What Is Violence Against Women And Children | RA 9262

Introduction

The deprivation of rights among women and children has been engraved in the history of different places in the world for a long time. In the past, women were not afforded with civil, social, political, and religious rights. They were not allowed to vote, to be employed, to have an education, or even wear dress that will not cover the whole body.

They were prohibited to attend social gatherings and were confined to their respective homes. They were sold by their parents for marriages. Worst, in other places, some perform genital mutilation or even killing right after the baby is born upon discovering that she is female.

The children along with their mothers, being vulnerable, were subjected to slavery or other forms of forced labor, and often experienced sexual, physical, psychological, and emotional abuse. Evidently, women and children were withheld with their inherent rights as human being to live and to enjoy it.

Past Norms

For many decades, this has been the norm of the world and nobody stood up and utter a voice, until the suffering became unbearable. According to United Nation Women Organization, it was only in 1840 that women started to cry out the truth that men and women are created equal.

Recognition of Women’s Rights

Then, the world opened its eyes and started to see the inhumane treatment women experienced. From that year on, the battle for the rights of women had begun.

More than hundred years had passed, violence among women and children are still prevalent. It is evident even in the Philippines wherein Filipinos are known to have close relationship ties with family, friends, and their partners.

To protect the rights of the women and children, the “Anti-Violence Against Women and Their Children Law (VWAC)” was enacted in 2004 or the famous statute known as Republic Act [RA] No. 9262.¹

This is to conform to the Constitutional policy that the State should protect and uphold the dignity of women and children, being an important part of the society and vital to the nation-building.

This is also to show adherence to the Universal Declaration of Human Rights, the convention on the Elimination of all forms of discrimination Against Women, Convention on the Rights of the Child, and other international human rights instruments of which the Philippines is a party.

What is the root of violence against women and children?

The root of violence against women and their children can be seen in different perspectives:

Historical

In historical perspective, in the earlier civilization, women were not allowed to go outside to hunt or work in the field because they are considered inferior and possess lesser physical strength as compared to men.

As years passed, this notion became a norm and women were afforded with fewer rights. In the culture and tradition of some countries, after the woman has been married to a man, she became the property of her husband, hence, was subject to the rights of the owner to use and even abuse.

She was restricted to perform some acts without her husband’s consent like entering into contracts. She has been made to depend on her husband even in financial aspect.

Social

In social perspective, despite that the world became modernized and in most places, women were afforded with equal rights, a patriarchal society still remain like in the Philippines.

There are still a lot of women who are not allowed to work outside home, on the other hand, if they have work outside home, they have the double burden of working inside the house and taking care of the family. Still, they are subject to some abuses.

Personal

Moreover, the root cause of abuse can be seen in personal perspective. Every person who enter into relationship will have personal differences.

Conflict and misunderstanding would often arise which have resulted to abuses. In some instances, the woman triggers her partner. In other cases, the partner who feels superior would easily inflict abuse even without trigger.

The family which is supposed to be a safe place became a battlefield. The persons who are supposed to be the protector of the women and their children has become their threat and agonizer.

When the love and respect between persons who have committed to love each other were lost, different forms of violence would come in. This violence should not be tolerated.

What are the effects of violence against women and children?

The common effects of violence against women and children can be classified into two, namely, social impact and psychological or personal impact.

Social Impact

The most disadvantageous effect of the violence is its negative impact in the society. Women inherently possess talents and skills which are vital to the society.

The nurturing nature of the woman are needed for child care, elderly care, etc.; their diligence and keenness in work are valuable in the workplace.

These are just few examples of contributions of women which can be hindered when violence comes in whether inside home or outside home. Their fullest potentials cannot be reached when they are entangled in the chain of violence.

Since the women and children are part of the family, when relationships are broken and family life is in chaos, the basic foundation of the society is shaken.

The children as products of chaotic family more likely to experience the same in their adult life, as studies show, unless the cycle is broken. Different criminal and civil cases will surface and would add up to the dockets of the courts as conflict arose.

Psychological or Personal Impact

Moreover, violence has psychological impact to the victims. Violence often result to fear and trauma. In Anti-VAWC cases, the perpetrators have or once have close relationship with the victim. Hence, the emotional wounds are deeper.

The violence even goes for years without being reported because of the idea that these personal matters will be fixed. The families or the partners’ reputation are dragged and tarnished. The children who are trapped in this circumstance are mocked and became the talk of the town.

The victims usually carry this horrific experience even after the violence ceased. In some cases, because of the accumulated anger, depression, frustration, it would result to crime of murder, homicide, parricide, etc.

These harsh effects of violence against women and children are the evil sought to be avoided or remedied through the Anti- VAWC Law.

Discuss Physical Violence, Sexual Violence, Psychological Violence, Economic Abuse, and Stalking

Abuses against women and their children are categorized under the Anti-VAWC Statute, which defines and specifically penalizes such atrocities.

Physical Violence

The Anti- VAWC Law define physical violence as acts that include bodily or physical harm. This bodily harm is the result of employing force or strength by the perpetrator to any part of the body of the victims.

In usual cases, this results to bruises, wounds, scratches, or same acts which qualified as physical injury in the Revised Penal Code.

Sexual Violence

On the other hand, “Sexual violence“² refers to an act which is sexual in nature, committed against a woman or her child. It includes, but is not limited to:

• rape, sexual harassment, acts of lasciviousness, treating a woman or her child as a sex object, making demeaning and sexually suggestive remarks,³
• physically attacking the sexual parts of the victim’s body, forcing her/him to watch obscene publications and indecent shows or forcing the woman or her child to do indecent acts and/or make films thereof,³
• forcing the wife and mistress/lover to live in the conjugal home or sleep together in the same room with the abuser,³
• acts causing or attempting to cause the victim to engage in any sexual activity by force, threat of force, physical or other harm or threat of physical or other harm or coercion;³
• Prostituting the woman or child.³

Under the Family Code, the wife has sexual responsibility with her husband. Despite that, the VAWC Law acknowledges that the wife has still the full control of her body and she could freely decide whether to engage in sexual activity or not under reasonable circumstances.

Forcing a wife to engage in sexual intercourse without her consent would constitute marital rape. In case of prostituting the woman or child, even with full knowledge and consent, if it is initiated and encouraged by the husband, then he is liable under the Anti- VAWC Law.

Since a sexually abusive husband can be persecuted, how much more to any person who is not a husband of the woman which could be lover, ex—lover, ex- husband, or lesbian girlfriend.

Psychological Violence

In addition, the Anti- VAWC Law defines “Psychological violence” as 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.⁴

It includes causing or allowing the victim to witness the physical, sexual or psychological abuse of a member of the family to which the victim belongs, or to witness pornography in any form or to witness abusive injury to pets or to unlawful or unwanted deprivation of the right to custody and/or visitation of common children.³

Though psychological violence does not result to physical wound or pain, it causes great harm to dignity, morale, or well-being of the victims.

Psychological violence could also result to mental illness, stress, depression, trauma, as well as physical illnesses.

In the recent case decided by the Supreme Court in 2020,⁵ it affirmed the appellate court’s decision to punish the husband with 6 moths to 8 years of imprisonment plus moral damages for his infidelity or extra marital affair which resulted to bearing three children with his mistress.

This is the proximate cause of the mental and emotional anguish of his wife for long years and was qualified as “psychological violence” under the VAWC Law.

Economic Abuse

Last, “economic abuse” refers to acts that make or attempt to make a woman financially dependent which includes, but is not limited to the following:⁶

• withdrawal of financial support or preventing the victim from engaging in any legitimate profession, occupation, business or activity, except in cases wherein the other spouse/partner objects on valid, serious and moral grounds as defined in Article 73 of the Family Code;³
• deprivation or threat of deprivation of financial resources and the right to the use and enjoyment of the conjugal, community or property owned in common;³
• destroying household property;³
• controlling the victims’ own money or properties or solely controlling the conjugal money or properties.³

In usual Filipino family set-up, men enter into employment while women stay at home to take care of the family, especially the children.

Generally, since it is man who earns income for the family, he has the final say as to where the money goes. It is easy to control the not employed woman by threatening her to be withheld with the only means she and her child could live.

This too, is punishable under Anti-VAWC Law for being a form of economic abuse. Also, even the spouses or partners were already separated, when their child is not given sufficient financial support, the man can be held liable.

Stalking

Stalking, on the other hand, is defined as an intentional act committed by a person who, knowingly and without lawful justification follows the woman or her child or places the woman or her child under surveillance directly or indirectly or a combination thereof.⁷

The VAWC Law put high regard in the safety and freedom from surveillance of the woman and her child as it also punishes mere staking wherein no direct harm is being inflicted to them. The law punishes this act to put preventive measure in the possible direct harm the perpetrator could do to woman and her children.

Explain the concept of “Dating Relationship” and “Sexual Relations” and differentiate them 

There are juridical nexus, whether past or existing, for which any abuse that may happen upon a woman and her child will be covered by the Anti-VAWC Law because of that relative relationship of the parties involved.

Dating Relationship

Under the Anti- VAWC Law and its Implementing Rules and Regulations [IRR], “Dating relationship” refers to a situation wherein the parties live as husband and wife without the benefit of marriage or are romantically involved over time and on a continuing basis during the course of the relationship.⁸

A casual acquaintance or ordinary socialization between two individuals in a business or social context is not a dating relationship.³

Sexual Relations

On the other hand, “Sexual relations” refers to a single sexual act which may or may not result in the bearing of a common child.⁹

Duration of Relationship

Dating relationship is differentiated in the law from sexual relations. As to duration of the relationship, dating relationship is longer than sexual relation since even a single sexual act can be classified as such and is already covered in the Anti-VAWC Law.

Degree of Emotional Attachment

As to the degree of emotional attachment, there is higher degree of emotional attachment and commitment in dating relationship because the parties are romantically involved over time and on a continuing basis.

On the other hand, in sexual relation, it is not necessary that the parties commit to each other. It does not follow that there is sexual relation in dating relationship or vice versa.

Public Perception

As to how the parties are perceived by the third person, in dating relationship, they are usually publicly known or seen as romantically involved with each other.

Third persons can see these through the couple’s overt acts, as can be inferred from those who are living as husband and wife without the benefit of marriage, or those more than casual acquaintance, regardless whether they label their relationship or not.

As compare to sexual relation, this is usually not known to the public since the act are performed in private.

Does a single act of harassment enough to convict an offender?

Yes, single act of harassment is enough to convict an offender. Under Section 3(a) of R.A. 9262, violence against women and children can be any act or series of act.

The law does not require that the violence is repetitive or continuous in order to have cause of action in filing the case as It can be ‘’any act”. The purpose of this is to reinforce and protect right away the woman and her child from further abuses.

What are the elements of the crime of violence against women and their children?

In the case of Rustan Ang Y Pascua vs. Sagud,¹⁰ the Court enumerated the elements of the crime of violence against women through harassment as follows:

• First, the offender has or had a sexual or dating relationship with the offended woman. The offender could include husband, ex-husband, lover, ex-lover, boyfriend, ex-boyfriend, girlfriend or ex-girlfriend since these are the persons a woman will have sexual or dating relationship with, or whom he has common child.
• Second, the offender, by himself or through another, commits an act or series of acts of harassment against the woman. It means that the offender can still be held liable for the crime even if he was not directly the one who inflicted the harm but other persons under his direction.
• Third, the harassment alarms or causes substantial emotional, physical or psychological distress to her. The violence can be physical, emotional, psychological, economic, sexual. The abuser can still be held liable, regardless of the kind of violence as well as the degree

Will a Temporary Protection Order (TPO) applicable or be issued in favor of a man against his wife?

It s not possible. The Anti- VAWC Law expressly provides protection to women and children. Hence, a Temporary Protection Order cannot be granted to a husband against his wife.

The applicable law that a husband can properly assert in his favor is the Revised Penal Code. The law has inclination to women and children because generally they are considered more vulnerable as compared to men who is usually stronger to protect themselves specially from physical violence.

Is it indispensable that the act of violence be a consequence of a dating or sexual relationship?

No, the law does not require that the act of violence be a consequence of dating or sexual relationship. The Supreme Court held that what is required is the committed act of violence may it be in the present wherein the parties are still in relationship or in the past when they had a relationship.

It is a basic rule that when the law does not distinguish, we should not distinguish.

What is battery? What is the concept of a battered woman syndrome?

Battery is repetitive physical abuse of a woman by her partner, husband, or lover which results to emotional, physical, psychological anguish of the woman. Battered woman syndrome is a concept originated from the United States wherein the Supreme Court adopted.

It is scientifically defined pattern of psychological and behavioral symptoms found in women living in battering relationships as a result of cumulative abuse. She always has fear for her life as if her husband or her partner is going to inflict harm to her anytime.

The concept of a battered woman syndrome is best described in the ruling of the Supreme Court in the landmark case of People vs Genosa¹¹, the Supreme Court held that a woman is considered battered if she is:

“repeatedly subjected to any forceful physical or psychological behavior by a man in order to coerce her to do something he wants her to do without concern for her rights. Battered women include wives or women in any form of intimate relationship with men.¹²

“Furthermore, in order to be classified as a battered woman, the couple must go through the battering cycle at least twice. Any woman may find herself in an abusive relationship with a man once. If it occurs a second time, and she remains in the situation.¹²

“Battered women exhibit common personality traits, such as low self-esteem, traditional beliefs about the home, the family and the female sex role; emotional dependence upon the dominant male; the tendency to accept responsibility for the batterer’s actions; and false hopes that the relationship will improve.”¹²

More graphically, the battered woman syndrome is characterized by the so-called “cycle of violence,” which has three phases:¹²

(1) the tension-building phase;¹²

(2) the acute battering incident; and¹²

(3) the tranquil, loving (or, at least, nonviolent) phase¹²

Tension Building Phase

During the tension-building phase, minor battering occurs — it could be verbal or slight physical abuse or another form of hostile behavior.¹²

The woman usually tries to pacify the batterer through a show of kind, nurturing behavior; or by simply staying out of his way. What actually happens is that she allows herself to be abused in ways that, to her, are comparatively minor.¹²

All she wants is to prevent the escalation of the violence exhibited by the batterer. This wish, however, proves to be double-edged, because her “placatory” and passive behavior legitimizes his belief that he has the right to abuse her in the first place.¹²

Acute Battering Incident

The acute battering incident is said to be characterized by brutality, destructiveness and, sometimes, death. The battered woman deems this incident as unpredictable, yet also inevitable.¹²

During this phase, she has no control; only the batterer may put an end to the violence. Its nature can be as unpredictable as the time of its explosion, and so are his reasons for ending it.¹²

The battered woman usually realizes that she cannot reason with him, and that resistance would only exacerbate her condition.¹²

At this stage, she has a sense of detachment from the attack and the terrible pain, although she may later clearly remember every detail. Her apparent passivity in the face of acute violence may be rationalized thus:¹²

“the batterer is almost always much stronger physically, and she knows from her past painful experience that it is futile to fight back.”¹²

Acute battering incidents are often very savage and out of control, such that innocent bystanders or intervenors are likely to get hurt.¹³

Tranquil Period

The final phase of the cycle of violence begins when the acute battering incident ends. During this tranquil period, the couple experience profound relief. On the one hand, the batterer may show a tender and nurturing behavior towards his partner.¹²

He knows that he has been viciously cruel and tries to make up for it, begging for her forgiveness and promising never to beat her again.¹²

On the other hand, the battered woman also tries to convince herself that the battery will never happen again; that her partner will change for the better; and that this “good, gentle and caring man” is the real person whom she loves.¹²

A battered woman usually believes that she is the sole anchor of the emotional stability of the batterer. Sensing his isolation and despair, she feels responsible for his well-being.¹²

The truth, though, is that the chances of his reforming, or seeking or receiving professional help, are very slim, especially if she remains with him.¹²

Generally, only after she leaves him does he seek professional help as a way of getting her back. Yet, it is in this phase of remorseful reconciliation that she is most thoroughly tormented psychologically.¹⁴

Dependency

The illusion of absolute interdependency is well-entrenched in a battered woman’spsyche. In this phase, she and her batterer are indeed emotionally dependent on eachother — she for his nurturant behavior, he for her forgiveness.¹⁴

Underneath this miserablecycle of “tension, violence and forgiveness,” each partner may believe that it is better todie than to be separated. Neither one may really feel independent, capable of functioningwithout the other.¹²

Is a battered woman syndrome a proper defense?

Yes, in the landmark case of People vs Genosa,¹⁵ the Supreme Court adopted the defense of battered woman syndrome and justified the killing of the husband by the accused wife.

A person who is suffering from battered woman syndrome always fear for her life and always feel the urge to defense herself from the repetitive battery of her husband.

In addition, it was expressly stated in Section 26 of R.A. 9262 that victim-survivors who are found by the courts to be suffering from battered woman syndrome do not incur any criminal and civil liability notwithstanding the absence of any of the elements for justifying circumstances of self-defense under the Revised Penal Code.¹⁶

How should the law be construed and why?

The law should be construed in favor of the victims. It is clearly the intent of the legislators to protect the women and children in order for their basic human rights to be realized and be enjoyed. As consequence, they can achieve their fullest potential and they can contribute to the society.

May the abuses committed by another person through conspiracy?

Yes, abuses can be committed by another person through conspiracy. The Anti-VAWC Law expressly provide in Section 47 that the Revised Penal Code and other applicable laws, shall have suppletory application.

Conspiracy is a general principle in the Revised Penal Code wherein the perpetrators shall be held liable as one regardless of the degree of their participation when it is proved that they have common design in committing the crime.

In addition, Section 5 of the Anti-VAWC law also provides that the violence can be committed by offender personally or through another person. Hence, another person can commit the said crime through conspiracy.

Discuss Jurisdiction and Venue. What are the prescriptive periods of acts punishable by this law?

Jurisdiction is the authority of the court to hear and decide the case while the venue in criminal cases is the place where the elements of the crime were committed. Jurisdiction of the subject matter, as in VAWC cases in conferred by the Anti-VAWC Law itself.

Here, it is expressly stated in Section 7 that Regional Trial Court designated as a Family Court shall have original and exclusive jurisdiction over cases of violence against women and their children.

In the absence of such court in the place where the offense was committed, the case shall be filed in the Regional Trial Court where the crime or any of its elements was committed at the option of the compliant.¹⁷

On the other hand, the prescriptive period or the time wherein the complaint can be filed is provided in Section 24 of the Law which states that acts falling under Sections 5(a) to 5(f) shall prescribe in twenty (20) years. Acts falling under Sections 5(g) to 5(I) shall prescribe in ten (10) years.

How is the crime of violence against women and children be classified?

Section 25 of RA 9262 provides that violence against women and their children shall be considered a public offense which may be prosecuted upon the filing of a complaint by any citizen having personal knowledge of the circumstances involving the commission of the crime.¹⁸

It is against the policy of State and any person stated in Section 9 of the Anti-VAWC Law can file a petition for protection order, namely:

• the offended party;¹⁹
• parents or guardians of the offended party;²⁰
• ascendants, descendants or collateral relatives within the fourth civil degree of consanguinity or affinity;²⁰
• officers or social workers of the DSWD or social workers of local government units (LGUs);²⁰
• police officers, preferably those in charge of women and children’s desks;²⁰
• Punong Barangay or Barangay Kagawad;²⁰
• lawyer, counselor, therapist or healthcare provider of the petitioner;²⁰
• At least two (2) concerned responsible citizens of the city or municipality where the violence against women and their children occurred and who has personal knowledge of the offense committed.²⁰

Does the Revised Penal Code have suppletory application under this Act? What is the importance of the Protection Order?

Yes, the RPC has suppletory application as it is expressly provided in Section 47 of the Anti-VAWC Law. The general law still applies to special laws when specifically provided in the latter.

The importance of protection order is to give immediate aid to the women and children and to lessen the abuses that will be possibly inflicted to them.

Since there is danger to the life of the victims in VAWC cases, this is considered urgent matter when filed in courts. Through the Protection Order, the abuser will be prohibited to go near the victims.

As consequence, the victims could start to recover and prepare for the further actions that they will take.

What has been decided

In People vs Genosa,²¹ despite that the killing of the husband by the wife was justified, the Court warned that in any event, the existence of the syndrome in a relationship does not in itself establish the legal right of the woman to kill her abusive partner. Evidence must still be considered in the context of self-defense.¹²

The crucial to the BWS defense is the state of mind of the battered woman at the time of the offense — she must have actually feared imminent harm from her batterer and honestly believed in the need to kill him in order to save her life.¹²

Settled in our jurisprudence, however, is the rule that the one who resorts to self-defense must face a real threat on one’s life; and the peril sought to be avoided must be imminent and actual, not merely imaginary.¹²

Unlawful aggression is the most essential element of self-defense. It presupposes actual, sudden and unexpected attack — or an imminent danger thereof — on the life or safety of a person.¹²

In the present case, however, according to the testimony of Marivic herself, there was a sufficient time interval between the unlawful aggression of Ben and her fatal attack upon him.¹²

She had already been able to withdraw from his violent behavior and escape to their children’s bedroom. During that time, he apparently ceased his attack and went to bed.¹²

The reality or even the imminence of the danger he posed had ended altogether. He was no longer in a position that presented an actual threat on her life or safety.¹²

In Araza vs People, the Court held that the accused is correct that he cannot be convicted based on acts of abandonment of the conjugal home, and pretenses that he was forcefully detained.⁵

These were not alleged in the Information. However, there were other acts alleged in the Information that caused emotional anguish and mental suffering on AAA.²²

In this case, the Court finds that the Information contains the recital of facts necessary to constitute the crime charged.²²

It clearly stated that:

(1) The offended party AAA, is the wife of offender Araza;²²

(2) AAA sustained emotional anguish and mental suffering; and²²

(3) such anguish and suffering is inflicted by Araza when he had an extramarital affair with Fabillar and had three illegitimate children with her.²²

Psychological violence is an indispensable element of violation of Section 5(i) of R.A. No. 9262. Equally essential is the element of emotional anguish and mental suffering, which are personal to the complainant.²²

Psychological violence is the means employed by the perpetrator, while emotional anguish or mental suffering are the effects caused to or the damage sustained by the offended party.²²

The law does not require proof that the victim became psychologically ill due to the psychological violence done by her abuser. Rather, the law only requires emotional anguish and mental suffering to be proven.²²

To establish emotional anguish or mental suffering, jurisprudence only requires that the testimony of the victim to be presented in court, as such experiences are personal to this party.²²

In order to establish psychological violence, proof of the commission of any of the acts enumerated in Section 5(i) or similar of such acts, is necessary.

The prosecution has established Araza’s guilt beyond reasonable doubt by proving that he committed psychological violence upon his wife by committing marital infidelity. AAA’s testimony was strong and credible. She was able to confirm that Araza was living with another woman.²²

Final thoughts

No one is superior in power to possess the license to commit violence specially to women and children. Women and children are already deprived for a long time of their inherent right to right to be safe, protected, and to a quality life just like any other persons.

The international community has seen this and many countries joined forces to eliminate this kind of violence. When women and children cannot protect themselves, the law itself should protect them.

The Philippines adheres to this call and continuously prosecute abusers who are supposed to be the protector and provider of the women and children. The purpose of the VAWC Law is very humane.

It acknowledges the equal rights of women and children, and it sees their value in the community. You too can take part of this goal, whether you are witness or the victim to the abuse, never let your voice be suppressed. Let the oppressors be made known.

1. RA 9262[↩]
2. IRR, RA 9262, Rule II, Section 5[c][2][↩]
3. Id.[↩][↩][↩][↩][↩][↩][↩][↩][↩][↩][↩]
4. IRR, RA 9262, Rule II, Section 5[c][3][↩]
5. G.R. No. 247429, September 08, 2020[↩][↩]
6. IRR, RA 9262, Rule II, Section 5[c][4][↩]
7. IRR, RA 9262, Rule II, Section 5[f][↩]
8. IRR, RA 9262, Rule II, Section 5[g][↩]
9. IRR, RA 9262, Rule II, Section 5[h][↩]
10. G.R. No. 182835, April 20, 2010[↩]
11. G.R. No. 135981, January 15, 2004[↩]
12. Id.[↩][↩][↩][↩][↩][↩][↩][↩][↩][↩][↩][↩][↩][↩][↩][↩][↩][↩][↩][↩][↩][↩][↩][↩][↩][↩][↩][↩]
13. Id.[↩]
14. Id.[↩][↩]
15. Supra.[↩]
16. Section 26, RA 9262[↩]
17. Garcia vs. Drilon G.R. No. 179267 June 25, 2013[↩]
18. Section 25, RA 9262[↩]
19. Section 9, RA 9262[↩]
20. Id.[↩][↩][↩][↩][↩][↩][↩]
21. G. R. No. 135981, January 15, 2004[↩]
22. Id.[↩][↩][↩][↩][↩][↩][↩][↩][↩][↩]