CHAPTER XII

TRANSBOUNDARY POLLUTION

A. Problem of Pollution
▪ Pollution cuts across national boundaries. Sometimes, pollution may originate
in one place and travel to the territorial boundaries of another state.
▪ For example, haze in one country in Southeast Asia could easily travel to a
neighboring country or countries. Oftentimes, this will require a joint or
concerted effort among affected countries in that region to contain the pollution.
▪ In addition to international response, the haze could also provide a private
cause of action for affected people and entities, necessitating the need for
determining the applicable law.
▪ The applicable law could be:
(1) the law from the state of the source of pollution,
(2) the law of a state where the pollution passes through,
(3) the law of the state where the impacts are felt, or
(4) an international treaty convention governs this problem, providing a remedy
for affected parties or a foundation from which the pollution may be abated
for well-being of member countries and their people.

B. Climate Change
▪ Defined as "a change of climate that is attributed directly or indirectly to human
activity that alters the composition of the global atmosphere and that is in
addition to natural climate variability observed over comparable time periods"
by the UNFCC or United Nations Framework Convention on Climate Change.

▪ On the other hand, the Intergovernmental Panel on Climate Change ("IPCC")

refers to climate change as any change in climate over time, whether due to
natural variability or as a result of human activity.
o IPCC is an international body established by the United Nations
Environment Programme ("UNEP") and the World Meteorological
Organization ("WMO") for the primary purpose of studying climate
change.
o In its latest Special Report, the IPCC warns policymakers that climate
change impacts are larger if global warming exceeds 1.5°C.
o Further, "on land, impacts on biodiversity and ecosystems, including
species loss and extinction, are projected to be lower at 1.5°C of global
warming compared to 2°C" and "limiting global warming to 1.5°C is
projected to reduce risks to marine biodiversity, fisheries, and
ecosystems, and their functions and services to humans."

1 | CONFLICT OF LAWS: Group 5 – Dimaculangan | Esteban | Leynes | Salud

 o This Special Report was issued after the entry into force of the Paris
Climate Agreement which targets a temperature increase and limit of
1.5°C.

▪ Climate change is already judicially recognized. Massachusetts v. EPA

declared that "the harms associated with climate change are serious and well
recognized."
▪ One of the causes of climate change is the use of fossil fuels. This can be
illustrated as follows:
(1) Fossil fuels have high carbon emissions that contribute to global warming.
(2) This warming brings with it weather disturbances, change in weather
patterns, and fiercer storms.
(3) Stronger storms cause devastating floods that severely affect small and
poor nations, most of whom could ill afford the impacts of climate change.

▪ This is unjust as these nations never caused climate change; however, they
feel the impacts more than the generators of climate change. There is,
therefore, an element of injustice in this climate dilemma when those suffering
huge damages are the innocent countries and not the guilty ones.

C. Paris Climate Agreement

▪ On December 12, 2015, countries across the globe entered into a treaty –
called Paris Climate Agreement or (“Agreement”), which is aimed at combating
climate change and limiting temperature increase.
▪ Foremost among its objectives is "holding the increase in the global average
temperature to well below 2 °C above pre-industrial levels and pursuing efforts
to limit the temperature increase to 1.5°C above pre-industrial levels."
▪ These targets were based on the findings of the IPCC.
▪ Key aspects of the Agreement include:
(a) provisions on long term (f) adaptation,
temperature goal, (g) loss and damage,
(b) global peaking and climate (h) technology and capacity-
neutrality, building support,
(c) mitigation, (i) education,
(d) sinks and reservoirs, (j) transparency,
(e) market and non-market- (k) compliance, and
based approaches, (l) global stocktake.

2 | CONFLICT OF LAWS: Group 5 – Dimaculangan | Esteban | Leynes | Salud

D. Climate Change Litigation
▪ From a conflict of laws perspective, climate change litigation is a very difficult
problem to resolve. Climate change has public and private international law
aspects.
▪ For those involving the relationship of nations, public international law governs.
▪ For conflicts involving the citizens of different countries, private international
law comes into play.
▪ For example, a citizen of a country devastated by a violent storm could sue an
oil company based in another country for damages to life and property. In
instances like this, it will be very difficult to assess the applicable law since
climate change may be caused in one country but the effects thereof could be
felt in another country.
o What justification could there be for the laws of one country located in
one continent to be applied in another country in another continent for
the determination of damages that could be assessed against the
guilty party? Another confounding issue is the suability of corporations
which, as held in Jesner v. Arab Bank, could not be held liable for
violations of international law.
o There must also be a realization that environmental laws are entitled to
a more liberal interpretation for them to work. Applying the traditional
approach utilized in torts, like the concepts of causation and
redressability, would ultimately weaken the system of compensation
provided in environmental laws.

Illustrative Case:

Georgia v. Tennessee Copper Co.

206 U.S. 230 (1907)

The State of Georgia filed a bill alleging that in consequence of a discharge of noxious
gases by Tennessee Copper Company (Copper) a wholesale destruction of forests, orchards, and
crops was going on, and other injuries were done and threatened in five of its counties. Georgia
filed a motion for a preliminary injunction to enjoin defendant companies from discharging
noxious gases to its territory. This was, however, denied.

Whether or not Georgia is entitled to injunction. YES.

1. This is a suit by a state for an injury to it in its capacity of quasi-sovereign. In that capacity
the state has an interest independent of and behind the titles of its citizens, in all the earth
and air within its domain.

3 | CONFLICT OF LAWS: Group 5 – Dimaculangan | Esteban | Leynes | Salud

 2. It is a fair and reasonable demand on the part of a sovereign that the air over its territory
should not be polluted on a great scale by sulphurous acid gas, that the forests on its
mountains, be they better or worse, and whatever domestic destruction they have suffered,
should not be further destroyed or threatened by the act of persons beyond its control, that
the crops and orchards on its hills should not be endangered from the same source.
3. In the case, it is not denied that the defendants generate in their works near the Georgia line
large quantities of sulphur dioxide which becomes sulphurous acid by its mixture with the
air. It hardly is denied, and cannot be denied with success, that this gas often is carried by
the wind great distances and over great tracts of Georgia land. On the evidence the pollution
of the air and the magnitude of that pollution are not open to dispute.
4. Injunction to issue.

E. Approaches to Transboundary Pollution

1. Governmental interest analysis

▪ This approach indulges courts to consider governmental interests when two
or more states have conflicting laws and interests.
▪ It is important to consider the interest of other states since commercial
transactions involve people located in several jurisdictions which have
conflicting interests in a transaction.
▪ This interest may have been a motivating factor in the agreement of the
parties and so should be properly considered.
▪ In torts cases, too, a state may have an interest in the dispute due to its
closer connection to the parties. Hence, the need to favor its laws over those
of another state.
▪ The governmental analysis approach involves the following steps:
(a) The court determines whether the relevant law of the affected
jurisdictions with regard to the issue in question is the same or different;
(b) If there is a difference, the court examines each jurisdiction's interest in
the application of its own law to determine whether a true conflict exists;
(c) If the court finds that there is a true conflict, it carefully evaluates and
compares the nature and strength of the interest of each jurisdiction to
determine which state's interest would be more impaired if its policy were
subordinated to the policy of the other state.

2. Lex loci delicti

▪ This calls for the application of the law of the place where the damage is
suffered or inflicted.

4 | CONFLICT OF LAWS: Group 5 – Dimaculangan | Esteban | Leynes | Salud

 ▪ It looks to the domestic law of a state which shall be applied to polluting
activities whose sources are foreign. Hence, so long as the effects are felt
locally even if the source comes from outside the country, domestic law may
be applied to govern the act complained of.

3. Most significant relationship approach

▪ The law of the state which has the most connection shall be applied in the
resolution of the conflict.
▪ The points of contact are:
(a) The place where the injury occurred;
(b) The place where the conduct causing the injury occurred;
(c) The domicile, residence, nationality, place of incorporation, and place of
business of the parties; and
(d) The place where the relationship, if any, between the parties is centered.

Illustrative Case:

Pakootas v. Teck Cominco Metals, Ltd.

452 F.3d 1066 (2006)

Teck operates a lead-zinc smelter in Trail, British Columbia, which generated and
disposed of hazardous materials into the Columbia River located in the United States. The
Environmental Protection Agency issued an order directing Teck to conduct a Remedial
Investigation/Feasibility Study under the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) for site contamination.

Teck did not comply with the Order, so Pakootas filed a citizen suit in federal district
court to force Teck to comply with the Order. Teck moved to dismiss on the ground that
CERCLA has no extraterritorial application and that the United States has no jurisdiction over
Teck, it being a Canadian corporation not operating in the United States. The court denied
Teck’s motion to dismiss.

Whether the application of CERCLA to Teck involves an extraterritorial application of a

domestic law of the United States. NO.

1. This case involves a domestic application of CERCLA. The location where a party arranged
for disposal or disposed of hazardous substances is NOT controlling for purposes of
assessing whether CERCLA is being applied extraterritorially, because CERCLA imposes
liability for releases or threatened releases of hazardous substances and not merely for
disposal or arranging for disposal of such substances.

5 | CONFLICT OF LAWS: Group 5 – Dimaculangan | Esteban | Leynes | Salud

 2. Applying CERCLA to the Site is a domestic application of CERCLA. The argument that
this case presents an extraterritorial application of CERCLA fails because CERCLA liability
does not attach until there is an actual or threatened release of hazardous substances into the
environment. The suit concerns actual or threatened releases of heavy metals and other
hazardous substances into the Upper Columbia River Site within the United States.

The Pakootas case is significant as it reinforces a state’s resolve to clean up its

environment even if the source of the pollution is from another country. This is a multi-
state event and not an extra-territorial application of domestic law. There is now a link
that allows domestic law to regulate a polluting activity which is coming from outside the
border. Hence, the polluting entity can be held liable because if its operations extend
outside a country’s boundaries, it is reasonable for it to expect that it will be held liable for
its polluting activity.

Illustrative Case:

Nnadili v. Chevron USA, Inc.

435 F.Supp.2d 93 (2006)

Plaintiffs, current and former owners/residents of Riggs Park neighborhood in

Washington, D.C., sued Chevron for having operated a gasoline station in Chillum, Maryland,
which is near the border between Maryland and Washington, D.C. Plaintiffs claimed that the
gas station’s operation contaminated the air, soil, and groundwater of the properties currently or
formerly owned or occupied by plaintiffs, resulting in the diminished values of their properties.
Chevron filed a motion for summary judgment with the district court.

Whether the Maryland law or the District of Columbia law governs plaintiffs’ claims.

District of Columbia law applies.

1. When deciding state-law claims under diversity or supplemental jurisdiction, federal courts
apply the choice-of-law rules of the jurisdiction in which they sit. The District of Columbia
has adopted the "substantial interest" approach to choice of law questions. When faced with
a choice of law in an action sounding in tort, a court in the District of Columbia will "balance
the competing interests of the two jurisdictions, and apply the law of the jurisdiction with
the more `substantial interest' in the resolution of the issue.
2. To determine which jurisdiction maintains a more substantial interest, District of Columbia
courts consider the factors listed in Section 145 of the Restatement (Second) of Conflict of
Laws (1971). These include: (1) the place of injury; (2) the place where the conduct causing
the injury occurred; (3) the domicile, residence, place of incorporation and place of business
of the parties; and (4) the place where the relationship between the parties is centered.

6 | CONFLICT OF LAWS: Group 5 – Dimaculangan | Esteban | Leynes | Salud

 3. Applying these factors to the instant facts, the District of Columbia has the greater interest
in the outcome of this litigation. While Chevron's conduct occurred mainly in Maryland,
where its former service station and USTs are situated, and a handful of plaintiffs currently
reside in that state, all of the alleged contamination at issue in this litigation occurred in
the District of Columbia, all of the alleged injuries were sustained in the District of
Columbia, and the overwhelming majority of plaintiffs still reside in the District of
Columbia. Accordingly, the Court concludes that all of the tort claims asserted in these
consolidated cases are governed by the laws of the District of Columbia.

7 | CONFLICT OF LAWS: Group 5 – Dimaculangan | Esteban | Leynes | Salud

 CHAPTER XIII
INTELLECTUAL PROPERTY

A. Conflict in Intellectual Property Rights

Conflict of law problems in intellectual property are common since intellectual

property rights are infringed beyond the territory of registration. The Internet has made
intellectual property protection complicated since violation can occur in cyberspace
across national boundaries. When this occurs the laws of different states may find
application to the problem.
The problem arises when foreign laws differ from domestic laws on intellectual property.

It is stated in most intellectual property textbooks that intellectual property rights

may be enforced across borders, however the same is only true when both foreign law
and domestic law are the same or similar to one another. In truth, the IP owner’s rights
are only limited to what is provided under domestic law since it would be difficult to apply
for protection with the courts of a foreign country.

B. Intellectual Property Code and International Conventions

The national treatment provisions of the Paris Convention, Berne Convention,

TRIPS (Trade-Related Aspects of Intellectual Property Rights), and the Intellectual
Property Code, are starting points in solving conflict of law problems in intellectual
property law.

The national treatment principle is the grant of reciprocal rights to citizens of states
who are signatories to international conventions.

Section 3 of the Intellectual Property Code of the Philippines embodies the concept
of national treatment.

SECTION 3. International Conventions and Reciprocity. ‑ Any person who is a

national or who is domiciled or has a real and effective industrial establishment in
a country which is a party to any convention, treaty or agreement relating to
intellectual property rights or the repression of unfair competition, to which the
Philippines is also a party, or extends reciprocal rights to nationals of the
Philippines by law, shall be entitled to benefits to the extent necessary to give effect
to any provision of such convention, treaty or reciprocal law, in addition to the rights
to which any owner of an intellectual property right is otherwise entitled by this Act.

The national treatment principle bars the extraterritorial application of foreign

copyright laws for it mandates the application of local laws for the equal treatment of the
rights of foreigners. This concept, however, does not resolve conflict of law issues in
intellectual property. National treatment simply mandates that the same treatment be

8 | CONFLICT OF LAWS: Group 5 – Dimaculangan | Esteban | Leynes | Salud

given to nationals of contracting parties to international conventions. It does not answer
the question of what law to apply or what approach to utilize to harmonize conflicting laws.

Illustrative Case:

Bridgeman Art Library v. Corel Corporation

36 F. Supp. 2d 191

Plaintiff Bridgeman Art Library is a company based in New York primarily involved in
possessing and managing public domain works of art owned by museums and collections.
Bridgeman distributed licensing arrangements to clients for the works of art. Defendant Corel
Corporation is a company based in the UK in the business of selling digitized images of paintings
and works of art. Bridgeman sued Corel for copyright infringement over certain photographic
transparencies of famous paintings distributed through CD-ROMs. The District Court dismissed
plaintiff’s complaint for infringement through defendant’s motion for summary judgment.
Bridgeman filed a motion for reconsideration.

Whether the Copyright Act or the Berne Convention is the source of plaintiff’s claim to
copyrightability of its works.

Copyright Act is the source of plaintiff’s claims.

1. In most circumstances, choice of law issues do not arise under the Berne and Universal
Copyright Conventions. Each adopts a rule of national treatment.
2. Under the Berne Convention, a holder of a British copyright who sues for infringement in a
US court is entitled to the same remedies as holders of US copyrights, and as previously
held, to the determination of infringement under the same rule of law.
3. It is important to note that the Berne Convention is not self-executing. While the Copyright
Act extends certain protection to the holders of copyright in Berne Convention, the
Copyright Act is the exclusive source of that protection, hence it is the source of plaintiff’s
claim to copyrightability of its works.

Illustrative Case:

Subafilms, Ltd. V. MGM-Pathe Communications Co.

24 F.3d 1088 (1994)

The Beatles, through Subafilms, entered into a joint venture with Hearst Corporation to
produce “Yellow Submarine”, an animated motion picture. Hearst, acting on behalf of the joint
venture, negotiated an agreement with United Artists Corporation (UA) to distribute and finance
the film. Several licensing agreements were entered by UA for the distribution of films on
videocassettes. UA however refused to license “Yellow Submarine.”

9 | CONFLICT OF LAWS: Group 5 – Dimaculangan | Esteban | Leynes | Salud

 UA was subsequently acquired by MGM/UA Communications Co. and it notified
Warner Bros. that it may now commence international distribution. Warner started distributing
the videocassettes internationally. Subafilms and Hearst sued MGM/UA and Warner contending
that the distribution of “Yellow Submarine” constitutes copyright infringement.

Whether respondents MGM Communications Co. are liable for copyright infringement.

NO, the Copyright Act has no extraterritorial application.

1. It is a long-standing principle under American law that legislation of Congress, unless a

contrary intent appears, is meant to apply only within the territorial jurisdiction of the United
States.
2. The “undisputed axiom” that the US copyright laws have no application to extraterritorial
infringement predates the 1909 Act, and under the principle of territoriality, has no
jurisdiction beyond the territorial jurisdiction of the United States.
3. The Congress, if so inclined, has the power to overturn the preexisting doctrine that
infringing acts that take place wholly outside the US are not actionable under the Copyright
Act.
4. It is inappropriate for the courts to act in a manner that might disrupt Congress’s efforts to
secure a more stable international intellectual property regime unless Congress otherwise
clearly has expressed its intent.
5. The Court reaffirms that the US copyright laws do not reach acts of infringement that take
place entirely abroad for it is the Congress, and not the courts, to take the initiative in this
field.

C. Approaches to IP Conflicts of Law (TeMoLePu)

1. Territoriality Approach
• Considered as the basic approach
• Entails that laws have no extraterritorial application
o Reason: Since numerous IP conventions refer to national laws as their
point of focus, it has become the better practice to apply IP laws within
the territorial boundaries of a state

10 | CONFLICT OF LAWS: Group 5 – Dimaculangan | Esteban | Leynes | Salud

 Illustrative Case:

Allarcom Pay Television Ltd. V

General Instrument Corp. and Showtime Networks Inc.
69 F.3d 381 (1995)

Plaintiff Allarcom is authorized by the Canadian government to be the exclusive

provider of English-language subscription television programming in Western Canada. It
obtained the exclusive right from producers such as Paramount and Touchstone to exhibit their
movies on TV in Allarcom’s territory. Through the use of a decoder device, defendants General
Instruments and Showtime Networks were able to transmit their signal to Canada that allowed
some programs in the US to be broadcasted in Canada which again, was Allarcom’s exclusive
territory. Hence, Allarcom sued for copyright infringement under the Federal Copyright Act
(FCA).

Does the Federal Copyright Act have extraterritorial application? NO.

1. For a US copyright law to apply, at least one alleged infringement must be completed
entirely within the US, and that mere authorization of extraterritorial infringement was not
a completed act of infringement in the US.
2. General Instrument and Showtime Networks either initiated a potential infringement in the
US by broadcasting the Showtime signal, which contained copyright material, or defendants
authorized people in Canada to engage in infringement.
3. In either case, the potential infringement was only completed in Canada once the signal was
received and viewed. Accordingly, US copyright law did not apply, and therefore did not
preempt Allarcom’s state law claims.

2. Most Significant Relationship

• Applies the law of the state that has the most significant relationship to the
parties to the case; said law is applied in the resolution of the conflict
• Answers to the need of modern litigation where there is difficulty of locating
the place of injury
• Appropriate to those cases involving transnational acts or those cases where
an act may be happening or being committed in several states at the same
time, ex: cyber offenses
• The points of contract as provided in the Restatement of Conflict of Laws
include the following:
o The place where the injury occurred
o The place where the conduct causing the injury occurred
o The domicile, residence, nationality, place of incorporation and place of
business of the parties
o The place where the relationship, if any, between the parties is centered

11 | CONFLICT OF LAWS: Group 5 – Dimaculangan | Esteban | Leynes | Salud

 Illustrative Case:

Itar-Tass Russian News Agency v Russian Kurier Inc.

153 F.3d 82 (1998)

Defendant Russian Kurier Inc. is a company which publishes The Kurier, a Russian
language weekly newspaper published in New York. Meanwhile plaintiff Itar-Tass Russian
News Agency publishes major Russian language newspapers and magazines in Russia and in
Israel. Plaintiff alleges that defendant copied about 500 articles that first appeared in the
plaintiff’s publications without their consent. It was further alleged that defendant has also
reproduced and published pictures, bylines, and graphics owned by plaintiffs. The District Court
ruled in favor of the plaintiff, recognizing in the newspaper publishers exclusive rights to the
articles.

Which between the Russian law or the US law governs ownership rights and
infringement issued?

Russian law applies to ownership issues while US law governs infringement issues.

1. Copyright is a form of property, and the usual rule is that the interests of the parties in
property are determine by the law of the state with the most significant relationship to the
property and the parties. Since the works at issue were created by Russians and first
published in Russia, Russian law is the appropriate source of law to determine issues of
ownership of rights.
2. Selection of Russian law to determine copyright ownership is subject to one procedural
qualification. Under the US law, an owner may sue for infringement in a US court only if it
meets the standing test of 17 USC Sec 501(B), which accords standing only to the legal or
beneficial owner of an exclusive right.
3. On infringement issues, the governing conflicts principle is usually lex loci delicti, the
doctrine generally applicable to torts. In this case, the place of torts is plainly the US. To
whatever extent lex loci delicti is to be considered only one part of a broader interest
approach, US law would still apply to infringement issues, since not only is this country the
place of tort, but also the defendant is a US corporation.

3. Lex Loci Delicti

• Provides that the state where the damage or injury is sustained has as much
interest in redressing the wrongs committed within its jurisdiction
• Traditional rule that employs the law of the place of injury
• Requires the application of the law of the state where the tort is committed as
such act offers simplicity, ease of application, and stability and predictability
in judicial decisions
• Based on the vested rights doctrine since the rights of the parties are vested
in the place of injury and nowhere else

12 | CONFLICT OF LAWS: Group 5 – Dimaculangan | Esteban | Leynes | Salud

 • When someone is wronged in a particular place, the rights of the parties arise
from that jurisdiction whose law must then be applied to determine the parties’
rights and liabilities
• The problem with the traditional approach of lex loci delicti – it is harsh and
inflexible; it does not answer to the complexities of modern litigation
o Scenario: when infringement happens in cyberspace, or where the injury
is felt in several jurisdictions, it will be extremely difficult to localize the
place of commission of the tort

4. Public Policy Exception

• Provides that when the application of a foreign law conflicts with an
established policy of the forum, the foreign law may not be applied as being
anathema to public policy

Illustrative Case:

Sarl Louis Feraud International and

SA Pierre Balmain v Viewfinder, Inc.
489 F.3d 474 (2007)

Plaintiffs Feraud and Balmain are French corporations that design high-fashion clothing
pieces for women. Defendant Viewfinder, a Delaware corporation with a principal place of
business in New York, operates an internet fashion magazine website on which it posts
photographs of international fashion shows including those of the plaintiffs.

A French court found Viewfinder liable for copyright infringement when it published in
its online magazine photographs of plaintiffs’ fashion shows without their consent. Such finding
was upheld on appeal by another French court. Plaintiffs then filed a case for enforcement with
the district court in New York, which was dismissed on the ground that enforcement would be
repugnant to the public policy of New York. The district court held that the fashion shows were
public events; hence, under its First Amendment right, Viewfinder is free to take photographs
and to publish the same.

Is the enforcement of the French courts’ decision violative of New York’s public policy?

It will be violative if enforcement will be repugnant to the First Amendment. Judgment

of the district court is vacated and remanded for further proceedings.

1. The “public policy inquiry rarely results in refusal to enforce a judgment unless it is
inherently vicious, wicked or immoral, and shocking to the prevailing moral sense.” It is
well established that mere divergence from American procedure does not render a foreign
judgment unenforceable. Under New York law, foreign decrees and proceedings will be
given respect even if the result under the foreign proceeding would be different than under
American law.

13 | CONFLICT OF LAWS: Group 5 – Dimaculangan | Esteban | Leynes | Salud

 2. Laws that are antithetical to the First Amendment will create such a situation. Foreign
judgments that impinge on these rights will be found to be repugnant to public policy.
3. The district court’s decision appears to rest on the assumption that if Viewfinder is a news
magazine reporting on a public event, then it has an absolute First Amendment defense to
any attempt to sanction such conduct. The First Amendment does not provide such
categorical protection. Intellectual property laws co-exist with the First Amendment in the
US, and the fact that an entity is a news publication engaging in speech activity does not,
standing alone, relieve such entities of their obligation to obey IP laws.
4. Absent extraordinary circumstances, the fair use doctrine encompasses all claims of first
amendment in the copyright field. Because this doctrine balances the competing interests of
the copyright laws and the First Amendment, some analysis of that doctrine is needed before
a court can conclude that a foreign copyright judgment is repugnant to public policy.

Reference:

Pe Benito, Galahad R. A. Conflict of Laws. 2020 ed. (Manila, Philippines: Rex Book Store, 2021).

--o0o--

14 | CONFLICT OF LAWS: Group 5 – Dimaculangan | Esteban | Leynes | Salud