Legal Technique Midterm Exam - Olivarez

16-284 1
I.
How has our history as a nation shaped the development of our legal system? What are the
modern-day indications of such historical influences? Discuss citing specifics.
Our history as a nation shaped the development of our legal system, through the influence
of the various nations that have occupied and colonized the Philippines, as well as the exposure
to indigenous populations and Muslims1. The Philippine legal system is considered to be a hybrid
system, because it is a mixture of civil law and common law regimes, along with Islamic law and
indigenous systems2. History has played a major role in forming the legal system of the
Philippines, such that the country used the different colonizers form of legal system as a basis to
form our own, while still preserving the integrity of the indigenous traditions and regulations.
While it is correct to say that the United States has inspired the present form of
government of the Philippines, the country had its primary influence during the Spanish colonial
period. Before their occupation, the indigenous groups of the Philippines had their own form or
system, which was allowed by the colonial government in 1565, under the condition that it did
not contradict the colonial structure3. The colonial form of government has influenced the
Philippines to adopt the civil law system, which promulgated the codification of the laws and
statutes. During the American colonization period, the Philippines were introduced to common
law while it retained civil law and indigenous regulations4. The common law system was able to
establish the Judiciary Act, making the Philippines have a Supreme Court, as well as Courts of
First Instance and Municipal Courts5. In addition to this, the Americans have also trained the
Philippines in developing their government by allowing them to adopt the American
governmental structure. America allowed the Filipinos to vote for their public officials, as well as
the creation of their own constitution with the due approval of the President of the United States6.
There are various modern-day indications that would show of such historical influences.
Primarily, it is seen through the use of jurisprudence or case law. Even though the Philippines
have codified its laws, its legal system still uses decisions of judges and justices as precedents or
as a basis in order to decide on a particular case. Statutory construction key terms such as stare
decisis and res judicata are applied whenever there are cases that have similar issues that can be
resolved using the decision of the one provided in jurisprudence or case law. With the use of
jurisprudence, it can be seen that the common law structure provided by the Americans is still
used by the country. In terms of civil law, it is seen through the countrys creation of the 1932
Revised Penal Code as well as the other codified laws such as the Civil Code of the Philippines.
In addition to this, it can also be seen that the intention of the country to preserve its
indigenous regulations and traditions is very much evident. The 1987 Constitution also provides,
in Article II of state policies under Section 22 that the state recognizes and promotes the rights of
indigenous cultural communities within the framework of national unity and development 7. Even
though this law is not self-executory, the Congress has passed Republic Act No. 8371, otherwise
1 DANTE, GATMAYTAN, LEGAL METHOD ESSENTIALS 2.0 8 (2014).
2 Id.
4 Id.
6 Id.
7 PHIL. CONST. art. II, XXII.
16-284 2
known as Indigenous Peoples Right Act, which was crafted in order to ensure the protection
of the rights, culture and traditions of the indigenous people. In addition to this, the Muslims are
also given autonomy through the creation of the Autonomous Regions in order for them freely
exercise their own regulations8.
In addition to the preservation of indigenous and Muslim rights and regulations, another
indication would be the existence of the local governments, particularly the barangays. During
the Spanish colonization, they have introduced a dispute resolution system, where there are
village leaders who would take immediate control of various conflicts and disputes within their
local jurisdiction9. The village leaders have evolved to become what is now known as the
barangay. The barangay chairman along with its kagawads serves as the grassroots of the
government. In addition to this, the 1987 Constitution is also patterned after the American
Constitution, as well as its separation of powers (judicial, executive and legislative)10.
II.
A.) What is judicial independence? Why does it matter in a democracy? Discuss this within
the context of current events.
Judicial independence is derived from the principle of separation of powers of the three equal
branches of the government. It is the ability of the judiciary to hear decide on justiciable issues
and questions freely and without any intervention coming from any other governmental
department or branch11. This means that the judiciary branch is given the right to exercise judicial
power without the influence of any public official or employee belonging to another branch of
the government.
The reason why judicial independence matters in a democracy, is because a democratic
government can be prone to biases which can influence and hinder the judiciary to decided
wisely on cases. According to Dante Gatmaytan, the judiciary should be able to hear and decide
cases in an independent manner, which would allow them to be free from outside influence or
pressure12. The judiciary is currently facing challenges when it comes to the amount of the
budget it receives. According to the report released by the Department of Budget and
Management on February 2016, the total budget that the judiciary shall receive is twenty-six
billion pesos, in which the main purpose for the increase of the budget is for the swift delivery of
justice13. Although, the main problem here is that this budget is no enough in order to promulgate
judicial independence because backlogs are still evident in the lower courts and bribery of judges
and other public officers under the judiciary is still prevalent due to lack of budget. For the fiscal
year of 2017, the judiciary prayed for a budget of P40.4 billion, although they only got P32.5
billion14. The main reason for the demand of the budget is to increase the efficiency in the
12 Id.
13 Department of Budget and Management, Peoples Budget 2016, John Alliage Tinio Morales
28 (February 2016).
14 Delon Porcalla, House backs bigger budget for judiciary, PHIL. STAR, September 13, 2016,
available at http://www.philstar.com/headlines/2016/09/13/1623300/house-backs-bigger-budget-
judiciary (last accessed March 29, 2017).
16-284 3
delivery of the administration of justice, particularly the backlog of cases that are pending due to
the lack of courts caused by insufficient funding15.
B.) What factors can potentially compromise judicial independence? Identify at least three
(3) factors and discuss the Constitutional and legal mechanisms that have been instituted to
guard against such factors.
Primarily, the appointment of incompetent judges can potentially compromise judicial
independence. This is protected under the 1987 Constitution, particularly Article 8 Section 8,
which specifies and stipulates the creation of a Judicial and Bar Council that shall be responsible
for the appointment of prospective judges and justices 16. This is created in order to filter and
produce a short-list of candidates who are eligible to become a judge or a justice. Section 8
encourages the act that selection must be based on merit. It is focused on the credentials of the
person applying to become a justice or a judge.
The second aspect would be judges or justices rendering judgments or conclusions that
are considered to be arbitrary and unjust. This can potentially compromise judicial independence,
because arbitrariness is usually brought about bias, which means that judges or justices have the
possibility to be influenced by public officials, employees of the government, or even private
entities or individuals that are affected in a certain case that they are deciding on. Therefore, in
order to avoid this instance, Article 8 Section 14 expressly stipulates the following: No decision
shall be rendered by any court expressing therein clearly and distinctly the facts and the law on
which it is based17. Section 14 guarantees procedural fairness, in such a way that it ensures that
the judges or justices should render the decision in such a way that it informs both parties as to
how they were able to come up with the decision, based on the facts and the application of the
law.
Another aspect would be the behaviour of justices and judges, most especially those who
have committed grave acts that have compromised the reputation of the legal system of the
country, as well as the effective administration of justice. Specifically, instances wherein a
certain judge coming from a lower court has purposely delayed the proceeding of a certain case,
in order to injure a third person or party, or the abuse of power. To guard against such factor,
Article 8 Section 11 of the 1987 Constitution provides that the Supreme Court En Banc shall
supervise the judges and has the power to dismiss them18.
15 Id.
16 PHIL. CONST. art. VIII, VIII.
17 PHIL. CONST. art. VIII, XIV.
18 PHIL. CONST. art. VIII, XI.
16-284 4
III.
1.) What are the assumptions and/or biases underpinning the Majority Opinion? How do
they affect the legal reasoning of the Justices? Compare and contrast these with the
dissenting opinions, citing specifics if necessary.
Primarily, the majority opinion looks at the case in two main issues: whether or not the statement
that was made is considered to be libellous, and whether or not it was published in order to cause
emotional distress to the Muslim community19. The majority opinion was grounded in the
assumption that since the respondents were not able to identify a person that was injured on the
published work of the article, they cannot file a case and invoke that such publication was
libellous20. The Majority Opinion mentioned that in order for one to invoke the case of libel, one
must identify the person injured in the statement and that the cause of action should be in one or
similar with the class that they belong in order for it to be valid21.
Another assumption which grounded the Majority Opinion is the fact that they merely focused
on the application of the law and the requisites that would constitute libel and defamation, rather
than the social, cultural implications, as well as the erroneous facts that was evidently present in
the published statement. Throughout the case, the Majority Opinion kept on citing the definition
of defamation that includes libel and slander, the requisites of what a libellous act is, and did a
side-by-side analysis to the case. It was as if the Majority Opinion was just trying to fit a glove,
and if it were too tight or too loose, they would conclude that it was not the right size. This
analogy shows that the Majority Opinion was very technical in deciding on the case; they merely
showed the elements of defamation, libel, slander as well as the cause of action of libel, and
tested to see whether it would fit into the case, only to conclude that it will not simply because
the respondents were not able to identify a particular person who was injured to the statement.
The Majority Opinion was technical in a sense that they only focused on what the law
had to say about the case, without considering the possibility that such statement was erroneous,
which could also be held as an obscene publication. Even though it is stipulated that the judiciary
is only supposed to handle justiciable issues (or legal question) and not political questions, the
Majority Opinion should not isolate the presence of political questions or issues in the case at
hand. In addition to this, another assumption that grounded the Majority Opinion was the nature
and characteristic of the publication. It was mentioned in the case that the publicized statement
was not extreme or outrageous22. This meant that the statement that was published did not
constitute emotional distress to any of the respondents 23 and that the statement, for it to be
libellous, should not just be merely insulting and that offensive words which are either written or
uttered, is not sufficient to constitute a cause of action for libel 24. The Majority Opinion focused
on the application of the elements of defamation, libel and slander and paralleled it to the
characteristic of the said statement that was published. The Majority Opinion did not give much
19 MVRS Productions, Inc. vs. Islamic DaWah Council, SCRA 396 SCRA 210, 217 (2003).
20 MVRS Productions, Inc. vs. Islamic DahWah Council, SCRA 396 SCRA 210, 226 (2003).
23 Id.
16-284 5
attention on how it would affect the respondents in other aspects and what other actions could
have been taken into consideration, since it would appear to be more of a political issue.
Overall, these assumptions that grounded the Majority Opinion affected the legal
reasoning of the judges in such a way that it was just simply applying the elements of the law
into the case, and focusing on one legal perspective which was the definition and elements of
defamation, libel and slander and whether or not the case matches or complements such
elements. The Majority Opinion was able to conclude that since the statement that was published
does not constitute libellous characteristics, the respondents have no cause of action. The
assumptions that became the basis of the Majority Opinion has given them a black-and-white
perspective in handling the case. For them, it was either there was a cause of action for libel, or
no cause of action at all, because the respondents have failed to mention a specific person that
was injured in the said statement.
On the other hand, two justices have given their dissenting opinion about the case.
Primarily, Justice Carpio was focused on the nature of action of the respondents. He stated in his
dissenting opinion that the cause of action was a tort case and not a libel case 25. He said that the
case was geared towards the use of Article 26 of the Civil Code and the mere fact that the
statement was publicized would aggravate the situation, causing the respondents to have more
mental anguish26. In addition to this, Justice Carpio also mentioned the role of the judiciary in
terms of their responsibility to enforce Constitutional Rights 27, specifically the right guaranteed
by the State that there shall be full respect for human rights28. In comparison to the Majority
Opinion, Justice Carpio sees the case not in the perspective that focuses on the issue of libel, but
rather, he focused on the statement published being a torts case. In addition to this, he Justice
Carpio also placed emphasis on the rights of people, which is a Constitutional guarantee that is
supposed to be prioritized by the courts. Therefore, regardless of whether or not the statement
published has affected a group of Muslims in particular, or a person, or the whole Muslim
community, the Constitutional mandate is the guarantee of the full respect for human rights29.
Justice Carpio took into consideration that regardless of whether a person was not mentioned, the
respondents are human beings that have the right to claim respect.
Justice Austria-Martinez also voiced out that the petitioners of the case can be held liable
for damages under Article 33 and 26(4) of the Civil Code 30, and has mentioned in her dissenting
opinion that the statement that was published was indeed offensive and can be considered as a
dishonourable act to all Muslims31. The statement was also considered as a downright
misrepresentation of the religious beliefs of Muslims 32. Just like the Majority Opinion, she also
focused on the nature and characteristics of the statement. She mentioned that the structure of the
statement, invites the readers to conclude that the publication company was making a factual
28 Id.
29 Id.
32 Id.
16-284 6
statement, and not just a fictional one33. The difference between her opinion and the Majority
Opinion about the nature of the statement that was published, was that she found the statement to
be erroneous which made a difference in the way she reasoned. The Majority Opinion focused on
the wording of the statement, and did not distinguish it as a factual statement. In Justice Austria-
Martinez, she noted that the statement aggravates the situation of the respondents, because it was
asserting a factual claim.
2.) What values were prioritized by the Majority, Concurring, and Dissenting Opinions?
How are these evident in the text of the opinions? Explain, citing specifics as appropriate.
Primarily, the Majority Opinion prioritized the value of U.S. jurisprudence or case law. One of
them was Arcand v. The Evening Call Publishing Company, wherein the Majority Opinion used
it in order to strengthen their argument about the essence of defamation in relation to libel, citing
that the defamation of large groups does not give a cause of action to an individual with the
exception that it can be proved that the individual was the target of the defamatory matter 34. The
Major Opinion used a number of other U.S. jurisprudence in order to strengthen their arguments,
even though it was merely persuasive in nature. In addition to this, the Majority Opinion also
used a number of technical definitions such as defamation, libel and slander, and even
mentioning its elements or requisites. The Majority Opinion also valued the technicalities and the
pure application of laws in determining the resolution for the issue. The values of the Majority
Opinion were evident in the text, because they repeated the application of the elements of
defamation and even proved the applicability of the elements by citing jurisprudence.
The dissenting opinions valued the other legal perspective of the case, which were torts and civil
claims for damages. On the part of Justice Carpio, he cited mainly Article 26 and valued the
constitutional guarantee for the protection of rights of all human beings. On the other hand,
Justice Austria-Martinez placed importance on the use of Article 33, and has placed value on the
importance of distinguishing not the Muslim populace, but rather pinpointing the manner of
factual assertion on the part of the petitioners. She placed value on the fact that the statement was
publishing and asserting a fact, which would aggravate the situation on the part of the
respondents. The values that were upheld by the justices were evident, since they kept on
integrating their main points to the respective articles in the Civil Code. On the other hand, the
separate concurring opinion of Justice Vitug focused and valued on clarifying the elements and
the technicality of defamation, in relation to libel and slander. He has mentioned that the case
was a matter that concerned a civil action rather than a criminal one35.
3.) Which of the opinions is most persuasive for you? Why?

The most persuasive for me would be Justice Austria-Martinez. This is because she was
able to tackle the legal aspect of the case, as well as transform the political questions into legal
ones. I liked the fact that she focused on the nature or character of the statement; she did not
hastily conclude and was fast into judging, because it was more than just the insulting and
33 Id.
16-284 7
offensive words; it was also the manner of assertion. I liked that she pointed out that the
underlying intention to prejudice the Muslim community due to the statement being a factual
assertion rather than a circumstantial one36. In addition to this, she was also able to look at the
legal issue in another perspective, by delving into Article 33 of the Civil Code. Just like Justice
Carpio, Justice Austria-Martinez also agreed that respondents could seek to claim damages on
the respective provision of the Civil Code. This goes to show that there was more to the case than
just the issue of whether or not the statement was a libellous act. Her opinion was able to
broaden the legal question and issue, by taking into consideration the political issues as well
through finding ways in integrating them or turning them into legal issues.
IV.
1.) Compare and contrast how the Majority, Separate, and Dissenting Opinions treated the
following legal authorities:
(a) The 1987 Constitution;
(b) Republic Act No. 10368;
(c) The International Convention on Civil and Political Rights; and
(d) AFP Regulation G 161-375
I. The Majority Opinion

The Majority Opinion primarily stated that the provisions stipulated in Article II of the
1987 Constitution should not be interpreted as a legal basis that is self-executory37 and even cited
the case of Taada v. Angara, stating that the provisions in Article II are used as aids or guides
for the purposes of judicial review38. In addition to this, they the Majority Opinion also
mentioned that Section 17 of Article VII of the 1987 Constitution, was not violated since the
provision is considered to be self-executory and that the President has the prerogative to carry
out the necessary steps and is an imposed obligation, under the Faithful Execution Clause39.
Concerning R.A. No. 10368, the Majority Opinion said that the particular Republic Act is silent
on the issue of the internment of Marcos in the Libingan ng mga Bayani (LNMB) 40. In addition
to this, the Majority Opinion also mentioned that the internment of Marcos in the LNMB shall
not have any negative effects or have any impairments on the part of enforcing Human Rights
Violations Victims (HRVVs) rights41.
37 Ocampo v. Enriquez, G.R. No. 225973, Nov. 8, 2016, 16, available at
http://sc.judiciary.gov.ph/pdf/web/viewer.html?
file=/jurisprudence/2016/november2016/225973.pdf (last accessed March 29, 2017).
38 Id.
16-284 8
Apart from R.A. No. 10368, the Majority Opinion also mentioned their decision regarding the
part pertaining on International Convention on Civil and Political Rights (ICCPR). The Majority
Opinion has held that the country is more than compliant to their obligation to the ICCPR, and
even mentioned specific laws that have been done by the Congress, which affected human
rights42. The Majority Opinion said that President Dutertes decision in allowing Marcos to be
buried in the LNMB shall not have any detrimental effects on how the Philippines comply with
the ICCPR43. Finally, regarding the AFP Regulation G 161-375, the Majority Opinion stated that
there is no provision stipulated in such Regulation that shall prohibit the interment of Marcos at
the LNMB44.
II. The Separate Opinions

Primarily, Brion pointed out that the Faithful Execution Clause does not constitutionalize the
issue, and even mentioned that such clause in relation to the functions of the Chief Executive,
also has limitations45. On the other hand, he agreed with the Majority Opinion in saying that the
burial order does not violate the international law obligations, such as the ICCPR 46. On the other
hand, Justice Perez talked about the consolidated cases, particularly focusing on President
Dutertes promise to voters that if he wins as President, he shall allow the burial of Marcos in the
LNMB47. He stated that this issue is considered to be a political question, and it does not even
lead to grave abuse of discretion because the basis is the result of the election 48. On the part of
Justice Mendoza, he mentioned that the issues present in the said case are non-justiciable since it
is grounded with political questions49.
II. Dissenting Opinions

The dissenting opinion of Justice Sereno lies mainly on the notion that the court should not just
merely look at the issue as a technical and a black-and-white issue, because the absence of an
express prohibition for her is not just the sole determinant factor that should decide the fate of
the case50. She mentioned that this case is not just looking at the constitutionality of the issues,

45 Ocampo vs. Enriquez, G.R. No. 225973, Nov. 8, 2016, 5, (Justice Arturo Brion, Separate
Opinion).
46 Ocampo vs. Enriquez, G.R. No. 225973, Nov. 8, 2016, 9, (Justice Arturo Brion, Separate
Opinion).
47 Ocampo vs. Enriquez, G.R. No. 225973, Nov. 8, 2016, 16, (Justice Jose Perez, Separate
Opinion).
48 Ocampo vs. Enriquez, G.R. No. 225973, Nov. 8, 2016, 16, (Justice Jose Perez, Separate
Opinion).
49 Ocampo vs. Enriquez, G.R. No. 225973, Nov. 8, 2016, 3, (Justice Jose Mendoza, Separate
Opinion).
50 Ocampo vs. Enriquez, G.R. No. 225973, Nov. 8, 2016, 1, (Chief Justice Maria Lourdes
Sereno, Dissenting Opinion).
16-284 9
but rather, it should also preserve itself and to look beyond the events of the past, and to focus on
the context of political reality51. In addition to this, she also mentioned that the court has the duty
to protect what the 1987 Constitution embodies52, as well as stating that the courts should look
and resolve at the issues with the use of a holistic perspective 53. Overall, she strongly disagrees
with the statements of the Majority Opinion, primarily because they focused on the technicalities
of the political issue, without considering the social factors such as the use of historical
references and other mandates coming from the 1987 Constitution54.
2.) Compare and contrast the Majority Opinion of Justice Peralta and the Dissenting
Opinion of Justice Caguioa on the procedural issues. What are the underlying philosophies
and how are they manifested in their respective opinions?
Overall, the Majority Opinion dealt with the procedural issues, as something that is isolated with
the political and social context of the time. Primarily, in terms of the case being a justiciable
controversy, the Majority Opinion concluded that President Dutertes decision to allow the burial
of Marcos in the LNMB a political question in nature, and therefore the petitioners cannot
invoke that there was a grave abuse in the exercise of such discretion since President Dutertes
choice to do such act is beyond judicial powers 55. In the case of locus standi, the Majority
Opinion mentioned that such petitioners have no legal standing because they were not able to
prove that they have suffered due to the burial of Marcos in the LNMB 56. In terms of the
exhaustion of administrative remedies, the Majority Opinion was not able to exhaust all legal
remedies available to them, and has failed to show exceptions that would grant them a waiver to
the doctrine of exhaustion of administrative remedies57.
On the other hand, Justice Caguioa strongly dissents the points raised by the Majority Opinion.
On the issue regarding whether or not the issue is a justiciable controversy, he mentioned that
there is no black-and-white perspective, and that the legal question and political question are
both inextricably intertwined58. In this particular case, he stated that the decision of President
Duterte about the interment of Marcos in the LNMB, is not purely a political question since he
functions with the powers granted by the 1987 Constitution. Therefore, the courts can investigate
on the issue based on the limitation of such power granted by President Duterte 59. In addition to
54 Id.
56 Id.
58 Ocampo vs. Enriquez, G.R. No. 225973, Nov. 8, 2016, 2, (Justice Alfredo Benjamin
Caguioa, Dissenting Opinion).
59 Ocampo vs. Enriquez, G.R. No. 225973, Nov. 8, 2016, 5-6, (Justice Alfredo Benjamin
16-284 10
this, he also stated that the petitioners actually have locus standi in the case, particularly the
victims of Martial Law since they have a personal and direct interest to question the burial of
Marcos in the LNMB since the foundation of this interest lies on their right to a full and effective
remedy to reparations60. Lastly, he also stated that the petitioners did not violate the rule on
hierarchy of courts, since there are special and compelling reasons that are present in the case to
present it directly to the Supreme Court61.
The underlying philosophy of Justice Caguioa is mostly based on jurisprudence. He cites a
number of case law that would substantiate what is stipulated in the rule of law. It goes to show
that he is constructing his answer based on experience and the reality of the application of the
law. On the other hand, Justice Peraltas underlying philosophy is very technical and legalese. He
strives to prove the points of the Majority Opinion by using the rule of law and applying it to the
facts stipulated in the case. The application of law makes his philosophy a black-and-white one,
which is objective in nature.
3.) Among all the opinions, whose interpretation of AFP Regulation G 161-375 is most
persuasive for you? Why?
For me, the most persuasive interpretation of AFP Regulation G 161-375 is Justice
Caguioas explanation. This is because he was able to clarify the meaning of the burial site,
saying that the word bayani is merely a misnomer, and that just because a person is buried
there does not mean that the person is deemed as a hero 62. In addition to this, I also like the fact
that he used jurisprudence in order to support his answers, and not merely rely on the rule of law
in order to justify his points. His explanation of AFP Regulation G 161-375 is comprehensive,
detailed and specific, since he was able to use jurisprudence to connect it, and he also paralleled
it to other statutes that are in close relation with such regulation. He analysed the regulation not
by merely breaking it down into parts in isolation with other laws and case law, but rather he
related it to the presidential proclamations and other statutes63. In general, his interpretation of
the regulation, was done with the use of harmonizing the laws and statutes in order to thoroughly
understand the regulation in a more detailed manner64.
Bonus
The Majority and Concurring Opinions have both seen the political question doctrine as a basis
for their decisions. Although, the political question doctrine has also hindered the both opinions
to fully decide on the issue, primarily because they are constrained or limited in analysing the
legal questions. Although, the quote of Wiesel is a message to the court that if the judges and
justices can effectively turn political questions to legal questions, then there would be issues to
64 Id.
16-284 11
tackle and not just merely a black-and-white situation. Even though it has been mentioned that
the political question does take sides, in the case of the Marcos burial, it does not seem to be the
case because the historical and contextual background should be taken into consideration. In the
quote of Desmond Tutu, justices should take sides in order to serve and administer justice in the
courts. In the case of the burial of Marcos, it is not just the internment, but rather the issue
involving the past and present generations that were affected due to his reign in the Martial Law.

Legal Technique Midterm Exam - Olivarez

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Legal Technique Midterm Exam - Olivarez

Uploaded by

Copyright:

Available Formats

16-284 1

3.) Which of the opinions is most persuasive for you? Why?

I. The Majority Opinion

II. The Separate Opinions

II. Dissenting Opinions

42 Ocampo v. Enriquez, G.R. No. 225973, Nov. 8, 2016, 27, available at

You might also like