Download as pdf or txt
Download as pdf or txt
You are on page 1of 60

CHAPTER 2

NATURE AND EFFECTS


OF OBLIGATIONS
(PREPARED BY ATTY. RJ ILIGAN TAKEN FROM THE BOOK OF BALLADA)
ARTICLE 1163
EVERY PERSON OBLIGED TO GIVE
SOMETHING IS ALSO OBLIGED TO TAKE
CARE OF IT WITH THE PROPER DILIGENCE
OF A GOOD FATHER OF A FAMILY, UNLESS
THE LAW OR THE STIPULATION OF THE
PARTIES REQUIRES ANOTHER STANDARD
OF CARE.
ARTICLE 1163
OBJECT OR PRESTATION:
v 2 KINDS OF PRESTATIONS:
1. REAL OBLIGATION (to give) – Article 1163 to 1166
2. PERSONAL OBLIGATION (to do or not to do) –
Article 1167 to 1168
vThere are 3 Prestation in an Obligation:
1. TO GIVE (OBLIGATION TO GIVE)
2. TO DO (OBLIGATION TO DO)
3. NOT TO DO (OBLIGATION NOT TO DO)
ARTICLE 1163
vIn obligation to give, the THING may either be:
1. DETERMINATE or SPECIFIC – particularly designated or
physically segregated from the class
2. INDETERMINATE or GENERIC – designated by class or
genus without designation or physical segregation.

Article 1163 talks about an OBLIGATION TO GIVE A


DETERMINATE or SPECIFIC THING
ARTICLE 1163
v According to Art. 1163 a person obliged to deliver or
give a specific thing (Debtor, Obligor or Passive Subject)
has to take of the thing with DILIGENCE.
v DILIGENCE – attention and care required of a person
in a given situation.
v 3 KINDS OF DILIGENCE UNDER THE LAW:
1. EXTRAORDINARY – extreme measure of care and caution
2. ORDINARY – “Diligence of a Good Father of a Family”
3. SLIGHT DILIGENCE or SLIGHT CARE – less or no prudence
ARTICLE 1163
v DILIGENCE OF A GOOD FATHER OF FAMILY
• Ordinary Diligence
• Diligence required of person obliged to deliver a
determinate thing
• An accepted notion that a FATHER will never put his
family at risk
• The obligor/Debtor/Passive subject should take care of
it as his own determinate thing
ARTICLE 1163
v HOW TO DETERMINE THE DILIGENCE REQUIRED:
1. PROVISION OF LAW – Article 1173 of Civil Code;
common carrier required extraordinary diligence due
to public safety and public policy.
2. STIPULATION OF PARTIES – Standard of care other
than ORDINARY DILIGENCE; NO DILIGENCE (NOT
ALLOWED)
3. ABSENCE OF STIPULATION – ordinary diligence
WHAT ARE THE OBLIGATION OF A PERSON WHO
IS REQUIRED TO GIVE SOMETHING?
1. TO PRESERVE and TAKE GOOD CARE OF THE
THING LIKE A DILIGENCE OF A GOOD FATHER
UNLESS THE PARTIES AGREED TO ANOTHER
STANDARD OF CARE. (ART. 1163)
2. TO DELIVER THE THING INCLUDING THE FRUITS
OF THE THING. (ART. 1164)
3. TO DELIVER THE ACCESSIONS and ACCESSORIES
OF THE THING. (Art. 1166)
ARTICLE 1164
THE CREDITOR HAS THE RIGHT TO THE
FRUITS OF THE THING FROM THE TIME THE
OBLIGATION TO DELIVER ARISES.
HOWEVER, HE SHALL ACQUIRE NO REAL
RIGHT OVER IT UNTIL THE SAME HAS BEEN
DELIVERED TO HIM.
ARTICLE 1164
KINDS OF FRUITS:
1. NATURAL FRUITS – spontaneous products of the soil,
and the young, and other products of animals. Examples
are plants and trees that grow without human
intervention.
2. INDUSTRIAL FRUITS - are those produced by lands of
any kind through cultivation or labor.
3. CIVIL FRUITS – rents of building or other properties.
ARTICLE 1164
PERSONAL and REAL RIGHTS:
1. PERSONAL RIGHTS or JUS in PERSONAM – is a power
demandable by one person of another to GIVE, TO DO,
or NOT TO DO.
2. REAL RITGHTS or JUS in RE – power over a specific
thing and is binding on the whole world.
ARTICLE 1164
CREDITOR’S/OBLIGEE/ACTIVE SUBJECT’S RIGHTS
TO THE FRUITS (as well as the THING):
v PERSONAL RIGHT from the TIME the obligation
to deliver it arises. (WHEN?)

v REAL RIGHT upon delivery to him


ARTICLE 1164
KINDS OF DELIVERY:
1. ACTUAL DELIVERY (Tradition) – property changes hands physically.
2. CONSTRUCTIVE – Physical Transfer is implied.
a) Tradition Symbolica (Symbolical Tradition)
b) Traditio Longa Manu ( mere consent or pointing out)
c) Traditio Brevi Manu (Short hand) - from possessor non – owner
to Possessor owner
d) Traditio Constitutum Possessorium – from possessor owner to
possessor Non – owner.
e) Tradition by Execution of Legal Forms
HOW DELIVERY IS MADE?
WHEN THE OBLIGATION TO DELIVER ARISES:
1. IF WITH A TERM or AGREEMENT – when the
term arrives or the condition happens.
2. IF WITH NO TERM or AGREEMENT – Perfection
of the Contract. PERFECTION (meeting of the
minds of the parties involved)
ARTICLE 1165
When what is to be delivered is a DETERMINATE THING, the
Creditor, in Addition to the Rights granted him by Article 1170,
may compel the debtor to make delivery.

If the thing is. INDETERMINATE or GENERIC, he may ask that the


obligation be complied with at the expense of the debtor.

If the obligor delays, or has promised to deliver the same thing


to 2 or more persons who does not have the same interest, he
shall be liable for fortuitous event until he effected delivery
ARTICLE 1165
RIGHTS OF THE CREDITOR, OBLIGEE, ACTIVE SUBJECT IF
DEBTOR/OBLIGOR/PASSIVE SUBJECT FAILES TO DELIVER: (First and Second
Paragraph)
1. IF THING IS DETERMINATE –
a) Compel the Debtor to make delivery. (SPECIFIC PERFORMANCE)
b) Demand DAMAGES from Debtor is he is guilty of FRAUD, NEGLIGENCE,
DELAY, or CONTRAVENTION OF AGREEMENT (ARTICLE 1170)
2. IF THE THING IS INDETERMINATE –
a) Ask for compliance of the obligation either by debtor or 3rd person at
DEBTOR’S EXPENSE. Demand a replacement which no of inferior or superior
quality.
b) Demand DAMAGES from Debtor is he is guilty of FRAUD, NEGLIGENCE, DELAY,
or CONTRAVENTION OF AGREEMENT (ARTICLE 1170)
ARTICLE 1165 IF THE OBLIGOR DELAYS, OR HAS PROMISED TO DELIVER THE SAME
THING TO 2 OR MORE PERSONS WHO DOES NOT HAVE THE SAME INTEREST, HE SHALL BE
LIABLE FOR FORTUITOUS EVENT UNTIL HE EFFECTED DELIVERY (THIRD PARAGRAPH)

FORTUITOUS EVENT:
v Definition: EVENT WHICH COULD NOT BE FORESEEN OR WHICH THOUGH FORESEEN
WERE INEVITABLE. (ACT OF GOD or ACT OF MAN/Force Majeure)
v Rules:
1. An obligation to deliver a DETERMINATE or SPECIFIC THING is EXTINGUISHED
BY FORTUITOUS EVENT.
Ø EXCEPT:
1. OBLIGOR DELAYS – LEGAL DELAY (with DEMAND)
2. OBLIGOR PROMISED TO DELIVER THE SAME THING TO TWO OR MORE PERSONS WHO DO
NOT HAVE THE SAME INTEREST. (BAD FAITH)
2. An obligation to deliver an INDTERMINATE or GENERIC THING is NOT
EXTINGUISHED BY A FORTUITOUS EVENT for GENUS NEVER PERISHES
ARTICLE 1166
THE OBLIGATION TO GIVE A
DETERMINATE THING INCLUDES THAT
OF DELIVERING ALL ITS ACCESSIONS
AND ACCESSORIES, EVEN THOUGH THEY
HAVE NOT HAVE BEEN MENTIONED.
(unless stipulated)
ARTICLE 1166
1. ACCESSIONS – PRODUCED by the thing which is the
object of the obligation as well as all of those which are
naturally or artificially attached thereto; (Natural,
Industrial, and Civil Fruits/Planted, built, and sown on
land)
2. ACCESSORIES – object of embellishment, use of
preservation of another thing which is more important
and to which not incorporated or attached. (key,
equipment, or tools)
ARTICLE 1167
IF PERSON OBLIGED TO DO SOMETHING FAILS TO DO
IT, IT SHALL BE EXECUTED AT HIS COST.

THE SAME RULE SHALL BE OBSERVED IF HE DOES IT


IN CONTRAVENTION OF THE TENOR OF OBLIGATION.

FURTHERMORE, IT MAY BE DECREED THAT WHAT HAS


BEEN POORLY DONE BE UNDONE.
ARTICLE 1167
v REFERS TO A PERSONAL POSITIVE OBLIGATION (TO DO)
v REMEDIES OF THE CREDITOR:
1. DEBTOR FAILS TO PERFORM HIS OBLIGATION
a) TO have the obligation performed or executed by debtor himself or by a
Third party if possible at Debtor’s expense
EXCEPTION: NO INVOLUNTARILY SERVITUDE OR IF PERSONAL
QUALIFICATION IS THE CONSIDERATION
b) To claim DAMAGES if with FIMVU (Article 1170)

2. CONTRARY TO WHAT WAS STIPULATED or POORLY DONE


a) TO have the obligation performed or executed by debtor himself or by a
Third party if possible at Debtor’s expense
b) To claim DAMAGES if with FIMVU (Article 1170)
ARTICLE 1168
WHEN THE OBLIGATION CONSISTS IN
NOT DOING, AND THE OBLIGOR DOES
WHAT HAS BEEN FORBIDDEN HIM, IT
SHALL ALSO BE UNDONE AT HIS
EXPENSE.
ARTICLE 1168
v REFERS TO A PERSONAL NEGATIVE
OBLIGATION (NOT TO DO)

v REMEDIES OF THE CREDITOR:


1.TO UNDONE WHAT HAS BEEN DONE
2.To claim DAMAGES if with FIMVU (Article
1170)
ARTICLE 1169
(PARAGRAPH 1)
THOSE OBLIGED TO DELIVER OR TO
DO SOMETHING INCUR IN DELAY
FROM THE TIME THE OBLIGEE
JUDICIALLY OR EXTRAJUDICIALLY
DEMANDS FROM THEM THE
FULFILLMENT OF THEIR OBLIGATION.
ARTICLE 1169 (PAR.1)
v 2 kinds of DELAY:
1. ORDINARY DELAY – Is the failure to perform an
obligation on time. This does not constitute breach.
2. LEGAL DELAY – DEFAULT or MORA; Failure to
perform an obligation on time which constitute
breach of the obligation. (Article 1169 onwards)
• Can make the delayed party liable for interest and
possible damages
ARTICLE 1169 (PAR.1)
v 2 kinds of DEFAULT or MORA (LEGAL DELAY):
1. MORA SOLVENDI – delay on the part of
DEBTOR/OBLIGOR/PASSIVE SUBJECT to perform his
obligation:
• ex re (delay in obligation to give)/ ex persona (delay
in obligation to do)
2. MORA ACCIPIENDI – delay on the part of
CREDITOR/OBLIGEE/ACTIVE SUBJECT to ACCEPT
delivery of the thing object or obligation.
3. COMPENSATIO MORAE – Delay of the parties or
obligors in reciprocal obligations.
ARTICLE 1169 (PAR.1)
v IN ORDER TO BE CONSIDERED IN DELAY OR MORA:

THERE HAS TO BE DEMAND JUDICIALLY and


EXTRAJUDICIALLY
ARTICLE 1169
(PARAGRAPH 2.1)
HOWEVER, THE DEMAND BY THE
CREDITOR SHALL NOT BE NECESSARY
IN ORDER THAT DELAY MAY EXIST:
1. When the obligation or the law
expressly so declares; or
ARTICLE 1169
(PARAGRAPH 2.2)
2. When from the NATURE and
CIRCUMSTANCE of the obligation it
appears that the designation of the time
when the thing is to be delivered or the
services is to be rendered was a
CONTROLLING MOTIVE FOR THE
ESTABLISHMENT OF THE CONTRACT; or
ARTICLE 1169
(PARAGRAPH 2.3)

3. When Demand would be useless, as


when the obligor has rendered it
beyond his power to perform.
ARTICLE 1169
(PARAGRAPH 3)
IN RECIPROCAL OBLIGATIONS, NEITHER
PARTY INCURS IN DELAY IF THE OTHER
DOES NOT COMPLY OR IS NOT READY TO
COMPLY IN A PROPER MANNER WITH
WHAT IS INCUMBENT UPON HIM. FROM
THE MOMENT ONE OF THE PARTIES
FULFILLS HIS OBLIGATION, DELAY BY THE
OTHER BEGINS.
ARTICLE 1169 (PAR.3)
v RECIPROCAL OBLIGATION – fulfillment of an
obligation by one party depends upon the
fulfillment of the obligation by both parties in
simultaneous.
v One must comply so that the other party may be
in delay or default.
ARTICLE 1170
THOSE IN THE PEFORMANCE OF THEIR
OBLIGATIONS ARE GUILTY OF FRAUD,
NEGLIGENCE, or DELAY and THOSE IN
ANY MANNER CONTRAVEN THE TENOR
THEREOF, ARE LIABLE FOR DAMAGES.
ARTICLE 1170
v GROUNDS FOR DAMAGES:
1. FRAUD or DOLO
2. NEGLIGENCE or CULPA
3. DELAY or MORA
4. CONTRAVENTION OF TERM OF THE AGREEMENT
• ILLICIT ACTS and DEFECTIVE PERFORMANCES
ARTICLE 1170
v KINDS DAMAGES: (BOOK IV TITLE XVIII OF CC)
1. ACTUAL or COMPENSATORY (art 2205)
2. MORAL (Art 2217 to 2220)
3. NOMINAL – sometimes in absence of actual D
4. TEMPERATE or MODERATE – loss but amount
cannot ge determined
5. LIQUIDATED - stipulated
6. EXEMPLARY OR CORRECTIVE – to correct the
wrong
(SEE PAGES 59 TO 60 OF THE BALLADA BOOK)
ARTICLE 1171
RESPONSIBILITY ARISING FROM FRAUD
IS DEMANDABLE IN ALL OBLIGATIONS.
ANY WAIVER OF AN ACTION FOR
FUTURE FRAUD IS VOID.
ARTICLE 1171
v FRAUD or DOLO – False representation of a matter of fact/whether by words
or conduct/by false or misleading allegations/or by concealment of that which
has been disclosed/. which deceives and intends to deceive another so that he
shall act upon it to his legal injury.
• WAIVER OF ACTION FOR FRAUD
• RIGHTS GRANTED BY LAW MAY BE WAIVED
• Provided that such waiver is NOT contrary to PUBLIC INTEREST, PUBLIC ORDER, or
PREJUDICIAL TO THIRD PERSON
• Waiver of action for future fraud is void because it is a license to do future fraud without
liability
• HOWEVER, Action for PAST FRAUD may be waived
v LIABLE TO ALL CONSEQUENCE OF HIS FRAUDULENT ACTION
ARTICLE 1171

v GENERAL CLASSIFICATION OF FRAUD:


1.CIVIL FRAUD
2.CRIMINAL FRAUD
ARTICLE 1171
v CLASSIFICATION OF CIVIL FRAUD:
1. FRAUD IN THE CONSTITUTION OF AN OBLIGATION (DOLO
CAUSANTE)
• Secure CONSENT OF PARTY in entering into a contract
• Leads to vitiated consent (Voidable – Injured party can
Annul the Contract)
2. FRAUD IN THE PERFORMANCE OF AN OBLIGATION (DOLO
INCIDENTE)
• Breach or non – fulfillment of obligation
• Remedy is not Annulment but DAMAGES
• Originally, injured party VALIDLY gave his consent
ARTICLE 1172
RESPONSIBILITY ARISING FROM
NEGLIGENCE IN THE PERFORMANCE OF
EVERY KIND OF OBLIGATION IS ALSO
DEMANDABLE, BUT SUCH LIABILITY MAY
BE REGULATED BY THE COURTS,
ACCORDING TO THE CIRCUMSTANCES.
ARTICLE 1172

LIABILITY ARISING FROM NEGLIGENCE IN THE


PERFORMANCE OF EVERY KIND OF OBLIGATION MAY BE
REGULATED BY THE COURTS. THE LIABILITY OF THE
OFFENDING PARTY MAY BE INCREASED or DECREASED
DEPENDING UPON THE CIRCUMSTANCE OF THE CASE.
ARTICLE 1173
THE FAULT OR NEGLIGENCE OF THE
OBLIGOR CONSISTS IN THE OMISSION OF
THAT DILIGENCE WHICH IS REQUIRED BY
THE NATURE OF THE OBLIGATION AND
CORRESPONDS WITH THE CIRCUMSTANCES
OF THE PERSONS, OF THE TIME, AND OF THE
PLACE.
ARTICLE 1173
(2 ND SENTENCE)

WHEN NEGLIGENCE SHOWS BAD FAITH,


THE PROVISIONS OF ARTICLE 1171
(FRAUD) and 2201, PARAGRAPH 2,
SHALL APPLY.
ARTICLE 1173 (2ND SENTENCE)
• Article 2201.
In contracts and quasi-contracts, the damages for which the
obligor who acted in good faith is liable shall be those that are the
natural and probable consequences of the breach of the obligation,
and which the parties have foreseen or could have reasonably
foreseen at the time the obligation was constituted.
In case of fraud, bad faith, malice or wanton attitude, the
obligor shall be responsible for all damages which may be reasonably
attributed to the non-performance of the obligation. (1107a)
ARTICLE 1173
(2 ND PARAGRAPH)

IF THE LAW or CONTRACT DOES NOT


STATE THE DILIGENCE WHICH IS TO BE
OBSERVED IN THE PERFORMANCE, THAT
WHICH IS EXPECTED OF A GOOD
FATHER OF A FAMILY IS REQUIRED.
ARTICLE 1173 (2ND PARAGRAPH)

v NEGLIGENCE vs FRAUD
v KINDS OF NEGLIGENCE:
1.CIVIL (UNDER THE NEW CIVIL CODE)
a. Culpa Contractual
b. Culpa Aquiliana (Quasi – Delict)
2.CRIMINAL (UNDER THE REVISED
PENAL CODE)
ARTICLE 1174
EXCEPT IN CASES EXPRESSLY SPECIFIED BY
LAW, OR WHEN IT IS OTHERWISE DECLARED
BY STIPULATION, OR WHEN THE NATURE OF
THE OBLIGATION REQUIRED THE ASSUMPTION
OF RISK, NO PERSON SHALL BE RESPONSIBLE
FOR THOSE EVENTS WHICH COULD NOT BE
FORESEEN, or WHICH, THOUGH FORESEEN, WERE
INEVITABLE. (FORTUITOUS EVENT)
ARTICLE 1174

v CLASSIFICATION OF FORTUITOUS EVENTS:


1. ACT OF GOD or FE PROPER – independent
of any human intervention. Brought about
by natural forces.
2. FORCE MAJEURE or FUERZA MAYOR –
those arise from legitimate or illegitimate
acts of persons other than the obligor.
ARTICLE 1174

v EFFECT OF FE ON OBLIGATIONS:
• THE OBLIGATION IS EXTINGUISHED UNLESS THE
OBJECT IS AN INDETERMINATE OR GENERIC
THING.
• OBLIGOR IS NOT LIABLE FOR DAMAGES.
• THE FE IS THE PROXIMATE and ONLY CAUSE FOR
THE LOSS.
ARTICLE 1174
v EXCEPTION TO THE GENERAL RULE:
1. IF SUCH LIABILITY IS EXPRESSLY PROVIDED FOR BY LAW.
• examples:
• Debtor in delay (Art 1165)
• Promises to deliver to 2 or more persons (Art 1165)
• Generic thing – never perishes
• DEBT of a specific things proceeds from a criminal offense
2. IF PARTY STIPULATED FOR IT.
3. NATURE OF THE OBLIGATION REQUIRES THE ASSUMPTION OF
RISK.
ARTICLE 1175
USURIOUS TRANSACTIONS SHALL BE
GOVERNED BY SPECIAL LAW.
• Usury Law is legally ineffective by RESO 224 dated 12/3/82 by the Monetary Board
of Central Bank and later by the Central Bank Circular No. 905 which took effect on
January 1, 1983
• IN a SC decide case GR No. 148491 interest can now be imposed as agreed by the
parties
• Sc in certain jurisprudence provide that lenders could not impose excessive interest as
against the morals
ARTICLE 1176
RECEIPT OF THE PRINCIPAL BY THE CREDITOR
WITHOUT RESERVATION AS TO INTEREST SHALL
GIVE RISE TO A PRESUMPTION THAT SAID
INTEREST HAS BEEN PAID.
RECEIPT OF LATER INSTALLMENT OF A DEBT
WITHOUT RESERVATION AS TO PRIOR
INSTALLMENT SHALL RAISE PRESUMPTION THAT
PRIOR INSTALLMENT HAS BEEN PAID
ARTICLE 1176
v PRESUMPTIONS – assumptions which the law requires to be made
based on another fact or group of facts or otherwise established in the
action
v KINDS on the LAW of EVIDENCE
1. CONCLUSIVE or ABSOLUTE
a) Not permitted to be overcome by any proof that the fact is
otherwise if the basic facts is established
b) IGNORATIA LEXIS NON EXCUSAT
2. DISPUTABLE or REBUTTALE PRESUMPTION
a) Accepted or acted on when there is no other evidence to
uphold the contention for which it stands
b) May be overcome by other evidence
v Section 1176 are Disputable Presumption
ARTICLE 1176
Article 1253 states that:
“If the debt produces interest, payment of the
principal shall not be deemed to have been made until
the interest have been covered.”
• if the creditor issued receipt showing payment
applied to principal, presumption is interest has been
paid.
• if prior installment not paid but creditor issued
receipt for the latter installment, presumption is
prior installment is paid already.
ARTICLE 1177
THE CREDITORS, AFTER HAVING PURSUED THE
PROPERTY IN POSSESSION OF THE DEBTOR TO
SATISFY THEIR CLAIMS, MAY EXERCISE ALL THE
RIGHTS AND BRING ALL ACTIONS OF THE LATTER
FOR THE SAME PURPOSE, SAVE THOSE WHICH ARE
INHERENT IN HIS PERSON; THEY MAY ALSO
IMPUGN THE ACTS WHICH THE DEBTOR MAY HAVE
DONE TO DEFRAUD THEM.
ARTICLE 1177
v REMEDIES OF THE CREDITOR IN THE EVENT THE DEBTOR WILL NOT PREFORM HIS
OBLIGATION:
1. TO PURSUE THE PROPERTY IN THE POSSESSION OF THE DEBTOR. (Principal
Remedy).
2. ACCTION SUBROGATORIA - TO BE SUBROGATED TO ALL THE RIGHTS and
ACTIONS OF THE DEBTOR SAVE THOSE WHICH ARE INHERENT IN HIS PERSON. The
creditor can proceed against third person against whom the debtor has claims.
• Art. 155. The family home shall be exempt from execution, forced sale or attachment except:
(1) For nonpayment of taxes;
(2) For debts incurred prior to the constitution of the family home;
(3) For debts secured by mortgages on the premises before or after such
constitution; and
(4) For debts due to laborers, mechanics, architects, builders, material men and others
who have rendered service or furnished material for the construction of the building.”
ARTICLE 1177
3. ACCION PAULIANA – Creditor has the right to
impugn or attack the acts of the debtor to
defraud him by RESCINDING the contracts
entered by the debtor to defeat the creditors
rights. (example. Donating or selling the property
to 3rd person)
• Availed of as a last resort. Only if other remedies
will not be available.
ARTICLE 1178
SUBJECTS TO THE LAWS, ALL RIGHTS
ACQUIRED IN VIRTUE OF AN OBLIGATION
ARE TRANSMISSIBLE. IF THERE IS NO
STIPULATION TO THE CONTRARY.
ARTICLE 1178

v RIGHTS ACQUIRED BY VIRTUE OF AN


OBLIGATION IS TRANSMISSIBLE AND CAN BE
ALIENTAED OR ASSIGNED TO THIRD PERSONS.
EXCEPT:
1. NON-TRASMISSIBLE BECAUSE OF ITS NATURE.
(Purely Personal Rights – Right to Vote.)
2. STIPULATED BY THE PARTIES.
3. OPERATION OF LAW.
THANK YOU. ON THE NEXT ONE.

You might also like