1/4/2021 E-Library - Information At Your Fingertips: Printer Friendly government; (2) it furthers an important or substantial governmental interest; (3) such governmental interest is unrelated to the suppression of the free expression; and (4) the incidental restriction on the alleged freedom of expression is no greater than what is essential to the furtherance of the governmental interest.[38] Our point of inquiry focuses on the fourth criterion in the said test, i.e., that the regulation should be no greater than what is essential to the furtherance of the governmental interest. The failure to meet the fourth criterion is fatal to the regulation's validity as even if it is within the Constitutional power of the government agency or instrumentality concerned and it furthers an important or substantial governmental interest which is unrelated to the suppression of speech, the regulation shall still be invalidated if the restriction on freedom of expression is greater than what is necessary to achieve the invoked governmental purpose.[39] In the judicial review of laws or statutes, especially those that impose a restriction on the exercise of protected expression, it is important that we look not only at the legislative intent pr motive in imposing the restriction, but more so at the effects of such restriction when implemented. The restriction must not be broad and should only be narrowly-tailored to achieve the purpose. It must be demonstrable. It must allow alternative avenues for the actor to make speech.[40] As stated, the prohibition is aimed at ensuring the conduct of honest and orderly elections to uphold the credibility of the ballots. Indeed, these are necessary and commendable goals of any democratic society. However, no matter how noble these aims may be, they cannot be attained by sacrificing the fundamental right of expression when such aim can be more narrowly pursued by not encroaching on protected speech merely because of the apprehension that such speech creates the danger of the evils sought to be prevented.[41] In this case, the challenged provision's sweeping and absolute prohibition against all forms of expression considered as partisan political activities without any qualification is more than what is essential to the furtherance of the contemplated governmental interest. On its face, the challenged law provides for an absolute and substantial suppression of speech as it leaves no ample alternative means for one to freely exercise his or her fundamental right to participate in partisan political activities. Consider: The use of the unqualified term "abroad" would bring any intelligible reader to the conclusion that the prohibition was intended to also be extraterritorial in application. Generalia verba sunt generaliter inteligencia.[42] General words are understood in a general sense. The basic canon of statutory interpretation is that the word used in the law must be given its ordinary meaning, unless a contrary intent is manifest from the law itself.[43] Thus, since the Congress did not qualify the word "abroad" to any particular location, it should then be understood to include any and all location abroad. Regardless, therefore, of whether the exercise of the protected expression is https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/65669 12/60