POLICY BRIEF

POS 2211

Familial, Social and Economical Factors of Violence Against Women in

the Philippines: Recommendations for Creating a Safe Space for Women
Abellare, Sir Henrik M., Flowers, Rayn H., Pardillo, Belle Reese D., Pormida, Andrie N.

Photosource: International Women's Day: Women take to the streets to protest- The New Indian Express

The insights and points of view in this
policy brief are a means of resources
offered voluntarily by the authors for
policy stakeholders to take into
consideration. This does not reflect the
views of the institution
EXECUTIVE SUMMARY
The Philippines as any other
country in the world is no stranger to
violence and abuse suffered by women. It
is one of the most evident issues on
crimes against women so much so that
there have been policies, institutions and
other bodies of authority governmental or
nongovernmental that have taken the

Page 1
necessary measures in order to combat
this issue and to provide for the safety,
security and well-being of women. One of
the laws that seeks to uphold human
rights for women is the Republic Act 9710,
also known as the Magna Carta of
Women. It seeks to eliminate
discrimination by recognizing, protecting,
fulfilling, and promoting the rights of
Filipino women, particularly those from
marginalized social groups. It conveys a
framework of women's rights that is
directly based on international law. The
Philippine Government has built
campaigns and programs in order to
strengthen the call for action on this issue.
But despite these efforts, the Philippines is
one of the countries with the highest
number of cases According to Michelle J.
Hiden, violence against womenin the year
2002 Violence against women is on the
rise. This has a significant impact not only
on women but also on men, not only to
her family and household, but also to the
economy and the region's and society's
productivity.
This policy brief intends to call for
strengthening and tightening our laws and
regulations and other measures taken that
seeks to address the issue of violence
against women. There are many reasons
for the occurrence of violence against.
Philippine society is very patriarchal and
views men superior over women.
According to data from the Philippine
National Police (PNP) the most culprits
that commit violence against women are
men, commonly found in intimate
partners. Male control and domination is a
main factor into the severity of this issue.
Inequalities between men and women are
prevalent in society and private aspects of
life, such as social, economic, and political,
cultural and political rights manifest
themselves in the limited freedom women
have.
In this policy brief we are going to
be discussing the familial, social and
economic aspect of this issue and going
deeper into the dynamics between men
and women, where women are placed in
a more vulnerable position. We must focus
on recognizing the severity of the
problem, albeit the already implemented
laws and policies that alleviate the burden
of abused women all over the Philippines,
with the acknowledgement application of
analyzation of societal dynamics it will
shed light into the issue and it will make us
better understand on creating or
upgrading policies that are catered to
violence against women.
BACKGROUND
Gender-based violence is prevalent in
many countries around the world. The
struggles that women go through, the
abuse they experience have had
detrimental effects not only on the
physical aspects but it will have an effect
on their mental and emotional being as
well. This is considered as widespread
human rights violation and influences the
social, economic, health, and familial
consequences that victims and their
families have to deal with. Violence
against women (VAW) appears to be one
of the country's most widespread social
issues. According to the Philippine
Statistics Authority's 2017 National
Demographic and Health Survey, one in
every four Filipino women aged 15 to 49
has experienced physical, emotional, or
Page 2
sexual violence from their husband or
partner. VAWC is closely linked to the
unequal power between men and women.
Hence why this is considered gender
based violence. Societal norms and
traditions dictate the people to think that
men are superior over women, they are
the pursuers, leaders and providers while
the women are the nurturers. The way
that the societal system functions makes
women more vulnerable and prone to
violence and abuse.
Women are regarded as a marginalized
group of people who adapt to and accept
perceptions of powerful groups that bring
about change in their point of view.
Individual perspectives, on the other hand,
differ. However, they can be similar if they
have similar interests and environments
shared with others. In 2020, as lockdowns
were started to be implemented due to
COVID-19 the Philippine National Police
documented 4,260 cases of violence
against women and children in just three
months. At least 2,138 cases were
committed against women. Also
according to the Philippine National
Police, from March 23 to May 27, 2020, at
least 602 individuals were sexually
violated. This meant that there was an
average 8 cases of rape that were
happening daily.
The country ranks high in gender based
violence even up to the times of the
pandemic which have perpetrated it even
more. Even though there is a good array
of national and local policies that address
the issue, the persistence and prevalence
of Gender Based Violence tend to
undermine the policy responses in order
to protect women.
Existing Policies
The Philippines has a number of laws that
address violence against women. Included
in the 1987 Constitution are several
provisions on women, which serves as the
basis for protecting their rights and
acknowledging their value. It is also worth
mentioning that the Philippines is a
signatory to international human rights
treaties such as the Convention on the
Elimination of All Forms of Discrimination
on Women (CEDAW), and its optional
protocol, including the Convention on the
rights of the child. In showing its
commitment to CEDAW the Philippine
Government passed on Republic Act 9710
the “Magna Carta of Women”. Its goal is
to address and eliminate violence against
women, and recognizes, protects, fulfills,
promotes, the human rights of women.
There are only a few existing policies at
the national level that addresses violence
against women. These are as follows in
chronological order: Republic Act No.
7877, Republic Act No. 8353, Republic Act
No. 8505, Republic Act No. 9622.
Other laws that promote the welfare of
women but aren’t specifically targeted
towards VAWC are Republic Act No. 7192
and Republic Act No. 10354.
● Republic Act No. 7877 or the
Anti-Sexual Harassment Act of 1995
is one of he earliest known policies
addressing the issue of sexual
harrassment occurring both in
schools and workplaces. Unwanted
sexual advances or granting sexual
favors in exchange for whatever
Page 3
 beneficial conditions is strictly
prhobited by this law.
● Republic Act No. 8353 or the
Anti-Rape Law of 1997 is a Revised
Penal Code of Title 8 of Act No.
3815, which classifies rape as a
Crime Against Persons. It
determines an act as rape if there is
a use of force, threat, or
intimidation; when the victim is
deprived of reason or unconscious,
or if the victim is under the age of
12.
● Republic Act No. 8505 or the Rape
Victim Assistance and Protection Act
of 1998 protects rape victims
through the establishment of a
rape crisis center, to be present in
every province and city. Its purpose
is to assist the victims in the
litigation process by providing free
legal, medical, and mental health
services.
● Republic Act No. 9262 or The
Anti-Violence against Women and
their Children Act of 2004 penalizes
any individual commiting any act or
a sequences of acts—including
physical, verbal, emotional, sexual,
and cyber attacks—against a
woman, whether it is his spouse,
former spouse, or against any
woman he has indulged in a
romantic or sexual relationship
with, or even with someone he has
had a child with, or against the
child of the said woman, regardless
if illegitimate or legitimate, within
or without the family’s abode.
● Republic Act No. 7192 of the
Women in Development and Nation
Building Act is an act that further
promotes and supports the
integration of women as complete
and equal partners of men in public
life, specifically in the development
and nation building, etc.
● Republic Act No. 10354 or The
Responsible Parenthood and
Reproductive Health Act of 2012 is a
law that guarantees the general
opportunity and free access to use
methods of contraception, sex
education, fertility control, and
maternal care for all Filipino
citizens, including those in
poverty-stricken communities, at
government health centers or
clinics.
While these laws have a progressive view
of women’s rights. Unfortunately there
has been limited progress in terms of the
violence that women have experienced.
According to the data obtained from the
Philippine Statistics Authority (PSA) from
the Philippine National Police (PNP) and
the Department of Social Welfare and
Development (DSWD). Around 420
women were victims of trafficking in 2019.
A 66.8% increase from 252 women in 2018.
DSWD also showed, PSA said, that 222
women were sexually exploited in 2019.
Which is 30.6% higher than the 1,656 cases
reported in 2018. As of February 2020,
data obtained from PSA states that there
were 16, 251 physical injury cases reported
to the PNP in 2019.
According to the Annual Responsible
Parenthood and Reproductive Health
(RPRH) report conducted by the Philippine
National Army (PNP) in 2019, there were
15, 160 cases of VAWC experienced in an
intimate-partner relationship. This can be
broken down into various types of
Page 4
gender-based violence, with rape
constituting 2, 341 cases, acts of
lasciviousness with 1, 953 cases,
concubinage with 204 cases, and sexual
harassment with 85 cases. Between
October 2019 and September 2020, online
searches that relate to domestic abuse
have risen significantly in the Philippines,
according to the United Nations women.
This was done in partnership with the
United Nations Population Fund (UNFPA)
and analytics company Quilt A.I. These
searches surged 63% in the Philippines.
These online searches include specific
references such as “men hitting women”,
“spouse abuse”, “controlling men”, and
“controlling husband”.
The data showed searches per 100,000
people for violence against women and
girls. In the Philippines this reached 1,048
the third highest among the countries
which were included in this study. In the
Philippines, social media posts mentioning
justice, law, and regulations accounted for
38%, while NGO and community support
accounted for 22% and 12%, respectively.
There are more causative factors to
violence against women. Age,
relationship, separation, income and
foregoing oppression are a few to name.
Other factors would be wealth, education
and religion that would also be other
factors. To fully understand and assess
violence against women, it is best to
identify and understand it’s elements.
There are many forms of abuse done to
women such as physical violence, sexual
assault, emotional and verbal abuse, and
cyber crime. These can be experienced by
any woman, any age,anywhere.
Forms of Abuse:
Physical and Sexual Abuse
Physical violence is the most recognized
form of abuse. Among many pressing
problems women face in their lives are
physical and sexual abuse. Physical
violence is exercised through physically
aggressive acts such as kicking, biting,
slapping, beating, or even strangling.
Physical violent behavior is exercised
through hitting, slapping, punching,
kicking, burning, strangulation, damaging
the personal property of their partner,
refusing medical care and/or controlling
partner’s medication, coercing partner
into substance abuse, and the use of
weapons. In the case of sexual abuse,
sexual violence is not necessarily about
sex. Sexual violent acts are about power,
control, and all sexual behavior performed
without the consent of their partner.
Forcing a partner into having intercourse
or perform sexual acts with other people,
human trafficking, pursuing sexual activity
when the victim is either unconsious or
not fully conscious or is fearful to reject
the advancements made by the other
party, hurting partner physically during
intercourse, and coercing partner to have
intercourse without any form of
protection, i.e condom, or deliberality
destroying partner’s contraceptives, i.e
birth control pills, are classified as sexual
abuse. Despite the enactment of
legislations such as Republic Act No. 9262,
or also known as the Anti-Violence Against
Women and Their Children Law, and
Republic Act No. 7877, a survey carried out
by the Commission on Population and
Development during the early months of
the COVID19 pandemic, 1 out of 4, or 25%
of Filipino adults across the country cited
harmful acts as the leading problems of
Page 5
women during the present health crisis.
Specifically 11% of women stated physical
violence as a concerning issue for Filipinas,
while 14% mentioned sexual abuse.
Emotional and Verbal
Writer and counselor, Aisha Mirza states
that “It is not the bruise on the body that
hurts. It is the wounds of the scars on the
mind.” Emotional and Verbal abuse are
both classified as forms of Psychological
abuse. Abuse is not limited to physical
violent acts, but rather words with
humiliating, hurtful, violent, and negative
undertones are considered abusive. Much
like physical and sexual violence,
emotioonal and verbal abuse can have
short-term and long-lasting consequences
that are just as serious and damaging to
one’s psyche. Section 3 of Republic Act
No. 6262, or otherwise known as the Anti-
Violence Against Women and their
Children, state that " 'Psychological
violence' refers to acts or omissions
causing or likely to cause mental or
emotional suffering of the victim such as
but not limited to intimidation,
harassment, stalking, damage to property,
public ridicule or humiliation, repeated
verbal abuse and mental infidelity…” and
in Section 5 of the same article, declares
that “the crime of violence against women
and their children is committed through
any of the following acts: (i) Causing
mental or emotional anguish, public
ridicule or humiliation to the woman or
her child, including, but not limited to,
repeated verbal and emotional abuse, and
denial of financial support or custody of
minor children or access to the woman's
child/children." This piece of legislation
recognizes that abuse comes in numerous
forms, and that it is not also limited to just
physical and sexual violence.
Cybercrime
The rapid devepment of Information and
Communication Technology (ICT) in the
past decade has led to the rise of
blackmailing, revenge porn, cyber
prostitution, and other cyber related
abuse. Cybercrime is defined by the
Department of Justice as “...a crime
committed with or through the use of
information and communication
technologies such as radio, television,
cellular phone, computer and network,
and other communication devices or
applications” (DOJ, 2012). The exploitation
of young girls, usually 13 years old and
below, is especially prevelant as the
perpetrators are usually their parents or
legal guardians who force them to
perform sexual acts with foreign
customers online. They use their children
for their own gain, without thinking about
the implications it will have for the
children. Moreover, it sometimes turns
into a blackmarket business wherein they
lure other girls into this line of work with
almost no way out for them. Despite the
passage of RA 9775 or the AntiChild
Pornography Act and RA 9995 or the
Anti-Photo and Voyeurism Act of 2009,
child pornography and cybersex is still a
prevelent issue plaguing the country.
Another form of cybercrime is the
proliferation of “video sex scandals” that
are posted without the consent of the
women in the videos. Most of the time,
they are used as material to blackmail the
victim into doing more lascivious acts for
Page 6
the pleasure of the blackmailer. Standard Employment Contract, the
Unfortunately, these videos are in high Filipino seafarer is officially compulsory to
demand, with a growing number of make a monthly allotment of at least 80%
interest in this subgenre. Moreover, the percent of his monthly basic salary which
public usually places the blame on the shall be payable to his designated allottee
victim, shaming her for even engaging in in the Philippines. Under VAWC, which
sexual acts. was promulgated March 08, 2004,
“economic abuse” can be committed
Economic Abuse against a woman who is his wife, former
wife, or against a woman with whom the
Economic Abuse is essentially Financial person has or had a sexual or dating
abuse, in which the abuser deprives their relationship, or with whom he has a
partner from financial support for their common child, or against her child
shared child/children, is controlling over whether legitimate or illegitimate, within
financial resources , withholding access to or without the family abode.”
money, or attempting to prevent their
partner from working and/or attending
school in an attempt to create financial
dependence as a means of control.
Domestic abuse is more than just physical
harm. In many cases, it also quietly hurts
victims by stripping away their control
over their own finances and destroying
their financial health. Under the POEA

Photosource: https://businessmirror.com.ph/2021/03/04/big-data-shows-steep-rise-in-domestic-abuse-searches-in-pandemic/

Page 7

FACTORS THAT LEAD TO VAW
Family Factors:
This refers to violence that is done in the
family. There can be many reasons as to
why violence is occurs at home; mostly
familial instability, marital instability, and
marital conflict. The implementation of
RA 9262 also known as the “The Anti
Violence against Women and Children
Act”, this is due to presence of violence in
the familial community. On the other
hand, an agent of the Philippine
Commission on Women, a government
agency that serves to protect the rights of
Women, claimed that family factors are
present considering the social status of
women. According to the study of
Racisdon et. al (2016), “It triggers
violence against women because of the
patriarchal society that makes the man
powerful and head of the family”. As
stated in RA. 9710 “equal rights in all
manner relating to marriage and family
relations, a woman who is denied equal
rights in the family is disregarded, hence
why it is a form of violence against
women”. Another trigger would also be
the instability in the marriage of partners
that can lead to abuse.
Economic Factors:
This is one of the most common factors
violence against women. It is the financial
aspect of women, including her family and
financial support of the head of the family.
According to the RA. 9262, “Economic, is
defined as the acts that make or attempt
to make a woman financially dependent”.
Data from the National Demographic
Health Survey, states the women who are
in lower income brackets are vulnerable to
abuse. The Philippine Commission on
women supported that not only women
who live in a lower income bracket are
vulnerable to violence. Some victims are
from well-off social status but do not
report as to not to put shame in their
name. Hence why, though the possibility
of violence is due to economic disparity,
no woman is safe from this and every
woman is vulnerable.
Social Factors:
A representative from Gabriela also stated
that violence against women occurs when
there is gender and social discrimination.
A facet of this is found in society where
women who have higher educational
attainment are offered better
opportunities. To add to this the portrayal
of women in the media is a factor. Women
who appear in the media wearing bikinis
and doing suggestive dances are seen as
an object which is degrading to women, a
claim made by a barangay chairwoman in
Manila. Discrimination of women in the
educational setting is also present, where
children are taught about the limitations
of women, which women should focus on
doing domestic jobs and the men have
other responsibilities that will have more
impact on their lives.
The preceding statement is a violation of
women's rights. The Magna Carta on
Women guarantees women's rights. The
law refers to the portrayal of women in
media and film that is non-discriminatory
Page 8
and non-derogatory. Promoting public
awareness of the importance of
identifying women's dignity, as well as
their function and contribution in the
home, community, and society using mass
media in a strategic way.
RECOMMENDATIONS
Provide support services to the victims
According to the 2017 National
Demographic and Health Survey, 1 out of
20 women and girls age 15-49 have
experienced sexual violence in their
lifetime. Some realities in the Philippines
contribute to Filipino women's
vulnerability to VAW, such as being
blamed of being "naggers" or inattentive
of their duties as wives, which leads to
them being assaulted by their husbands or
being raped owing to her "flirtatious"
behaviors. In normal situations and in the
aftermath of an emergency, the
Department of Social Welfare and
Development (DSWD) and United Nations
Fund for Population Activities (UNFPA) in
the Philippines should work
collaboratively to enhance and prioritize
strengthening policies and protection
mechanisms to prevent and respond to
gender-based violence. During these
situations, UNFPA works together with
the Department of Social Welfare and
Development (DSWD) and the
Department of
Health to organize the delivery of
humanitarian aid to meet the unique
needs of
women and girls, as well as to help
survivors of gender-based violence.
Women-Friendly Spaces, clinical and
psychological assistance, a
recommendation route to resources, and
capacity building are among them.
Create an environment with awareness of
the issue Violence against Women
Raising awareness about Violence
against Women in every environment will
help the society fight against the
misconceptions and norms of the rights of
Women. With an environment aware of
this issue, it will shape the idea into a
positive change where it will be
considered as a shared responsibility of all
community members. A similar idea to this
is the Council of Europe Recommendation
(2002) of the Committee of Ministers to
member States on the protection of
women against violence, where their
efforts have had impact in the Europe
member states and provided pressure on
the primary authorities to create an action
to the issue. The recommendation to
create awareness will help the
government in relation to adoption of
laws and national action plans to the
existing provisions.
Create a safe environment for the women
Despite domestic abuse is now
generally understood as a human rights
violation, violence against women and
girls in public areas, especially sexual
molestation, continues to be a major
ignored issue, with few laws or policies in
effort to avoid and address it.
Strengthening existing laws and adding
more specifics to it is better than Ignoring
the abuses to women in society. Its scope
must not only be implemented in urban
areas, the intensity of the security to the
Page 9
women must also be felt to the rural areas
where women in small rural and isolated
areas reported to be the highest
prevalence of IPV (22.5% and 17.9%,
respectively) compared to 15.5% for urban
women (Peek-Asa, 2011).
Develop data collection and monitoring
systems for violence against women, as
well as the mindsets and ideals that
support it.
In 2004, the Philippines passed the
Anti-Violence Against Women and Children
Act. However, no follow-up data on
implementation is available, which could
guide the next steps of action. Active
surveillance and additional research are
required to build a reliable data
infrastructure on violence against women
in the Philippines. To provide adequate
and timely medical, psychological, legal,
financial, and housing aid to victims,
cross-sectoral coordination between
policymakers, non-governmental
organizations, community leaders,
women's advocates, and the health sector
must be strengthened. Data must be
gathered in administrative and survey
formats. When victims of violence seek
assistance, administrative data is typically
collected during the normal operation of
public services.
Prioritize funding for the programs that
support and respond to the victims in the
home and the community from the time
conflict begins.
Some Women are experiencing
non-partner sexual violence and intimate
partner violence and are affected by
harmful traditional practices such as
leaving them pregnant and not financially
supporting the child and woman. To
address these urgent problems, the
government and humanitarian community
needs to prioritize in designing and
funding of provisions or programs that will
help those women who got abandoned by
their husband and ensure to punish those
men who did not financially support their
families. The humanitarian community, if
possible, needs to coordinate with the
Single Moms community Program where
there is a 10-week program designed to
assist mothers on their journey to
self-sufficiency and the government
provides benefits such as Income Support,
income-based Jobseeker's Allowance,
income-related Employment and Support
Allowance, Child Tax Credit, Working Tax
Credit, Housing Benefit.
CONCLUSION
Familial, Social and Economic Factors of
Violence Against Women poses an
obstacle to peace and security in the
Philippines. It prevents women from
engaging in civil and democratic
processes, as well as rebuilding and
rehabilitation after a conflict. This issue
has been existing for too long and it needs
a solution from the government. There are
only few existing policies that strengthen
the security of the women in the
Philippines and with the recommendation
that emphasizes on the factors of the
Violence against Women, the Familial,
Social, Economic factors, will help in
fighting against the war on violence
against women. Many misconceptions
were made and old traditions in the
society that need to be corrected but with
the help of creating awareness in the
Page 10
society, this issue might come to an end.
This current time, the society needs to
embody the feminist perspective in order
to put more importance to the women in
our society. People in the society are
called to educate themselves in order to
create awareness, speak up and share
resources to help those women who have
been a victim in violence against women.
REFERENCES
Racidon, et.al (2017). Violence Against
Women in the Philippines. Asia Pacific
Journal of Multidisciplinary Research.
http://www.apjmr.com/wp-content/uploa
ds/2018/01/APJMR-2017.6.1.15a.pdf
Philippine Statistics Authority (2017).
Results from the 2017 National and
Demographic Survey.
https://psa.gov.ph/content/one-four-wom
en-have-ever-experienced-spousal-violenc
e-preliminary-results-2017-national
World Bank (2020), Gender based Violence
and Policy Institutional Mapping Report.
https://thedocs.worldbank.org/en/doc/e15
75832e43d4030373f9a616975364f-0
Center for Reproductive Rights (2014).
Philippine Supreme Court Upholds Historic
Reproductive Health Law.
https://reproductiverights.org/philippine-s
upreme-court-upholds-historic-reproductiv
e-health-law/
The Philippine Commission on Women.
Violence Against Women.
https://pcw.gov.ph/violence-against-wome
n/#:~:text=Violence%20against%20women%
20(VAW)%20appears,by%20their%20husba
nd%20or%20partner.
David et.al (2017) Rising to the challenge
of eliminating all forms of violence against
women and girls. Philippine Institute on
Development Studies.
pidspn1725.pdf (think-asia.org)
Ordinario, C. (2020) More Women raped,
physically abused last year-govt data.
Business Mirror.
https://businessmirror.com.ph/2020/03/09/
more-women-raped-physically-abused-last
-year-govt-data/Cai Ordinario
(businessmirror.com.ph)
Ordinario, C. (2020). Big data shows a
steep rise in domestic abuse searches in
the pandemic. Business Mirror.
https://businessmirror.com.ph/2021/03/04/
big-data-shows-steep-rise-in-domestic-abu
se-searches-in-pandemic/
Espartero, B. (n.d.). POPCOM: 1 out of 4
Pinoys cite violence vs women as top
concern during pandemic | Commission on
Population and Development. POPCOM.
https://popcom.gov.ph/popcom-1-out-of-4-
pinoys-cite-violence-vs-women-as-top-con
cern-during-pandemic/
Soto, J. U. (n.d.). Violence against Women
and Information Communication
Technologies: Philippines Country Report.
APC WNSP.
Acosta, P. (2021, October 8). Verbal abuse
punishable under RA 9262. The Manila
Times.
https://www.manilatimes.net/2021/10/08/le
gal-advice/verbal-abuse-punishable-under-
ra-9262/1817535
Page 11
Allotment, a remittances a and
Violence Against women ANDA a their
children act (VAWC). (2019, October 15).
INQUIRER.net.
https://cebudailynews.inquirer.net/264129/
allotment-remittances-and-violence-agains
t-women-and-their-children-act-vawc

Context in the Philippines. (2020, May 9).

Association CAMELEON.
https://www.cameleon-association.org/co
ntexte-aux-philippines/?lang=en

POPCOM: 1 out of 4 Pinoys cite violence vs

women as top concern during pandemic.
(n.d.). Commission on Population and
Development | Empowering Filipino
Families.
https://popcom.gov.ph/popcom-1-out-of-4-
pinoys-cite-violence-vs-women-as-top-con
cern-during-pandemic/

Smith, K. A. (2021, October 21). 3 warning

signs of financial abuse—And how victims
can recover. Forbes Advisor.
https://www.forbes.com/advisor/personal-
finance/signs-of-financial-abuse-domestic-
violence-awareness/

Types of abuse. (n.d.). Women Against

Abuse.
https://www.womenagainstabuse.org/edu
cation-resources/learn-about-abuse/types-
of-domestic-violence

Violence against women. (n.d.). Philippine

Commission on Women.
https://pcw.gov.ph/violence-against-wome
n/

Page 12