VILLANUEVA, Samantha Agnes Labor Law Review

20170630 Thursday (6:00 – 9:00 PM)

ASSIGNMENT
001-2021

1. Provide proper definition: Employee, Employer, Social

Legislation, Labor standards, Labor Relations,
Unemployment, Capital, and Work.

Employee – includes any individual employed by an employer. (Art. 97,

Labor Code) as a natural person who is hired, directly or indirectly, by a
natural or juridical person to perform activities related to the business of
the “hirer: who, directly or through an agent, supervises or controls the
work performance and pays the salary or wage of the “hiree”. (Azucena)

Employer – includes any person acting directly or indirectly in the

interest of an employer in relation to an employee and shall include the
government and all its branches, subdivisions and instrumentalities, all
government-owned or controlled corporations and institutions, as well as
non-profit private institutions, or organizations.

Social Legislation – all laws passed by the State to promote public

welfare. Laws that provide particular kinds of protection or benefits to
society or segments thereof in furtherance of social justice. It includes
statutes intended to enhance the welfare of the people even where there is
no employer-employee relationship.

Labor Standards – the minimum requirements prescribed by existing

laws; rules and regulations as to the terms and conditions of employment
relating to wages, hours of work, cost-of-living allowance, and other
monetary and welfare benefits, including occupational, safety and health
standards.

Labor Relations – defines and regulates the status, rights and duties, and
the institutional mechanisms that govern the individual and collective
interactions of employers, employees or their representatives.

Unemployment - it occurs when workers want to work and unable to find

jobs, which lower economic output.

Capital - money available to a business to pay for its day-to-day operations

and fund for its future growth.
VILLANUEVA, Samantha Agnes Labor Law Review
20170630 Thursday (6:00 – 9:00 PM)

Work - it is an activity which requires a physical or mental effort for an

individual to achieve a certain purpose or result.

2. Explain the kinds of unemployment.

Seasonal Unemployment: Seasonal unemployment occurs when

workers lose their jobs due to the time of year. Life guards getting laid off in
the winter and temporary store retail clerks getting laid off after the holiday
shopping season are two examples. Seasonal unemployment is a natural
part of a healthy economy.

Frictional Unemployment: This type of unemployment is characterized

by movement between jobs. When a college graduate is looking for her first
job, a cook quits his restaurant job, or a brick mason is fired from
construction company, all three of these people are now frictionally
unemployed.

Structural Unemployment: This type of unemployment is most often

characterized by a skills mismatch; meaning the skills unemployed workers
have do not match the skills needed for the jobs available. These workers
must go back to school or be retrained to get the skills they need. This type
of unemployment can be caused by technological changes like ATM
machines replacing banking tellers.

Cyclical Unemployment: This is unemployment caused by the business

cycle. People unemployed as a result of the great depression of the 1930’s
and the recent great recession were cyclically unemployed.

3. Explain the difference between UNEMPLOYMENT and

UNDEREMPLOYMENT.

Underemployed persons are employed persons who express the desire to

have additional hours of work in their present job or an additional job, or
have a new job with longer working hours.

The unemployed consists of working-age persons who are (1) without

work, (2) currently available for work, and (3) seeking work or not seeking
work because of the belief that no work is available, or awaiting results of
previous job application, or because of temporary illness or disability, bad
VILLANUEVA, Samantha Agnes Labor Law Review
20170630 Thursday (6:00 – 9:00 PM)

weather or waiting for rehire or job recall. Those who are not in the labor
force (i.e., who are neither employed or unemployed) include stay-home
spouses, students, persons with disability, retired persons, and seasonal
workers, as well as discouraged workers not actively seeking employment.

4.
What are the conventional test’s in determining the
existence of employer employee relationship?
Four-Fold Test

1. the selection and engagement of the employee;

2. the payment of wages;
3. the power of dismissal; and,
4. the employer’s power to control the employee on the means and
methods by which the work is accomplished.

5. Define Economic realities test?

The proper standard of economic dependence is whether the worker is

dependent on the alleged employer for his continued employment in that
line of business

6. Explain the Two-tiered test or multi-factor test?

The two-tiered test enunciated in Francisco vs. NLRC, is composed of:

- The putative employer’s power to control the employee with respect to
the means and methods by which the work is to be accomplished
[control test]; and
- The underlying economic realties of the activity or relationship [broader
economic reality test]

7. How do you establish Employee Employer Relation on the

following: to wit:

a. Salaried Insurance Agents

Control over the performance of the task of one providing service both with
respect to the means and manner, and the results of the service is the
primary element in determining whether an employment relationship
exists. The Supreme Court ruled petitioners Motion against his favor since
he failed to show that the control Manulife exercised over him was the
control required to exist in an employer-employee relationship; Manulifes
VILLANUEVA, Samantha Agnes Labor Law Review
20170630 Thursday (6:00 – 9:00 PM)

control fell short of this norm and carried only the characteristic of the
relationship between an insurance company and its agents, as defined by
the Insurance Code and by the law of agency under the Civil Code.

In the Supreme Courts June 29, 2010 Resolution, they noted that there are
built-in elements of control specific to an insurance agency, which do not
amount to the elements of control that characterize an employment
relationship governed by the Labor Code. The Insurance Code provides
definite parameters in the way an agent negotiates for the sale of the
company’s insurance products, his collection activities and his delivery of
the insurance contract or policy. They do not reach the level of control into
the means and manner of doing an assigned task that invariably
characterizes an employment relationship as defined by labor law. To
reiterate, guidelines indicative of labor law "control" does not merely relate
to the mutually desirable result intended by the contractual relationship;
they must have the nature of dictating the means and methods to be
employed in attaining the result. Tested by this norm, Manulifes
instructions regarding the objectives and sales targets, in connection with
the training and engagement of other agents, are among the directives that
the principal may impose on the agent to achieve the assigned tasks. They
are targeted results that Manulife wishes to attain through its agents.
Manulifes codes of conduct, likewise, do not necessarily intrude into the
insurance agents means and manner of conducting their sales. Codes of
conduct are norms or standards of behavior rather than employer directives
into how specific tasks are to be done. (Tongko vs Manulife)

b. School Teachers
Professors and instructors are not independent contractors but are
employees in that their work is controlled by their employer – the
university – which prescribes the courses or subjects that they teach and
the time and place for teaching; their work is on a regular basis and
continuous for a certain fixed period; they are compensated for their
services by salaries and wages rather than by share in the profits; they
cannot substitute others to perform their work without the consent of the
university; and they can be laid off if their work is not satisfactory. (Feafi
University vs. Bautista)

c. Jeepney Drivers
As early as 3 March 1956, in National Labor Union v. Dinglasan, this
Court ruled that the relationship between jeepney owners/operators on one
VILLANUEVA, Samantha Agnes Labor Law Review
20170630 Thursday (6:00 – 9:00 PM)

hand and jeepney drivers on the other under the boundary system is that of
employer-employee and not of lessor-lessee. Therein we explained that in
the lease of chattels the lessor loses complete control over the chattel leased
although the lessee cannot be reckless in the use thereof, otherwise he
would be responsible for the damages to the lessor. In the case of jeepney
owners/operators and jeepney drivers, the former exercise supervision and
control over the latter. The fact that the drivers do not receive fixed wages
but get only that in excess of the so-called "boundary" they pay to the
owner/operator is not sufficient to withdraw the relationship between them
from that of employer and employee. (Jardin vs NLRC)

d. Taxi Drivers
We have applied by analogy the above stated doctrine to the relationships
between bus owner/operator and bus conductor, 20 auto-calesa
owner/operator and driver,21 and recently between taxi owners/operators
and taxi drivers. (Jardin vs NLRC)

e. Bus Drivers
In the case at bar, the labor arbiter, the NLRC and the Court of Appeals
were unanimous in finding that private respondent worked as a driver of
one of the buses of petitioner and was paid on a 10% commission basis.

We have no reason to disturb all these factual findings because they are
amply supported by substantial evidence. (R Transport Corporation Vs.
Rogelio Ejandra)

f. Truck Trailer/Lorry Drivers

It ruled that an employer-employee relationship existed between the
parties, considering that: (a) respondent engaged petitioner's services
without the aid of a third party or a manpower agency; (b) the payment of
wages on a percentage basis did not negate such existence; (c) respondent's
power to dismiss petitioner was inherent in his selection and engagement
of the latter as truck driver; and (d) respondent exercised control and
supervision over petitioner's work as shown in the former's determination
of the latter's delivery areas and schedules. (Felicilda vs Uy)

g. UV Express Driver
The SC reiterated National Labor Union v. Dinglasan which distinctly
identifies the boundary system to be an employer-employee relationship as
opposed to a lessor-lessee relationship. It also provided other supporting
VILLANUEVA, Samantha Agnes Labor Law Review
20170630 Thursday (6:00 – 9:00 PM)

analogies, found in Magboo v. Bernardo and Lantaco, Sr. v. Llamas, to

highlight that an employer-employee relationship likewise existed in
relationships between an auto-calesa owner/operator and driver, a bus
owner/operator and conductor, and a taxi owner/operator and
driver (Villamaria v. CA)

h. Barbers
Absent a clear showing that petitioners and private respondent had
intended to pursue a relationship of industrial partnership, we entertain no
doubt that private respondent was employed by petitioners as caretaker-
barber. Initially, petitioners, as new owners of the barbershop, hired private
respondent as barber by absorbing the latter in their employ. Undoubtedly,
the services performed by private respondent as barber is related to, and in
the pursuit of the principal business activity of petitioners. Later on,
petitioners tapped private respondent to serve concurrently as caretaker of
the shop. Certainly, petitioners had the power to dismiss private
respondent being the ones who engaged the services of the latter. In fact,
private respondent sued petitioners for illegal dismissal, albeit contested by
the latter. As a caretaker, private respondent was paid by petitioners wages
in the form of honorarium, originally, at the rate of one-third (1/3) of the
shop's net income but subsequently pegged at a fixed amount per month.
As a barber, private respondent earned two-thirds (2/3) of the fee paid per
haircut or shaving job done. Furthermore, the following facts indubitably
reveal that petitioners controlled private respondent's work performance,
in that: (1) private respondent had to inform petitioners of the things
needed in the shop; (2) he could only recommend the hiring of barbers and
masseuses, with petitioners having the final decision; (3) he had to be at the
shop at 9:00 a.m. and could leave only at 9:00 p.m. because he was the one
who opened and closed it, being the one entrusted with the key. 7 These
duties were complied with by the private respondent upon instructions of
petitioners. Moreover, such task was far from being negligible as claimed by
petitioners. On the contrary, it was crucial to the business operation of
petitioners as shown in the preceding discussion. Hence, there was enough
basis to declare private respondent an employee of petitioners. (Jo vs
NLRC)

i. Street – Hired Cargadores

The Court considers the cargadores as regular employees. Basing from the
facts, the Court has deemed that the Unionmembers had worked as
cargadores for Corfarm. They loaded, unloaded and piled sacks of palay
VILLANUEVA, Samantha Agnes Labor Law Review
20170630 Thursday (6:00 – 9:00 PM)

from the warehouses tothe cargo trucks and from the cargo trucks to the
buyers.- This work is directly related, necessary and vital to the operations
of Corfarm.- Moreover, Corfarm did not even allege, much less prove, that
the Union members have substantial capital oinvestment in the form of
tools, equipment, machineries, [and] work premises, among others.- Lastly,
Corfarm had wielded the power of dismissal over the Union members (an
important element of the four-foldtest). Hence, the workers are not
independent contractors and an employer-employee relationship exists
betweenthe Union and Corfarm. (CPWU vs Laguesma And Corfarm
Grains, Inc)

j. Fisherman
Fishermen-crew who rendered services in various capacities (patron/pilot,
master fisherman, second fisherman, chief engineer, and fisherman)
aboard the fishing vessels of a company engaged in “trawl” fishing and
whose compensation was paid in cash on percent commission basis, are
employees following the right-of-control test, it being established that the
conduct of the fishing operations such as the schedule of the fishing trips
and the time to return to the fishing port, was under the control and
supervision of the company’s operations manager.

k. Workers in Movie Projects

The employer-employee relationship between petitioners and VIVA can
further be established by the "control test." While four elements are usually
considered in determining the existence of an employment relationship,
namely: (a) the selection and engagement of the employee; (b)... the
payment of wages; (c) the power of dismissal; and (d) the employer's power
to control the employee's conduct, the most important element is the
employer's control of the employee's conduct, not only as to the result of
the work to be done but also as to the means and methods... to accomplish
the same.

Lest it be misunderstood, this ruling does not mean that simply because
an... employee is a project or work pool employee even outside the
construction industry, he is deemed, ipso jure, a regular employee. All that
we hold today is that once a project or work pool employee has been: (1)
continuously, as opposed to intermittently, re-hired by the same...
employer for the same tasks or nature of tasks; and (2) these tasks are vital,
necessary and indispensable to the usual business or trade of the employer,
then the employee must be deemed a regular employee, pursuant to Article
VILLANUEVA, Samantha Agnes Labor Law Review
20170630 Thursday (6:00 – 9:00 PM)

280 of the Labor Code and jurisprudence. (Alejandro Maraguinot V.

NLRC)

l. TV Host
Applying the control test to the present case, we find that SONZA is not an
employee but an independent contractor. The control test is the most
important test our courts apply in distinguishing an employee from an
independent Contractor. This test is based on the extent of control the hirer
exercises over a worker. The greater the supervision and control the hirer
exercises, the more likely the worker is deemed an employee. The converse
holds true as well – the less control the hirer exercises, the more likely the
worker is considered an independent contractor.

We find that ABS-CBN was not involved in the actual performance that
produced the finished product of SONZA’s work. ABS-CBN did not instruct
SONZA how to perform his job. ABS-CBN merely reserved the right to
modify the program format and airtime schedule “for more effective
programming.” ABS-CBN’s sole concern was the quality of the shows and
their standing in the ratings. Clearly, ABS-CBN did not exercise control
over the means and methods of performance of SONZA’s work.

In any event, not all rules imposed by the hiring party on the hired party
indicate that the latter is an employee of the former. In this case, SONZA
failed to show that these rules controlled his performance. We find that
these general rules are merely guidelines towards the achievement of the
mutually desired result, which are top-rating television and radio programs
that comply with standards of the industry.

Being an exclusive talent does not by itself mean that SONZA is an

employee of ABS-CBN. Even an independent contractor can validly provide
his services exclusively to the hiring party. In the broadcast industry,
exclusivity is not necessarily the same as control. (Sonza vs ABS-CBN)

m. News Anchor
The most crucial test — the control test — demonstrates all too clearly the
absence of an employer-employee relationship. No one at the DZRC had the
power to regulate or control private respondents' activities or inputs.
VILLANUEVA, Samantha Agnes Labor Law Review
20170630 Thursday (6:00 – 9:00 PM)

Unlike the regular reporters, he was not subject to any supervision by

petitioner or its officials. Regular reporters "are required by the petitioner
to adhere to a program schedule which delineates the time when they are to
render their reports, as well as the topic to be reported upon. The substance
of their reports are [sic] oftentimes screened by the station prior to [their]
actual airing. In contrast, volunteer reporters are never given such a
program schedule but are merely advised to inform the station of the
reports they would make from time to time."

In Encyclopedia Britannica (Philippines) Inc., v. NLRC, we reiterated that

there could be no employer-employee relationship where "the element of
control is absent; where a person who works for another does so more or
less at his own pleasure and is not subject to definite hours or conditions of
work[;] and in turn is compensated according to the result of his efforts and
not the, amount thereof, we should not find that the relationship of
employer-employee exists." In the present case, private respondent worked
at his "own pleasure and [was] not subject to definite hours or conditions of
work." (Filipinas Broadcasting Network vs. NLRC)

8. What are the relationships created in a subcontracting

arrangement?

The following relationships are created:

a. The principal which decides to farm out a job or service to a

subcontractor;
b. The subcontractor which has the capacity to independently undertake
the performance of the job or service; and
c. The employees engaged by the subcontractor to accomplish the job or
service.

In subcontracting, the four-fold test of employer-employee relationship

should be satisfied by the subcontractor in relation to the employees it
engages to accomplish the subcontracted job or service. In such cases, the
subcontractor is also referred to as independent contractor.

9. What are the other prohibited acts that may be considered

as similar to labor-only contracting?
VILLANUEVA, Samantha Agnes Labor Law Review
20170630 Thursday (6:00 – 9:00 PM)

The following are other prohibited acts that may be considered as similar to
labor-only contracting
- when the principal farms out work to a “Cabo”
- Contracting out of job or work through an in-house agency
- Contracting out of job or work through an in-house cooperative which
merely supplies workers to the principal
- Contracting out of a job or work by reason of a strike or lockout whether
actual or imminent
- Contracting out of a job or work being performed by union members and
such will interfere with, restrain or coerce employees in the exercise of
their rights to self-organization as provided in Article 259 of the Labor
Code, as amended
- Requiring the contractor’s/subcontractor’s employees to perform
functions which are currently being performed by the regular employees
of the principal.
- Requiring the contractor’s/subcontractor’s employees to sign, as a
precondition to employment or continued employment, an antedated
resignation letter; a blank payroll, a waiver of labor standards including
minimum wages and social or welfare benefits; or a quitclaim releasing
the principal or contractor from liability as to payment of future claims;
or require the employee to become member of a cooperative
- Repeated hiring by the contractor/subcontractor of employees under an
employment contract of short duration
- Requiring employees under a contracting/subcontracting arrangement
to sign a contract fixing the period of employment to a term shorter than
the term of the Service Agreement, unless the contract is divisible into
phases for which substantially different skills are required and this is
made known to the employee at the time of engagement.
- Such other practices, schemes or employment arrangements designed to
circumvent the right of workers to security of tenure

10. What is labor-only contracting? What is the effect of

labor-only contracting?

Labor-only contracting refers to arrangement where the contractor or

subcontractor merely recruits, supplies or place workers to perform a job or
work for a principal, and the elements enumerated in Section 5 hereunder
are present.
VILLANUEVA, Samantha Agnes Labor Law Review
20170630 Thursday (6:00 – 9:00 PM)

The following are the effects:

a. The subcontractor will be treated as the agent of the principal. Since the
act of an agent is the act of the principal, representations made by the
subcontractor to the employees will bind the principal.
b. The principal will become the employer as if it directly employed the
workers engaged to undertake the subcontracted job or service. It will be
responsible to them for all their entitlements and benefits under the
labor laws.
c. The principal and the subcontractor will be solidarily treated as the
employer.
d. The employees will become employees of the principal, subject to the
classifications of employees under Article 28 of the Labor Code.

If the labor-only contracting activity is undertaken by a legitimate labor

organization, a petition for cancellation of union registration may be filed
against it, pursuant to Article 239(e).

11. Is the contractor allowed to just supply workers who will

do the work, to the principal?

No, this would fall under labor-only contracting which is prohibited

12. Explain exhaustively the term Social Justice.

Social justice is "neither communism, nor despotism, nor atomism, nor

anarchy," but the humanization of laws and the equalization of social and
economic forces by the State so that justice in its rational and objectively
secular conception may at least be approximated. Social justice means the
promotion of the welfare of all the people, the adoption by the Government
of measures calculated to insure economic stability of all the competent
elements of society, through the maintenance of a proper economic and
social equilibrium in the interrelations of the members of the community,
constitutionally, through the adoption of measures legally justifiable, or
extra-constitutionally, through the exercise of powers underlying the
existence of all governments on the time-honored principle of salus populi
est suprema lex.

13. How is Social Justice exemplified in Labor Laws?

VILLANUEVA, Samantha Agnes Labor Law Review
20170630 Thursday (6:00 – 9:00 PM)

The State shall:

a. Promote the principle of shared responsibility between workers and
employers
b. Promote the preferential use of voluntary modes in settling disputes
c. Regulate the relations between workers and employers,
d. Recognize the right of labor to its just share in the fruits of production
and the right of enterprises to reasonable returns to investments, and to
expansion and growth.

14. What is the basic policy of labor laws in the Philippines?

The State shall:

a. Afford protection to labor,
b. Promote full employment,
c. Ensure equal work opportunities regardless of sex, race or creed, and
d. Regulate the relations between workers and employers.

The State shall assure the rights of workers to:

a. Self-organization,
b. Collective bargaining,
c. Security of tenure, and
d. Just and humane conditions of work.

15. Explain the principle followed in the construction of labor

laws.

Art. 4 of the Labor Code mandates that all doubts in the implementation
and interpretation of the provisions thereof shall be resolved in favor of
labor. This is merely in keeping with the spirit of our Constitution and
laws which lean over backwards in favor of the working class, and mandate
that every doubt must be resolved in their favor. (Hocheng Philippines
Corporation v. Farrales)

16. Is the relationship between employee and employer

contractual in nature?

The relations between employer and employee are not merely contractual.
They are so impressed with public interest that labor contracts must yield
to the common good. Therefore, such contracts are subject to the special
VILLANUEVA, Samantha Agnes Labor Law Review
20170630 Thursday (6:00 – 9:00 PM)

laws on labor unions, collective bargaining, strikes and lockouts, closed

shop, wages, working conditions, hours of labor and similar subjects 

17. Is a Contract necessary to create an employer-employee

relationship? Explain with credible legal basis.

No, the employment contract is not the sole indicator of an employer

employee relationship.

The four-fold test is usually applied:

1. the selection and engagement of the employee;
2. the payment of wages;
3. the power of dismissal; and,
4. the employer’s power to control the employee on the means and
methods by which the work is accomplished.

And in the case of Victor Meteoro et. al. vs Creative Creatures, Inc., the
court stated that to establish the 4 elements of employer employee
relationship, any competent and relevant evidence may be considered
including but not limited to:

- Identification Cards;
- Cash Vouchers;
- Social Security Registration;
- Appointment Letters;
- Employment Contracts;
- Payrolls;
- Organization Charts; and
- Personnel List.

18. Explain the individual and collective rights of employees

under existing Philippine Laws.

The following are the individual rights under existing Philippine laws:

a. Right to security of tenure

b. Right to regular working hours
c. Right to regular working days Right to Regular meal periods
VILLANUEVA, Samantha Agnes Labor Law Review
20170630 Thursday (6:00 – 9:00 PM)

d. Right to weekly rest periods Right to overtime work pay

e. Right to Night-shift differential pay
f. Right to Compensation for holiday work
g. Right to Additional Compensation on scheduled rest day, Sunday or
h. special holiday work
i. Right to Service Incentive leave
j. Right to a share in the collective service charge

The following are the collective rights under existing Philippine laws:

a. Right to Self-Organization
b. Right to engage in collective bargaining
c. Right to participate in policy and decision-making processes
d. Right to engage in peaceful concerted activities including strike

19. Discuss the cardinal rights of Labor.

Cardinal Rights to Labor:

1. right to self-organization;
2. collective bargaining and negotiations;
3. peaceful concerted activities including the right to strike in
accordance with law;
4. security of tenure;
5. humane conditions of work;
6. living wage; and
7. participate in policy and decision-making processes affecting their
rights and benefits as may be provided by law.

20. Discuss the case of Calalang vs. Williams

In the case of Calalang v. Williams, Maximo Calalng brought before the

Supreme Court a petition for a writ of prohibition against respondents.
Respondents are, the Chairman of National Traffic Commission (Williams),
Director of Public Works (Fragrante), Acting Secretary of Public Works and
COmmunications (Bayan), Mayor of the City of Manila (Rodriguez) and
Acting Chief of Police of Manila (Dominguez). 
VILLANUEVA, Samantha Agnes Labor Law Review
20170630 Thursday (6:00 – 9:00 PM)

On July 17, 1940, the National Traffic Commission, recommended to the

Director of PUblic Works and to the Secretary of Public Works and
Communications that animal-drawn vehicles be prohibited from passing
along certain national roads for a period of 1 year from the date of the
opening of the Colgante Bridge. 

Williams, the Chairman of National Traffic Commission, recommended the

Director of PUblic Works the adoption of the measure proposed in the
resolution. 

On August 2, 1940, Fragante, the Director of Public Works recommended

to the Secretary of Public Works and Communications (Bayan) the approval
of the recommendation made by the Chairman of the National Traffic
Commission with some modifications. 

On August 10, 1940, Secretary Bayan, approved the recommendation of the

Director of Public Works. And as a result, the Mayor of Manila and the
Acting Chief of Police of Manila have enforced and caused to be enforced
the rules and regulations thus adopted.

One of the averments of the petitioner was that the rules and regulations
complained of infringe upon the constitutional precept regarding the
promotion of social justice to insure the well-being and economic security
of all the people.

Supreme Court ruled that Calalang’s contention is UNTENABLE.

Justice Laurel in ruling in the case, defined social justice, “.. is neither
communism, nor despotism, not atomism, nor anarchy but the
humanization of laws and the equalization of social and economic forces by
the State so that justice in its rational and objectively secular conception
may at least be approximated”.

Commonwealth Act 548, where the power to create rules and regulations
on traffic was derived, aims to promote safe transit upon and avoid
obstructions on national roads, in the interest and convenience of the
public.
VILLANUEVA, Samantha Agnes Labor Law Review
20170630 Thursday (6:00 – 9:00 PM)

The enactment of said law was inspired by a desire to relieve congestion of

traffic, which is to say the least is a menace of public safety.