2021 National Human Rights Situation Report 67 high. Online GBV proliferates because of the nature of cyberspace–the anonymity it offers, the intractability of perpetrators, and the many barriers in accessing remedies.252 276 In the Safe Spaces webinars, cases raised include unauthorized distribution of private sexually explicit content, among students and also adults. In one case from the GBV portal on rape, the rape video was posted and reposted online. Even with the intervention of the Commission and with letter requests to Facebook, taking down took long, with several reposting in many other sites. All these highlight the continuing challenges in addressing GBV committed in online spaces and of the need to further strengthen referral mechanisms and response.253 277 Another issue pertaining to women’s equal protection before the law is the attempt to disqualify Gabriela Partylist. The issue has been brought to the attention of the Commission, particularly invoking women’s right to participation and representation. During the Commission’s Purple Action Day Webinar last March 2021, speakers from Gabriela including its Secretary General Joms Salvador and Gabriela representative Congresswoman Arlene Brosas detailed how the organization has been the subject of different attacks. In the case of Joms and other officers of Gabriela, criminal cases were filed by the National Task Force to End Local Communist Armed Conflict (NTF-ELCAC). A petition for disqualification on the other hand, was filed against the partylist.254 278 For Gabriela, these are clear acts of silencing and repression. They have filed petitions for writ of amparo and habeas corpus before the Supreme Court and have questioned as well the constitutionality of the Anti-terror Law. Gabriela stresses that all these actions, like the Anti-terror law are meant to silence dissent, they are an affront not only to Gabriela as an organization that has advance women’s human rights for 36 years, but also to all women and women human rights defenders.255 Children 279 A motu propio investigation on an alleged sexual assault and physical violence committed against a 9-year-old Jhenice Ednalan Punzalan by Christopher Abella transpired on 11 November 2020 at Barangay Locloc, Palauig, Zambales. Jhenice was found buried alive at Barangay Pangolingan and died after eight days. 280 Based on the investigation and information gathered by CHR Regional Office III, the respondent was seen comforting the victim during a commotion in front of the victim’s residence. The victim then went missing, and upon checking the barangay outpost CCTV camera, the victim was seen with Christopher. Some allegedly saw the respondent carrying the victim. 281 While the victim’s search continues, the victim’s relatives went to a vacant lot around 200 meters from the victim’s house. One of them stepped on the foot of the victim covered with grass. She was half-naked, and her struggle can be seen all over her young body. 252 Commission on Human Rights Gender Equality and Women’s Human Rights Center. (2021). Gender Ombud Report: January to June 2021 253 Commission on Human Rights Gender Equality and Women’s Human Rights Center. (2021). Gender Ombud Report: January to June 2021 254 Commission on Human Rights Gender Equality and Women’s Human Rights Center. (2021). Gender Ombud Report: January to June 2021 255 Commission on Human Rights Gender Equality and Women’s Human Rights Center. (2021). Gender Ombud Report: January to June 2021