EMPLOYER-EMPLOYEE RELATIONS

WITH LABOR LAWS AND CBA

Lecture Notes Part VI

 All employees in all establishments and undertakings, whether for

profit or not, except:
1. government employees (governed by the Civil Service Law)
2. managerial employees and managerial staff including supervisors,
(managers are exempted from Art 82 to 96; supervisors are
excluded in Book III but not in Book V)
3. field personnel,
4. members of the family of the employer who are dependent on him
for support,
5. domestic helpers or persons in the personal service of another (
except if they work in commercial/industrial establishments)
6. and workers who are paid by results as determined by the
Secretary of Labor in appropriate regulations. (output based
regardless of hours worked)

 Managerial employees refer to those whose primary duty

consists of the management of the establishment in which they
are employed or of a department or subdivision thereof, and to
other officers or members of the managerial staff
Field personnel refer to non-agricultural employees who
regularly perform their duties away from the principal place of
business or branch office of the employer and whose actual
hours of work in the field cannot be determined with
reasonable certainty

 Normal hours of work. - The normal hours of work of any employee

shall not exceed eight in a day.
Health personnel in cities or municipalities with a population of at
least one million (1,000,000) or in hospitals or clinics with a bed
capacity of at least one hundred (100) shall hold regular office hours
for eight (8) hours a day, for five (5) days a week, exclusive of time
for meals, except where the exigencies of the service require that
such personnel work for six (6) days or forty-eight (48) hours, in which
case they shall be entitled to an additional compensation of at least
thirty (30%) percent of their regular wage for work on the sixth day.
For purposes of this Article, health personnel shall include: resident
physicians, nurses, nutritionists, dieticians, pharmacists, social workers,
laboratory technicians, paramedical technicians, psychologists,
midwives, attendants and all other hospital or clinic personnel.
* Medical secretaries are also included
Govt health personnel are excluded and governed by R.A. 7305

 To safeguard the welfare of workers

To minimize unemployment by forcing
ERs to employ different workers for
each shift where the operation of the
establishment is more than 8 hrs a day
Note: Part-time work is not prohibited

 Hours worked. - Hours worked shall include (a) all time during which
an employee is required to be on duty or to be at a prescribed
workplace, and (b) all time during which an employee is suffered or
permitted to work.
Rest periods of short duration during working hours shall be counted
as hours worked
IRR : Principles in determining hors worked
a. All hours which the EE is required to give to his ER, whether or not if
spent in productive physical or mental exertion
b. If an EE can stop working and completely rest even if he does not
leave the premises, the same is counted as rest period.
c. Work done was necessary or benefited the ER or the EE cannot
abandon his work at the end of his shift because he has no
replacement as long as ER knows
d. Work interruptions due to forces beyond the EEs control if
imminence of resumption requires his presence or interruption is
brief to be used gainfully for EEs own interest.

 Hours worked. - Hours worked shall include (a) all time during which
an employee is required to be on duty or to be at a prescribed
workplace, and (b) all time during which an employee is suffered or
permitted to work.
Rest periods of short duration during working hours shall be counted
as hours worked
IRR : Principles in determining hors worked
a. All hours which the EE is required to give to his ER, whether or not if
spent in productive physical or mental exertion
b. If an EE can stop working and completely rest even if he does not
leave the premises, the same is counted as rest period.
c. Work done was necessary or benefited the ER or the EE cannot
abandon his work at the end of his shift because he has no
replacement as long as ER knows
d. Work interruptions due to forces beyond the EEs control if
imminence of resumption requires his presence or interruption is
brief to be used gainfully for EEs own interest.

 WORK DAY the 24-hr period which commences from the time
the EE regularly starts to work. Work done in excess of 8 hrs
within the 24-hr period is considered overtime regardless of
hether the work covers the two calendar days
BROKEN HOURS OF WORK - the minimum working hours need
not be continuous as logn as it is within the work day
WORK IN DIFFERENT SHIFTS IN A WORK DAY work in excess
of 8 hrs within a work day is considered overtime regardless of
whether this is performed in a work shift other than at which the
EE regularly works
COMPRESSED WORK WEEK (Dole Advisory No. 02-04)- the
number of work days is decreased but the number of hours is
increased to more than 8 but there is no overtime pay but work
beyond 48 hrs a week is overtime

 FLEXIBLE WORK ARRANGEMENTS (FWA) Dept Advisory No.

2, s pf 2009, FWA is better alternative than outright
termination or closure of establishment; DOLE must be apprised;
temporary in nature, maybe implemented in addition to
compressed work week and may include the ff:
A. REDUCTION OF WORK DAY normal workdays are reduced
but must not last 6 months
B. ROTATION OF WORKERS EEs are required to go on leave
for several days utilizing their leave credits if any
C. BROKEN-TIME SCHEDULE work schedule is not continuous but
the number of hours worked a day is not reduced
D. FLEXI-HOLIDAY SCHEDULE the EEs agree to avail of the
holidays without diminution of benefits

 WAITING TIME if spent predominantly for ERs benefit, then

compensable
WORKING WHILE EATING Not compensable if EE is
completely relieved from duty for the purpose of eating regular
meals.
WORKING WHILE SLEEPING Compensable if subject to
serious interruptions and EE must hold himself in readiness for a
call to action employment.
ON CALL An EE required to remain on call on the ERs
premises or close thereto that he cannot use the time effectively
for his own purpose is working while on call, If he is not
required to be at the ERs premises but merely required to
leave word where he may be reached is not working while on
call.

TRAVEL TIME : When is it compensable?

TRAVEL FROM HOME TO WORK When an EE received an emergency
call outside of his regular working hours and is required to travel to his
regular place of business or some other work site, such travel is working
time.
TRAVEL THAT IS ALL IN A DAYS WORK Time spent by an EE to travel as
part of his principal activity, such as travel from jobsite to jobsite during the
workday, or required to attend a meeting and get instructions from a
different place, or carry tools, the travel is compensable.
TRAVEL AWAY FROM HOME Travel that cuts through the working day is
compensable. Ex: Travel that keeps the EE away from home overnight,
while he is on board the place, train, ship, bus, etc to accompany his boss to
a meeting, unless given adequate facilties to sleep in; Time for truck driver
from getting delivery truck to and from the bodega is coempensable.

LECTURES/MEETINGS/SEMINARS
Attendance at lectures, meetings, training programs and similar
activities need not be counted as working time if the ff criteria
are met:
1. Attendance is outside of the EEs regular working hours
2. Attendance is in fact voluntary and
3. The EE does not perform any productive work during such
attendance
CASE: The security guards were directed to report for duty one
hour in advance of the usual time for guard work for briefing
purposes. The SC held that the services rendered outside the
working hours partake of overtime work. (PRISCO v CRI et al,
G.R. No. L-13806, May 23, 1960)

MEAL PERIOD
60 minutes for EEs regular meals; if less than or spent for ERs benefit,
then it is compensable.
May be shortened and not compensable if :
1. The EEs voluntarity agree in writing
2. No diminution in the salary and fringe benefits
3. The EEs work does not involve strenuous physical exertion and
there are adequate coffee breaks in the morning and afternoon
4. The value of the benefits derived by the EE from the arrangement is
commensurate with the compensation as well as for the overtime
pay for the remaining 30 min
5. The OT pay is due and demandable the moment the hours worked
exceeds 8 hrs

6. The effectivity of the arrangement is determined by the SOLE.

NIGHT SHIFT DIFFERENTIAL

Plus 10% of regular hourly rate for work performed between 10
p.m. to 6 a.m.
Night work is not desirable. Lack of sunlight tends to produce
anemia and tuberculosis and to predispose to other ills. Nigh shift
brings increased liability to eyestrain and accident. Serious moral
dangers are also likely to result from the necessity of traveling the
street alone and from the interference with normal home life.
From an economic point of view, moreover, the investigation
showed that night work was unprofitable, being inferior to day
work both in quality and quantity (Principles of Labor Legislation
by Commons and Andrew, 4th Ed, p 142)

OVERTIME PAY compensation as additional pay for service or

work rendered in excess of 8 hrs a day by EEs covered by the
Eight-hour Labor Law.; plus 25% of the bdr
REGULAR BASE PAY/ BASIC PAY excludes money received by an
employee in different concepts such as Christmas bonus and other
fringe benefits.
UNDERTIME work on any particular day shall not be offset by
overtime work on same day or another day. Remedy is to deduct
undertime from leave credits or salary but pay the overtime.

An EE may be required by the ER to perform overtime work in any of the ff cases:

(a) When the country is at war or when any other national or local emergency
has been declared by Congress or the Chief Executive;
(b) When it is necessary to prevent loss of life or property or in case of
imminent danger to public safety due to an actual or impending emergency in
the locality caused by serious accidents, fire, flood, typhoon, earthquake,
epidemic or other disaster or calamity;
(c) When there is urgent work to be performed on machines, installation or
equipment, in order to avoid serious loss or damage to the employer or some
other cause of similar nature;
(d) When the work is necessary to prevent loss or damage to perishable
goods;
(e) Where the completion or continuation of the work started before the eight
(8th) hour is necessary to prevent serious obstruction or prejudice to the business
or operations of the employer.
Any employee required to render overtime work under this Article shall be
paid the additional compensation required in this Chapter.

(a) It shall be the duty of every employer, whether

operating for profit or not, to provide each of his
employees a rest period of not less than twenty-four
consecutive hours after every six consecutive normal
work days.
(b) The employer shall determine and schedule the
weekly rest day of his employees, subject to collective
agreement and to such rules and regulations as the
Secretary of Labor and Employment may provide.
However, the employer shall respect the preference of
employees as to their weekly rest day when such
preference is based on religious grounds.

The employer may require his employees to work on any day:

(a) In case of actual or impending emergencies caused by serious accidents,
fire, flood, typhoon, earthquake, epidemic or other disaster or calamity to
prevent loss of life and property or imminent danger to public safety;
(b) In cases of urgent work to be performed on the machinery, equipment or
installation to avoid serious loss which the employer would otherwise suffer;
(c) In the event of abnormal pressure of work due to special circumstances,
where the employer cannot ordinarily be expected to resort to other
measures;
(d) To prevent loss or damage to perishable goods;
(e) Where the nature of the work requires continuous operations and the
stoppage of work may result in irreparable injury or loss to the employer;
and
(f) Under other circumstances analogous or similar to the foregoing as
determined by the Secretary of Labor and Employment.
*Premium pay = plus 30% of bdr

(a) Every worker shall be paid his regular daily wage during regular holidays, except in
retail and service establishment regularly employing less than ten workers;
(b) The employer may require an employee to work on any holiday but such employee
shall be paid a compensation equivalent to twice his regular rate;
R.A. 9492 (NO work Mondays for some holidays)
A. 12 Regular Holidays
New Year's Day
January 1
Maundy Thursday
Movable date
Good Friday
Movable date
Araw ng Kagitingan
April 9
Labor Day
May 1
Independence Day
June 12
National Heroes Day
Last Sunday of August
Bonifacio Day
Monday nearest November 30
Christmas Day
December 25
Rizal Day
Monday nearest December 30
Eidl Fotr and Eidl Adha follow the Islamic calendar and dates are announced by a
presidential proclamation
B.Nationwide Special Days
All Saints Day
Last Day of the Year

November 1
December 31

P.D. 1083, Title I, BK V

Article 169. Official Muslim holidays. The following are hereby recognized as legal
Muslim holidays:

(a) 'Amun Jadid (New Year), which falls on the first day of the first lunar month of
Muharram;
(b) Maulid-un-Nabi (Birthday of the Prophet Muhammad), which falls on the twelfth day
of the third lunar month of Rabi-ul-Awwal;
(c) Lailatul Isra Wal Mi'raj (Nocturnal Journey and Ascension of the Prophet
Muhammad), which falls on the twenty-seventh day of the seventh lunar month of Rajab;

(d) 'Id-ul-Fitr (Hari Raya Pausa), which falls on the first day of the tenth lunar month of
Shawwal, commemorating the end of the fasting season; and
(e) 'Id-ul-Adha (Hari Raja Haji), which falls on the tenth day of the twelfth lunar month of
Dhu 1-Hijja.

P.D. 1083, Title I, BK V

Article 170. Provinces and cities where officially observed.
(1) Muslim holidays shall be officially observed in the Provinces of Basilan, Lanao del
Norte, Lanao del Sur, Maguindanao, North Cotabato, Sultan Kudarat, Sulu, Tawi-Tawi,
Zamboanga del Norte and Zamboanga del Sur, and in the Cities of Cotabato, Iligan,
Marawi, Pagadian, and Zamboanga and in such other Muslim provinces and cities as
may hereafter be created.
(2) Upon proclamation by the President of the Philippines, Muslim holidays may also be
officially observed in other provinces and cities.
Article 171. Dates of observance. The dates of Muslim holidays shall be determined by
the Office of the President of the Philippines in accordance with the Muslim Lunar
Calendar (Hijra).

P.D. 1083, Title I, BK V

Article 172. Observance of Muslim employees.
(1) All Muslim government officials and employees in places other
than those enumerated under Article 170 shall also be excused
from reporting to office in order that they may be able to
observe Muslim holidays.
(2) The President of the Philippines may, by proclamation, require
private offices, agencies or establishments to excuse their Muslim
employees from reporting for work during a Muslim holiday
without reduction in their usual compensation.

Kinds of Holiday
REGULAR HOLIDAY

UNWORKED
100%

REGULAR HOLIDAY
AND REST DAY

100%

WORKED
1ST 8 hrs = 200%
Excess of 8 hrs =
plus 30% of hourly
rate on said day
1ST 8 hrs = plus 30%
of 200%
Excess of 8 hrs =
plus 30% of hourly
rate on said day

Kinds of Holiday

UNWORKED

WORKED

SPECIAL NON-WORKING
DAY/ SPECIAL PUBLIC
HOLIDAY/ SPECIAL
NATIONAL HOLIDAY/ Nov.
1 and Dec 31

No pay unless CBA

1ST 8 hrs = plus 30% of
provides or company policy brd
provides
Excess of 8 hrs = plus 30%
of hourly rate on said day

SPECIAL NON-WORKING
DAY/ SPECIAL PUBLIC
HOLIDAY/ SPECIAL
NATIONAL HOLIDAY/ Nov.
1 and Dec 31 and REST
DAY

No pay unless CBA

1ST 8 hrs = plus 50% of
provides or company policy bdr
provides
Excess of 8 hrs = plus 30%
of hourly rate on said day

SPECIAL WORKING HOLIDAYS for work performed, EE is

entitled only to his bdr.

 DOUBLE HOLIDAY: Two Regular Holidays on the same day

(Explanatory Bulleting of DOLE, April 9,1993 Good Friday
and Araw ng Kagitingan)
If unworked = 200%
If worked = 300%

If worked and also a rest day = plus 30% of the 300% = 390%

 SUCCESSIVE REGULAR HOLIDAY

EE may not be paid for both holidays if he
absents himself from work on the day
immediately the first holiday.
If he works on the first holiday, he is entitled
to his holiday pay for the second holiday

 (a) Every employee who has rendered at least one year of service
shall be entitled to a yearly service incentive leave of five days with
pay.

(b) This provision shall not apply to those who are already enjoying
the benefit herein provided, those enjoying vacation leave with pay
at least five days and those employed in establishments regularly
employing less than ten employees or in establishments exempted
from granting this benefit by the Secretary of Labor after considering
the viability or financial condition of such establishment.

(c) The grant of benefit in excess of that provided herein shall not be
made a subject of arbitration or any court of administrative action.

 (a) Every employee who has rendered at least one year of service
shall be entitled to a yearly service incentive leave of five days with
pay. [ONE YR OF SERVICE whether continuous or broken and
includes authorized absences and holidays]

(b) This provision shall not apply to those who are already enjoying
the benefit herein provided, those enjoying vacation leave with pay
at least five days and those employed in establishments regularly
employing less than ten (10) employees or in establishments
exempted from granting this benefit by the Secretary of Labor after
considering the viability or financial condition of such establishment.

(c) The grant of benefit in excess of that provided herein shall not be
made a subject of arbitration or any court of administrative action.
*piece-rate workers are excluded

1. Sick Leave and Vacation Leave are not

mandatory
2. Paternity Leave (R.A. 8187)
3. Maternity Leave (Art 133 Labor Code)
4. Battered Woman Leave (R.A. 9262)
5. Solo Parent Leave (R.A. 8972)

1.

"Solo parent" - any individual who falls under any of the following
categories:

2.

(1) A woman who gives birth as a result of rape and other crimes against
chastity even without a final conviction of the offender: Provided, That the
mother keeps and raises the child;

3.

(2) Parent left solo or alone with the responsibility of parenthood due to
death of spouse;

4.

(3) Parent left solo or alone with the responsibility of parenthood while the
spouse is detained or is serving sentence for a criminal conviction for at
least one (1) year;

5.

(4) Parent left solo or alone with the responsibility of parenthood due to
physical and/or mental incapacity of spouse as certified by a public
medical practitioner;

(5) Parent left solo or alone with the responsibility of parenthood due to
legal separation or de facto separation from spouse for at least one (1)
year, as long as he/she is entrusted with the custody of the children;
(6) Parent left solo or alone with the responsibility of parenthood due to
declaration of nullity or annulment of marriage as decreed by a court
or by a church as long as he/she is entrusted with the custody of the
children;
(7) Parent left solo or alone with the responsibility of parenthood due to
abandonment of spouse for at least one (1) year;
(8) Unmarried mother/father who has preferred to keep and rear
her/his child/children instead of having others care for them or give
them up to a welfare institution;

(9) Any other person who solely provides parental care

and support to a child or children;
(10) Any family member who assumes the responsibility of
head of family as a result of the death, abandonment,
disappearance or prolonged absence of the parents or
solo parent.
A change in the status or circumstance of the parent
claiming benefits under this Act, such that he/she is no
longer left alone with the responsibility of parenthood,
shall terminate his/her eligibility for these benefits.

Section 42. Ten-day paid leave in addition to other leave benefits. - At any time during the
application of any protection order, investigation, prosecution and/or trial of the criminal case, a
victim of VAWC who is employed shall be entitled to a paid leave of up to ten (10) days in
addition to other paid leaves under the Labor Code and Civil Service Rules and Regulations and
other existing laws and company policies, extendible when the necessity arises as specified in the
protection order. The Punong Barangay/kagawad or prosecutor or the Clerk of Court, as the case
may be, shall issue a certification at no cost to the woman that such an action is pending, and this is
all that is required for the employer to comply with the 10-day paid leave. For government
employees, in addition to the aforementioned certification, the employee concerned must file an
application for leave citing as basis R.A. 9262. The administrative enforcement of this leave
entitlement shall be considered within the jurisdiction of the Regional Director of the DOLE under
Article 129 of the Labor Code of the Philippines, as amended, for employees in the private sector,
and the Civil Service Commission, for government employees.
The availment of the ten day-leave shall be at the option of the woman employee, which shall
cover the days that she has to attend to medical and legal concerns. Leaves not availed of are
noncumulative and not convertible to cash.
The employer/agency head who denies the application for leave, and who shall prejudice the
victim-survivor or any person for assisting a co-employee who is a victim-survivor under the Act shall
be held liable for discrimination and violation of R.A 9262.

All service charges collected by hotels, restaurants

and similar establishments shall be distributed at
the rate of eighty-five (85%) percent for all
covered employees and fifteen (15%) percent for
management. The share of the employees shall be
equally distributed among them. In case the service
charge is abolished, the share of the covered
employees shall be considered integrated into their
wages

In case the service charge is abolished, the share of

the covered employees shall be considered
integrated in their wages. The basis shall be the
average monthly share of each EE for the part 12
months immediately preceding the abolition of the
charges.

 SECURITY OF TENURE Workers cannot be dismissed without

just and authorized causes and due process; workers shall be
made regular after 6 months probation
HOURS OF WORK Normal working hours of 8 hrs a day;
meal and rest periods; meal breaks of less than one hour and
short rest periods shall be considered compensable working
time
WEEKLY REST DAY A day-off of 24 consecutive hours after 6
days of work should be scheduled by the employer upon
consultation with the workers

- Minimum wage in the region/sector

- Holiday pay = one day pay for every regular holiday if unworked
subject to certain conditions
- Premium pay for work within 8 hours on a
SPECIAL/REST DAY = plus 30% of basic daily rate (bdr)
REST DAY FALLING ON A SPECIAL DAY = plus 50% of bdr
REST DAY FALLING ON A REG HOLIDAY = plus 50% of 200% of bdr
- Overtime pay for work in excess of 8 hrs on
ORDINARY DAYS = plus 25% of the basic hourly rate
SPECIAL/REST DAYS/HOLIDAYS = plus 30% of the regular hourly
rate on said days

BASIC RIGHTS OF WORKERS

 NIGHT SHIFT DIFFERENTIAL PAY = plus 10% of the

basic/regular rate for work between 10 PM to 6 AM
SERVICE INCENTIVE LEAVE = 5 days with pay for every year of
service
SERVICE CHARGES = 85% for distribution to rank-and-file
employees; 15% for losses, breakages, or distribution to
managerial employees (applicable only to establishments
collecting service charges)
13th MONTH PAY = 1/12 of the total basic salary earned
within the calendar year
PATERNITY LEAVE = 7 days with full pay to attend to the needs
of legal wife before/during/after delivery

 SEPARATION
PAY = Minimum
of month pay
for every year
of service for
authorized
causes of
separation

RETIREMENT PAY: 22.5 days

salary for every year of service
for optional retirement at 60
under RA 7641 or under
applicable agreement or for
compulsory retirement at 65.
FOR UNDERGROUND MINE
EES = optional retirement is 50
and compulsory is at 60 (RA
7641 as amended by RA 8558)

 PAYMENT OF WAGES
- Shall be paid in cash, legal tender at or near the place of work
- Through a bank upon written petition of majority of the workers
in establishments with 25 or more EEs and within 1 km radius
from a bank
- Paid directly to EEs
- Shall be given not less than once every two weeks or twice
within a month at intervals not exceeding 15 days
- Preference of workers money claims over government and
other creditors in case of bankruptcy or liquidation of business
- Labor-only contracting is prohibited and the so-called
contractor is considered merely as an agent of the ER

EMPLOYMENT OF WOMEN
*Nightwork prohibition unless allowed by the rules in
INDUSTRIAL UNDERTAKINGS from 10 pm to 6 am
COMMERCIAL/NON-INDUSTRIAL UNDERTAKINGS
from 12 MN to 6 AM
AGRICULTURAL UNDERTAKINGS, at night time unless
given not less than 9 consecutive hours of rest
WELFARE FACILITIES at the workplace such as seats, separate
toilet rooms, lavatories, dressing rooms
Prohibition against discrimination with respect to pay (i.e., equal
pay for work of equal value), promotion, training opportunities,
study and scholarship grants

EMPLOYMENT OF YOUNG WORKERS

Minimum employable age is 15 years.
A worker below 15 should be directly under the sole responsibility
of parents or guardians; work does not interfere with childs
schooling/normal development; with work permit from DOLE
No person below 18 can be employed in a hazardous or
deleterious undertaking

 SAFE AND HEALTHFUL CONDITIONS OF WORK AND WELFARE

SERVICES

Proper illumination and ventilations

Fire exits and extinguishers
Occupational health personnel and services
Family welfare/planning services in the workplace

 SELF-ORGANIZATION AND COLLECTIVE BARGAINING

LABOR EDUCATION THROUGH SEMINARS, DIALOGS AND
INFORMATION, EDUCATION AND COMMUNICATION
MATERIALS
PEACEFUL CONCERTED ACTIVITIES IN ACCORDANCE WITH
LAW
PARTICIPATION IN POLICY AND DECISION-MAKING
PROCESSES AFFECTING THEIR RIGHTS AND BENEFITS
FREE ACCESS TO THE COURTS AND QUASI-JUDICIAL BODIES
AND SPEEDY DISPOSITION OF THEIR CASES

ECC BENEFITS FOR WORK-RELATED CONTINGENCIES

Medical benefits for sickness/injuries
Disability benefits
Rehabilitation benefits
Death and funeral benefits
Pension benefits

SSS BENEFITS
Maternity
Sickness
Disability
Retirement
Death
Pension

OTHER PAID LEAVES

Solo Parents Leave (R.A. 8972 Solo Parents Act)
Battered Womans Leave (R.A. 9261- Anti Violence Against
Women and Children [Anti-VAWC Law])
Two months special leave with pay (R.A. 9710 Magna Carta
of Women [2009])

Source: Bureau of Working Conditions, DOLE

 Abad, Jr., Antonio H. (2011). (4th ed). Compendium on

labor law. 4th ed. Manila: Rex.

Azucena, Jr. A. C. (2010). (7th ed.). The labor code with
comments and cases. Manila: Rex.
Azucena, C.A., Jr. (2007). (5th ed.). Everyone's Labor
Code. Manila:Rex.
Rex case digest. (2006). Labor law and social legislation,
legal ethics, mercantile law. Quezon City: Rex.
Salao, Ernesto C. (2009). Law dictionary. Manila: Rex.