly, unconstitutional. elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/64165 57/70