FACTS:
San Miguel sought to recover from two insurance policies. It is maintained however that San Miguel’s only interest in the property insured is that it is a mortgage creditor. The property was really owned by Harding who was included as a defendant. The insurance companies don't deny liability but they maintain that San Miguel is only entitled to the amount of the mortgage credit. They also maintain that Harding is not entitled to any proceeds in excess of the mortgage credit because he was not party to the insurance contract.
HELD:
There is no cause of action in Henry Harding against the insurance companies. He is not a party to the contracts of insurance and cannot directly maintain an action thereon. His claim is merely of an equitable and subsidiary nature and must be made effective, if at all, through the San Miguel Brewery in whose name the contracts are written. Now the Brewery, as mortgagee of the insured property, undoubtedly had an insurable interest therein; but it could not, in any event, recover upon these policies an amount in excess of its mortgage credit. In this connection it will be remembered that Antonio Brias, upon making application for the insurance, informed the company with which the insurance was placed that the Brewery was interested only as a mortgagee. It would, therefore, be impossible for the Brewery mortgage on the insured property. This conclusion is not only deducible from the principles governing the operation effect of insurance contracts in general but the point is clearly covered by the express provisions of sections 16 and 50 of the Insurance Act (Act No. 2427). In the first of the sections cited, it is declared that "the measure of an insurable interest in property is the extent to which the insured might be damnified by loss or injury thereof" (sec. 16); while in the other it is stated that "the insurance shall be applied exclusively to the proper interest of the person in whose name it is made unless otherwise specified in the policy" (sec. 50).
These provisions would have been fatal to any attempt at recovery even by D. P. Dunn, if the ownership of the property had continued in him up to the time of the loss; and as regards Harding, an additional insuperable obstacle is found in the fact that the ownership of the property had been charged, prior to the loss, without any corresponding change having been effected in the policy of insurance. In section 19 of the Insurance Act we find it stated that "a change of interest in any part of a thing insured unaccompanied by a corresponding change of interest in the insurance, suspends the insurance to an equivalent extent, until the interest in the thing and the interest in the insurance are vested in the same person." Again in section 55 it is declared that "the mere transfer of a thing insured does not transfer the policy, but suspends it until the same person becomes the owner of both the policy and the thing insured."
Undoubtedly these policies of insurance might have been so framed as to have been "payable to the Sane Miguel Brewery, mortgagee, as its interest may appear, remainder to whomsoever, during the continuance of the risk, may become the owner of the interest insured." (Sec 54, Act No. 2427.) Such a clause would have proved an intention to insure the entire interest in the property, not merely the insurable interest of the San Miguel Brewery, and would have shown exactly to whom the money, in case of loss, should be paid. But the policies are not so written.
Sunday, June 13, 2010
Go vs. Redfern, GR 47705, 25 April 1941
Note: Original decision in Spanish [Rough translation]
Facts:
In October 1937, Edward K. Redfern obtained an insurance policy against accidents from the International Assurance Co, Ltd. On 31 August 1938, Redfern died from an accident. The mother of the deceased, presenting the necessary evidence of the death of Redfern, sought to claim the proceeds of the insurance policy from the insurance company. The company, however, denied such claim, on the ground that the insurance policy was amended on 22 November 1937 to include another beneficiary, Concordia Go. Hence, an action was filed to determine who has the right to collect the insurance proceeds of the deceased Redfern. The mother claimed that the addition of the co-beneficiary is illegal. Go, on her part, alleged the contrary. The trial court ruled in favor of Angela Redfern, the mother. Go appealed.
Issue:
Whether the addition of Go’s name as co-beneficiary can be allowed for her share in the insurance proceeds
Held:
When designated in a policy, the beneficiary acquires a right of which he cannot be deprived of without his consent, unless the right has been reserved specifically to the insured to modify the policy. The same doctrine was enunciated by the Court in the cases of Gercio vs. Sun Life Assurance Co. of Canada (48 Phil. 55) and Insular Life vs. Suva (34 Off. Gaz. 861). Thus, unless the insured has reserved specifically the right to change or to modify the policy, with respect to the beneficiary, said policy constitutes an acquired right of the beneficiary, which cannot be modified except with the consent of the latter. Herein, it is admitted that Redfern did not reserve expressly his right to change or modify the policy. Change implies the idea of an alteration. The addition of Go's name as one of the beneficiaries of the policy constitutes change as all addition is an alteration. The addition of Go's name changed the policy inasmuch as there are two beneficiaries instead of one, and thus in effect the original beneficiary cannot receive the full amount of the policy. The Supreme Court affirmed the appealed judgment in all of its parts, with costs against Go.
Facts:
In October 1937, Edward K. Redfern obtained an insurance policy against accidents from the International Assurance Co, Ltd. On 31 August 1938, Redfern died from an accident. The mother of the deceased, presenting the necessary evidence of the death of Redfern, sought to claim the proceeds of the insurance policy from the insurance company. The company, however, denied such claim, on the ground that the insurance policy was amended on 22 November 1937 to include another beneficiary, Concordia Go. Hence, an action was filed to determine who has the right to collect the insurance proceeds of the deceased Redfern. The mother claimed that the addition of the co-beneficiary is illegal. Go, on her part, alleged the contrary. The trial court ruled in favor of Angela Redfern, the mother. Go appealed.
Issue:
Whether the addition of Go’s name as co-beneficiary can be allowed for her share in the insurance proceeds
Held:
When designated in a policy, the beneficiary acquires a right of which he cannot be deprived of without his consent, unless the right has been reserved specifically to the insured to modify the policy. The same doctrine was enunciated by the Court in the cases of Gercio vs. Sun Life Assurance Co. of Canada (48 Phil. 55) and Insular Life vs. Suva (34 Off. Gaz. 861). Thus, unless the insured has reserved specifically the right to change or to modify the policy, with respect to the beneficiary, said policy constitutes an acquired right of the beneficiary, which cannot be modified except with the consent of the latter. Herein, it is admitted that Redfern did not reserve expressly his right to change or modify the policy. Change implies the idea of an alteration. The addition of Go's name as one of the beneficiaries of the policy constitutes change as all addition is an alteration. The addition of Go's name changed the policy inasmuch as there are two beneficiaries instead of one, and thus in effect the original beneficiary cannot receive the full amount of the policy. The Supreme Court affirmed the appealed judgment in all of its parts, with costs against Go.
Wednesday, June 2, 2010
STRADEC vs. Radstock; G.R. No. 178158 and 180428; December 4, 2009; Natural Resources; Land Ownership; Public funds; Appropriation
Facts
Construction Development Corporation of the Philippines (CDCP) was incorporated in 1966. It was granted a franchise to construct, operate and maintain toll facilities in the North and South Luzon Tollways and Metro Manila Expressway.
CDCP Mining Corporation (CDCP Mining), an affiliate of CDCP, obtained loans from Marubeni Corporation of Japan (Marubeni). A CDCP official issued letters of guarantee for the loans although there was no CDCP Board Resolution authorizing the issuance of such letters of guarantee. CDCP Mining secured the Marubeni loans when CDCP and CDCP Mining were still privately owned and managed.
In 1983, CDCP’s name was changed to Philippine National Construction Corporation (PNCC) in order to reflect that the Government already owned 90.3% of PNCC and only 9.70% is under private ownership. Meanwhile, the Marubeni loans to CDCP Mining remained unpaid.
On 20 October 2000 and 22 November 2000, the PNCC Board of Directors (PNCC Board) passed Board Resolutions admitting PNCC’s liability to Marubeni. Previously, for two decades the PNCC Board consistently refused to admit any liability for the Marubeni loans.
In January 2001, Marubeni assigned its entire credit to Radstock Securities Limited (Radstock), a foreign corporation. Radstock immediately sent a notice and demand letter to PNCC.
PNCC and Radstock entered into a Compromise Agreement. Under this agreement, PNCC shall pay Radstock the reduced amount of P6,185,000,000.00 in full settlement of PNCC’s guarantee of CDCP Mining’s debt allegedly totaling P17,040,843,968.00 (judgment debt as of 31 July 2006). To satisfy its reduced obligation, PNCC undertakes to (1) "assign to a third party assignee to be designated by Radstock all its rights and interests" to the listed real properties of PNCC; (2) issue to Radstock or its assignee common shares of the capital stock of PNCC issued at par value which shall comprise 20% of the outstanding capital stock of PNCC; and (3) assign to Radstock or its assignee 50% of PNCC’s 6% share, for the next 27 years, in the gross toll revenues of the Manila North Tollways Corporation.
Strategic Alliance Development Corporation (STRADEC) moved for reconsideration. STRADEC alleged that it has a claim against PNCC as a bidder of the National Government’s shares, receivables, securities and interests in PNCC.
Issue
Whether or not the Compromise Agreement between PNCC and Radstock is valid in relation to the Constitution, existing laws, and public policy
Held
The Compromise Agreement is contrary to the Constitution, existing laws and public policy.
PNCC’s toll fees are public funds. PNCC cannot use public funds like toll fees that indisputably form part of the General Fund, to pay a private debt of CDCP Mining to Radstock. Such payment cannot qualify as expenditure for a public purpose. The toll fees are merely held in trust by PNCC for the National Government, which is the owner of the toll fees. Considering that there is no appropriation law passed by Congress for the compromise amount, the Compromise Agreement is void for being contrary to law, specifically Section 29(1), Article VI of the Constitution. And since the payment pertains to CDCP Mining’s private debt to Radstock, the Compromise Agreement is also void for being contrary to the fundamental public policy that government funds or property shall be spent or used solely for public purposes.
Radstock is not qualified to own land in the Philippines. Consequently, Radstock is also disqualified to own the rights to ownership of lands in the Philippines. Radstock cannot own the rights to ownership of any land in the Philippines because Radstock cannot lawfully own the land itself. Otherwise, there will be a blatant circumvention of the Constitution, which prohibits a foreign private corporation from owning land in the Philippines. In addition, Radstock cannot transfer the rights to ownership of land in the Philippines if it cannot own the land itself. It is basic that an assignor or seller cannot assign or sell something he does not own at the time the ownership, or the rights to the ownership, are to be transferred to the assignee or buyer. The third party assignee under the Compromise Agreement who will be designated by Radstock can only acquire rights duplicating those which its assignor is entitled by law to exercise. Thus, the assignee can acquire ownership of the land only if its assignor owns the land. Clearly, the assignment by PNCC of the real properties to a nominee to be designated by Radstock is a circumvention of the Constitutional prohibition against a private foreign corporation owning lands in the Philippines. The said circumvention renders the Compromise Agreement void.
Construction Development Corporation of the Philippines (CDCP) was incorporated in 1966. It was granted a franchise to construct, operate and maintain toll facilities in the North and South Luzon Tollways and Metro Manila Expressway.
CDCP Mining Corporation (CDCP Mining), an affiliate of CDCP, obtained loans from Marubeni Corporation of Japan (Marubeni). A CDCP official issued letters of guarantee for the loans although there was no CDCP Board Resolution authorizing the issuance of such letters of guarantee. CDCP Mining secured the Marubeni loans when CDCP and CDCP Mining were still privately owned and managed.
In 1983, CDCP’s name was changed to Philippine National Construction Corporation (PNCC) in order to reflect that the Government already owned 90.3% of PNCC and only 9.70% is under private ownership. Meanwhile, the Marubeni loans to CDCP Mining remained unpaid.
On 20 October 2000 and 22 November 2000, the PNCC Board of Directors (PNCC Board) passed Board Resolutions admitting PNCC’s liability to Marubeni. Previously, for two decades the PNCC Board consistently refused to admit any liability for the Marubeni loans.
In January 2001, Marubeni assigned its entire credit to Radstock Securities Limited (Radstock), a foreign corporation. Radstock immediately sent a notice and demand letter to PNCC.
PNCC and Radstock entered into a Compromise Agreement. Under this agreement, PNCC shall pay Radstock the reduced amount of P6,185,000,000.00 in full settlement of PNCC’s guarantee of CDCP Mining’s debt allegedly totaling P17,040,843,968.00 (judgment debt as of 31 July 2006). To satisfy its reduced obligation, PNCC undertakes to (1) "assign to a third party assignee to be designated by Radstock all its rights and interests" to the listed real properties of PNCC; (2) issue to Radstock or its assignee common shares of the capital stock of PNCC issued at par value which shall comprise 20% of the outstanding capital stock of PNCC; and (3) assign to Radstock or its assignee 50% of PNCC’s 6% share, for the next 27 years, in the gross toll revenues of the Manila North Tollways Corporation.
Strategic Alliance Development Corporation (STRADEC) moved for reconsideration. STRADEC alleged that it has a claim against PNCC as a bidder of the National Government’s shares, receivables, securities and interests in PNCC.
Issue
Whether or not the Compromise Agreement between PNCC and Radstock is valid in relation to the Constitution, existing laws, and public policy
Held
The Compromise Agreement is contrary to the Constitution, existing laws and public policy.
PNCC’s toll fees are public funds. PNCC cannot use public funds like toll fees that indisputably form part of the General Fund, to pay a private debt of CDCP Mining to Radstock. Such payment cannot qualify as expenditure for a public purpose. The toll fees are merely held in trust by PNCC for the National Government, which is the owner of the toll fees. Considering that there is no appropriation law passed by Congress for the compromise amount, the Compromise Agreement is void for being contrary to law, specifically Section 29(1), Article VI of the Constitution. And since the payment pertains to CDCP Mining’s private debt to Radstock, the Compromise Agreement is also void for being contrary to the fundamental public policy that government funds or property shall be spent or used solely for public purposes.
Radstock is not qualified to own land in the Philippines. Consequently, Radstock is also disqualified to own the rights to ownership of lands in the Philippines. Radstock cannot own the rights to ownership of any land in the Philippines because Radstock cannot lawfully own the land itself. Otherwise, there will be a blatant circumvention of the Constitution, which prohibits a foreign private corporation from owning land in the Philippines. In addition, Radstock cannot transfer the rights to ownership of land in the Philippines if it cannot own the land itself. It is basic that an assignor or seller cannot assign or sell something he does not own at the time the ownership, or the rights to the ownership, are to be transferred to the assignee or buyer. The third party assignee under the Compromise Agreement who will be designated by Radstock can only acquire rights duplicating those which its assignor is entitled by law to exercise. Thus, the assignee can acquire ownership of the land only if its assignor owns the land. Clearly, the assignment by PNCC of the real properties to a nominee to be designated by Radstock is a circumvention of the Constitutional prohibition against a private foreign corporation owning lands in the Philippines. The said circumvention renders the Compromise Agreement void.
PEZA vs. Pearl City Manufacturing Corporation; G.R. No. 168668; December 16, 2009; Administrative Proceedings; Due Process
Facts
PEZA is an administrative agency. Pearl City Manufacturing Corporation (PCMC) is a PEZA-registered Ecozone Export Enterprise. PCMC was informed of a physical inventory to be conducted by the PEZA officers. PEZA officers discovered that PCMC had an unaccounted importation of 8,259,645 kilograms of used clothing.
PCMC was instructed to submit its explanation regarding the unaccounted shortage. After submitting the required explanation, PCMC was subjected to a special audit conducted by PEZA to determine the amount of wastage generated by the company. On the basis of the results of the inventory and the special audit conducted, the PEZA Board passed a resolution canceling the PEZA Registration of PCMC as an Ecozone Export Enterprise.
An administrative appeal was filed by PCMC to the Office of the President (OP) from the resolution canceling its registration. The OP affirmed the resolution and denied the Motion for Reconsideration filed by PCMC afterwards. PCMC then filed a petition for review with the Court of Appeals. The CA reversed the decision of the OP and declared the PEZA Board Resolution cancelling the registration of PCMC as null and void.
Issue(s)
1. Whether or not PCMC was afforded due process
2. Whether or not there is substantial evidence to support the PEZA Board Resolution and the OP decision
Held
PCMC was afforded due process. In administrative proceedings, a fair and reasonable opportunity to explain one’s side suffices to meet the requirements of due process. The essence of procedural due process is embodied in the basic requirement of notice and a real opportunity to be heard. "To be heard" does not mean only verbal arguments in court; one may be heard also thru pleadings. Where opportunity to be heard, either through oral arguments or pleadings, is accorded, there is no denial of procedural due process.
PCMC cannot claim that it was denied due process because it was properly informed of the supposed discrepancy in its import and export liquidations. It was given ample opportunity to be heard or to explain its side in relation to its unaccounted imported materials. And it was informed of the decision of the PEZA Board to cancel its registration on the basis of its assessment of the evidence presented or lack thereof.
The PEZA Board Resolution and the Decision of the OP is supported by substantial evidence. Settled is the rule that Courts will not interfere in matters which are addressed to the sound discretion of the government agency entrusted with the regulation of activities coming under the special and technical training and knowledge of such agency. Administrative agencies are given wide latitude in the evaluation of evidence and in the exercise of their adjudicative functions, latitude which includes the authority to take judicial notice of facts within their special competence. The PEZA Board and the OP were correct in ruling that, based on the evidence presented, or the insufficiency thereof, the PCMC failed to account for the unexplained shortage in its imported materials. The failure of PCMC to account for the importation shortages constitutes prima facie proof that the goods or merchandise were illegally sent out of the restricted areas.
PEZA is an administrative agency. Pearl City Manufacturing Corporation (PCMC) is a PEZA-registered Ecozone Export Enterprise. PCMC was informed of a physical inventory to be conducted by the PEZA officers. PEZA officers discovered that PCMC had an unaccounted importation of 8,259,645 kilograms of used clothing.
PCMC was instructed to submit its explanation regarding the unaccounted shortage. After submitting the required explanation, PCMC was subjected to a special audit conducted by PEZA to determine the amount of wastage generated by the company. On the basis of the results of the inventory and the special audit conducted, the PEZA Board passed a resolution canceling the PEZA Registration of PCMC as an Ecozone Export Enterprise.
An administrative appeal was filed by PCMC to the Office of the President (OP) from the resolution canceling its registration. The OP affirmed the resolution and denied the Motion for Reconsideration filed by PCMC afterwards. PCMC then filed a petition for review with the Court of Appeals. The CA reversed the decision of the OP and declared the PEZA Board Resolution cancelling the registration of PCMC as null and void.
Issue(s)
1. Whether or not PCMC was afforded due process
2. Whether or not there is substantial evidence to support the PEZA Board Resolution and the OP decision
Held
PCMC was afforded due process. In administrative proceedings, a fair and reasonable opportunity to explain one’s side suffices to meet the requirements of due process. The essence of procedural due process is embodied in the basic requirement of notice and a real opportunity to be heard. "To be heard" does not mean only verbal arguments in court; one may be heard also thru pleadings. Where opportunity to be heard, either through oral arguments or pleadings, is accorded, there is no denial of procedural due process.
PCMC cannot claim that it was denied due process because it was properly informed of the supposed discrepancy in its import and export liquidations. It was given ample opportunity to be heard or to explain its side in relation to its unaccounted imported materials. And it was informed of the decision of the PEZA Board to cancel its registration on the basis of its assessment of the evidence presented or lack thereof.
The PEZA Board Resolution and the Decision of the OP is supported by substantial evidence. Settled is the rule that Courts will not interfere in matters which are addressed to the sound discretion of the government agency entrusted with the regulation of activities coming under the special and technical training and knowledge of such agency. Administrative agencies are given wide latitude in the evaluation of evidence and in the exercise of their adjudicative functions, latitude which includes the authority to take judicial notice of facts within their special competence. The PEZA Board and the OP were correct in ruling that, based on the evidence presented, or the insufficiency thereof, the PCMC failed to account for the unexplained shortage in its imported materials. The failure of PCMC to account for the importation shortages constitutes prima facie proof that the goods or merchandise were illegally sent out of the restricted areas.
Damasen vs. Tumamao; G.R. No. 173165; February 17, 2010; Succession in Sanggunian
Facts:
The Vice-Mayor of San Isidro, Isabela, died. The highest-ranking member of the Sangguniang Bayan, a member of the Laban ng Demokratikong Pilipino (LDP), was elevated as Vice-Mayor. Mayor Abraham T. Lim (Mayor Lim) recommended to Governor Maria Gracia Cielo M. Padaca (Governor Padaca) the appointment of Oscar G. Tumamao (Tumamao), also a member of the LDP, to fill up the vacancy in the Sanggunian. Tumamao took his oath before the mayor as Sangguninan member and attended its regular sessions.
After a few days, Atty. Lucky Damasen (Damasen) took his oath of affiliation to the LDP before the LDP Provincial Chairman, Ms. Ana Benita Balauag (Provincial Chairman Balauag), and secured from her a letter of nomination addressed to Governor Padaca for his appointment to the Sangguniang Bayan. He was appointed as Sanggunian member by the governor and took his oath before her. Damasen attended the Sangguniang Bayan session but was not duly recognized.
Damasen filed with the Regional Trial Court a petition seeking to be declared as the rightful member of the Sanggunian by reason of the provincial chairman’s nomination and the governor’s appointment.
The RTC ruled in favor of Damasen. It based its decision on Sec. 45 (b) of RA 7160. This law provides for the rule on succession in cases of permanent vacancies in the Sanggunian: first, that the appointee shall come from the same political party as that of the Sanggunian member who caused the vacancy and; second, that the appointee must have a nomination and a Certificate of Membership from the highest official of the political party concerned.
Tumamao appealed the RTC Decision to the Court of Appeals. The CA held that Damasen was not entitled to assume the vacant position in the Sangguniang Bayan.
Issue: Whether Damasen is entitled to assume the vacant position in the Sangguniang Bayan
Held:
Damasen is not entitled, not even qualified, to assume the vacant position in the Sangguniang Bayan because he is not a bona fide member of LDP. Provincial Chairman Balauag is not the highest official of the LDP. The membership of Damasen still had to be approved by the LDP National Council. Thus, notwithstanding Damasen’s procurement of a Certificate of Membership from LDP Provincial Chairman Balauag, the same merely started the process of his membership in the LDP, and it did not mean automatic membership thereto.
The Vice-Mayor of San Isidro, Isabela, died. The highest-ranking member of the Sangguniang Bayan, a member of the Laban ng Demokratikong Pilipino (LDP), was elevated as Vice-Mayor. Mayor Abraham T. Lim (Mayor Lim) recommended to Governor Maria Gracia Cielo M. Padaca (Governor Padaca) the appointment of Oscar G. Tumamao (Tumamao), also a member of the LDP, to fill up the vacancy in the Sanggunian. Tumamao took his oath before the mayor as Sangguninan member and attended its regular sessions.
After a few days, Atty. Lucky Damasen (Damasen) took his oath of affiliation to the LDP before the LDP Provincial Chairman, Ms. Ana Benita Balauag (Provincial Chairman Balauag), and secured from her a letter of nomination addressed to Governor Padaca for his appointment to the Sangguniang Bayan. He was appointed as Sanggunian member by the governor and took his oath before her. Damasen attended the Sangguniang Bayan session but was not duly recognized.
Damasen filed with the Regional Trial Court a petition seeking to be declared as the rightful member of the Sanggunian by reason of the provincial chairman’s nomination and the governor’s appointment.
The RTC ruled in favor of Damasen. It based its decision on Sec. 45 (b) of RA 7160. This law provides for the rule on succession in cases of permanent vacancies in the Sanggunian: first, that the appointee shall come from the same political party as that of the Sanggunian member who caused the vacancy and; second, that the appointee must have a nomination and a Certificate of Membership from the highest official of the political party concerned.
Tumamao appealed the RTC Decision to the Court of Appeals. The CA held that Damasen was not entitled to assume the vacant position in the Sangguniang Bayan.
Issue: Whether Damasen is entitled to assume the vacant position in the Sangguniang Bayan
Held:
Damasen is not entitled, not even qualified, to assume the vacant position in the Sangguniang Bayan because he is not a bona fide member of LDP. Provincial Chairman Balauag is not the highest official of the LDP. The membership of Damasen still had to be approved by the LDP National Council. Thus, notwithstanding Damasen’s procurement of a Certificate of Membership from LDP Provincial Chairman Balauag, the same merely started the process of his membership in the LDP, and it did not mean automatic membership thereto.
Welcome Fellow Student of the Law!
Hi! Welcome to my blog!
I will post all the things that I believe are relevant to all Philippine law students. Most of these will be case digests that I will personally make as regularly required in all law schools. I will also be posting updates in the practice and study of law especially those related to current events.
I hope to be of great help to you, my fellow law student. I do not write this to make you dependent or lazy. I still prefer that you read the whole cases themselves with my work as guides in your comprehension. You are free to criticize, comment, suggest, etc. (even copy!) my posts here.
Enjoy reading! Enjoy studying!
SO ORDERED.
I will post all the things that I believe are relevant to all Philippine law students. Most of these will be case digests that I will personally make as regularly required in all law schools. I will also be posting updates in the practice and study of law especially those related to current events.
I hope to be of great help to you, my fellow law student. I do not write this to make you dependent or lazy. I still prefer that you read the whole cases themselves with my work as guides in your comprehension. You are free to criticize, comment, suggest, etc. (even copy!) my posts here.
Enjoy reading! Enjoy studying!
SO ORDERED.
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