Sunday, October 23, 2011

1. The Philippine mission to the United Nations recently signed the Rome Statute (which established the International Criminal Court), thru Charge d’ affairs Enrique Manalo.Before the President of the Philippines signed it, Senator Pimentel demanded that a copy be sent to Senate for its concurrence. The Department of Foreign Affairs refused to send the copy for concurrence, upon order of the President.
Senator Pimentel filed a mandamus case, to compel the Philippines Mission to submit said Rome Statute for Senate Ratification.Can the DFA be compelled to submit said copy of the Rome Statute to Senate?

ANSWER: The DFA cannot be compelled as it is still discretionary on the part of the president whether to ratify the treaty or not. Ratification of the treaty lies within the president’s executive power, and she cannot be compelled by mandamus to submit the same for Senate concurrence. (Pimentel v. Executive Secretary, gr no. 158088, july 6, 2005)
2. During the Japanese occupation, Juan Tamad obtained lease contract for the use of fishery facilities from the Japanese Executive Commission for a period of five years. The contract was fuly signed, and rentals were paid in advance.
After the Japanese lost the war, the American forces cancelled the lease agreement, and awarded it to another person. Juan Tamad sued in Court invoking that his contractual rights had been impaired, arguing further that the lease contract is not political in nature, hence not abrogated. For all intents it must survive the after effects of war.
If you were the counsel of the American forces, how would you argue to support the validity of the cancellation of the lease contract? If you were the judge, how would you rule on the matter.

Answer: The cancellation of the lease contract can be justified on the ground that an occupying belligerent is merely an administrator and usufructuary of of the property of the occupied territory and therefore obliged to return the property after it loses in the occupation. The Judge must therefore rule in favor of the American forces. The contract can be deemd automatically cancelled.(Banaag v. Encarnacion, GR No. L-493, April 19, 1949)
3.What do understand about the Nottebohm doctrine? How was it invoked in the Frivaldo case?
Answer: “The court of third states, when they have before them an individual whom two other states hold to be their national, seek to resolve the conflict by having recourse to international criteria and their prevailing tendency is to prefer the real and affective nationality”. Nottebohm’s actual connections with Liechtenstein were extremely tenuous. No settled abode, no prolonged residence in the country at the time of his naturalization x x x on the contrary he returned to Guatemala very shortly after his naturalization and showed every intention of remaining there. Naturalization was asked so much for the purpose of obtaining a legal recognition x x x Guatemala is under no obligation to recognize nationality granted in such circumstances. Liechtenstein consequently is not entitled to extend its protection to Nottebohm vis-à-vis Guatemala and its claim must for this reason, be held to be inadmissible.
In the Frivaldo case, the SC denied the application of the NOTTEBOHM doctrine considering that there is no third state involved.

4.Distinguish a hostile blockade from a pacific blockade?
ANSWER: Hostile blockade occurs when the vessels and aircraft of one belligerent prevent all other vessels, including those of neutral states, from entering or leaving the ports or coasts of the other belligerent, the purpose being to shut off the place from international commerce and communication with other states. Pacific blockade applies only to vessels of the blockaded state and does not affect the vessels of other state.
5.What are some of the recognized uses of a neutral territory?
ANSWER: 1. PASSAGE OF the sick and wounded troops is allowed through a neutral state provided personnel and materials of war are not carried,
2. Person bound for enlistment in the belligerent armies may cross neutral frontiers if they do so individually or separately and not as a body
3.the neutral state itself may give refuge to troops from the belligerent forces but must intern them as far as possible at a distance from the theater of war
4. Escaped POWs need not be detained by the neutral state but must be assigned a place of residence if they are allowed to remain.
5. Passage of warships or prizes belongng to belligerents, but they cannot enter neutral ports except only in cases of unseaworthiness, lack of fuel, lack of provisions, or stress of weather.
6. Repairs of vessels may also be made in neutral ports provided that they are not intended to increase the fighting force of the vessel 7.

6. The plaintiff-appellees in these two cases are owners in fee simple of the parcels of land in question, even before the outbreak of World War II. When the Japanese came and occupied the Philippines, the Japanese Imperial Army took these parcels of land and used them for the construction of a railroad line. When the Philippines was liberated from the Japanese Military Occupation, the aforesaid parcels were abandoned and the plaintiffs-appellees immediately returned to their respective areas and repossessed them.
On September 26, 1947, the Philippine Alien Property Administrator vested in himself pursuant to Vesting Order No. P-386, the aforesaid properties after having found them to be owned or controlled or held by an enemy country. Said properties were to be held, used, administered, liquidated, sold or otherwise dealt with by the Philippine Alien Property Administrator for the interest and benefit of the United States in accordance with the Philippine Property Act of 1948. Obviously unaware of the implication of Vesting Order No. p-386 and the Philippine Property Act of 1948, plaintiffs-appellees failed to file their notice of claims for the return of their respective properties within the period provided for under the aforesaid Vesting Order. In the middle part of 1954, defendant-appellant Manila Railroad Company entered the said parcels of land and re-established its railroad track thereon.
Ruling on the plaintiffs-appellees' suit for the recovery of ownership and possession of the properties in question, the lower court held that they are entitled to a just compensation of their lands taken by defendant-appellant.
QUESTION: Based on the international law principles governing was, can there still be recovery of the said properties?
ANSWER: No. The Supreme Court held that the Japanese Imperial Army acquired no title over the questioned properties and therefore the same cannot be treated as enemy properties as contemplated in the Trading with the Enemy Act of 1917 and cannot be subjected to the Vesting Order of the Philippine Alien Property Administrator.
(.HEIRS OF ANSELMA TUGADI, ET AL. AND MARGARITA PAJIMOLA, ET AL., plaintiffs-appellees, vs. MANILA RAILROAD COMPANY (PNR), ET AL., defendants-appellants. FIRST DIVISION[G.R. No. L-26478-79. July 31, 1975.])

7. The petitioner Boris Mejoff is an alien of Russian descent who was brought to this country from Shanghai as a secret operative by the Japanese forces during the latter's regime in these Islands. Upon liberation he was arrested as a Japanese spy, by U. S. Army Counter Intelligence Corps. Later he was handed to the Commonwealth Government for disposition in accordance with Commonwealth Act No. 682. Thereafter the People's Court ordered his release. But the deportation board taking his case up, found that having no travel documents Mejoff was illegally in this country, and consequently referred the matter to the immigration authorities. After the corresponding investigation, the Board of Commissioners of Immigration on April 5, 1948, declared that Mejoff had entered the Philippines illegally in 1944, without inspection and admission by the immigration officials at a designated port of entry and, therefore, it ordered that he be deported on the first available transportation to Russia. The petitioner was then under custody, he having been arrested on March 18, 1948. In May, 1948, he was transferred to the Cebu Provincial Jail together with three other Russians to await the arrival of some Russian vessels. In July and August of that year two boats of Russian nationality called at the Cebu Port. But their masters refused to take petitioner and his companions alleging lack of authority to do so. In October, 1948, after repeated failures to ship this deportee abroad, the authorities removed him to Bilibid Prison at Muntinglupa where he has been confined up to the present time, inasmuch as the Commissioner of Immigration believes it is for the best interests of the country to keep him under detention while arrangements for his deportation are being made.
It is contended on behalf of petitioner that having been brought to the Philippines legally by the Japanese forces, he may not now be deported. It is enough to say that the argument would deny to this Government the power and the authority to eject from the Islands any and all of the members of the Nipponese Army of occupation who may still be found hiding in remote places.
Petitioner likewise contends that he may not be deported, because the statutory period to do that under the laws has long expired. The proposition has no basis. Under section 37 of the Philippine Immigration Act of 1940 any alien who enters this country "without inspection and admission by the immigration authorities at a designated port of entry" is subject to deportation within five years
Rule on the contention of the parties.
ANSWER: The contention of Mejoff has no merit. Under section 37 of the Philippine Immigration Act of 1940 any alien who enters this country "without inspection and admission by the immigration authorities at a designated point of entry" is subject to deportation within five years. In a recent decision of a similar litigation (Borovsky vs. Commissioner of Immigration) we denied the request for habeas corpus, saying:

"It must be admitted that temporary detention is a necessary step in the process of exclusion or expulsion of undesirable aliens and that pending arrangements for his deportation, the Government has the right to hold the undesirable alien under confinement for a reasonable lenght of time. However, under established precedents, too long a detention may justify the issuance of a writ of habeas corpus. 1
"The meaning of "reasonable time" depends upon the circumstances, specially the difficulties of obtaining a passport, the availability of transfortation, the diplomatic arrangements concerned and the efforts displayed to send the deportee away. 2 Considering that this Government desires to expel the alien, and does not relish keeping him at the people's expense, we must presume it is making efforts to carry out the decree of exclusion by the highest officer of the land. On top of this presumption assurances were made during the oral argument that the Government is really trying to expedite the expulsion of this petitioner. On the other hand, the record fails to show how long he has been under confinement since the last time he was apprehended. Neither does he indicate neglected opportunities to send him abroad. And unless it is shown that the deportee is being indefinitely imprisoned under the pretense of awaiting a chance for deportation 3 or unless the Government admits that itcan not deport him 4 or unless the detainee is being held for too long a period our courts will not interfere.

8. A treaty is defined as a formal agreement, usually but not necessarily in writing, which is entered into by states or entities possessing the treaty-making capacity for the purpose of regulating their mutual relations under the law of nations.
1.In a generic sense, what other words are equivalent to the term treaty? Conventions, declarations, covenants, acts, concordats.
2.From the viewpoint of international law, is treaty different from executive agreement? What about under municipal law? From the viewpoint of international law, they are deemed the same.From the viewpoint of municipal law, the treaty as to its binding effect may be different, depending on the provisions of the said municipal law.In our Phil. Constitution, the treaty cannot be binding unless concurred by 2/3 of senate.
3.What do you understand by the term pacta tertiis nec nocent nec prosunt? It means that only signatories to the treaty are bound by its provisions.Non-signatories are not.
4.State the exception to the principle of pacta sunt servanda.It is what is termed by Jessup as the “equivalent exception to the principle of pacta sunt servanda”, and also considered as one of the modes of terminating a treaty.
REBUS SIC STANTIBUS. It applies only to treaties of indefinite duration; the vital change must have been unforseen or unforseeable and should not have been caused by the party invoking the doctrine, must be invoked within reasonable time, andit cannot operate retroactively upon the provisions of the treaty already executed prior to the change of circumstances.
5.a travaux preparatories and protocol are some of the tools to be resorted in interpreting a treaty in case of doubt to its provisions.What is a travaux preparatories ? protocol?The former is the preliminaries of the treaty, while the latter is the “agreed minutes” in which certan terms used in the body of the treaty are defined and clarified.The protocol can be considered as the rough draft of the trearty.

9. Explain the “right of postliminy”.
ANSWER: The right of postliminy is that in which persons or things taken by the enemy are restored to the former state on coming actually into the power of the nation to which they belong; imports the reinstatement of the authority of the displaced government once control of the enemy is lost over the territory affected. Thus upon the end of a belligerent occupation, the laws of the re-established government are revived and all acts taken by the belligerent occupant which it could not legally do under the law of nations, as well as lawful acts of a political complexion are invalidated.

10. 1.This principle states that within a third state, a person having more than one nationality shall be treated as if he had only one. Without prejudice to the applicatin of its law in matters of personal status and of any convention in force, a third state shall, of the nationalities which, any such person possesses, recognize exclusively in its territory either the nationality of the country in which he is habitually and principally resident or the nationality of the country ith which in the circumstances he appears to be in fact most closely connected. What is this principle? Cite two cases in international law where this principle was applied as decided by the international court of justice.
ANSWER: This is the Principle of EFFECTIVE or ACTIVE NATIONALITY, applied in Tellech v. Austria, Canevaro and Nottebohm cases.
2.It is an accepted principle that the state is not an insurer of the life or property of the alien when he is within its territory. Generally, the state is not responsible for the alien’s welfare in another state. Notwithstanding these observations, there are instances when the alien can claim a more favored position than the national of the local state, and in proper cases, hold the state liable for injuries committed against him while within its territory. Under this doctrine, a state may be held responsible for an international deliquency and for acts directly imputable to it that causes injury of another state. This doctrine has been frequently invoked in recent times because of the expanding need and desire of nations for wider relations in their commercial and cultural activities. Its function is to assure travellers that when his rights are violated in a foreing state, he will not be denied any remedy simply because he is not one of its nationals. What is this principle? Elaborate its application in international law.
ANSWER: Doctrine of State Responsibility.Under this doctrine a state may be held responsible for an international deliquency, directly or indirectly attirbutable to it, which causes injury to the national of another state.
3.If an alien is damaged or injured, but happens to be stateless then he cannot avail of dipomatic protectionWhat principle of international law applies to him in this situation?
4.To avoid state responsibility another principle of international law may be invoked specifically with respect to contractual lIabilities “because of the unwillingness of most states to act as collection agencies for their nationals entering into private agreements in foreign countries. In a contract parties may stipulate that the alien waves protection from his own state on any claim arising from the contract. What is this known as? Explain.answer:
ANSWER: CALVO CLAUSE, still requires the alien to exhaust the remedies in the local state, then the calvo clause may be enforced as a lawful condition of the contract.However, it may not be interpreted to deprive the alien’s state of the right to protect or vindicate his interest in case they are injured in another state as such waiver can legally be made not by him but by his own state.
5.In extradition treaty, (1)a person may be extradited only for crimes included in the list of offense in the treaty; or (2) that the state may not extradite their own nationals committing a crime in another state, but just punish them in their own state; or (3) that to be extradited, the act must be punishable in both states. State what principle is 1, 2, and 3?

11.The principle is that war activities by or on behalf of any of the belligerents may not be undertaken in the territory of the neutral state without infringement of its neutrality. Neutral territory is inviolable and cannot be used by the belligerent for the movement of its troops, the transport of war suppLies, the erection of wireless stations for exclusively military purposes, the recruitment of soldiers, and the undertaking of military operations. All these acts should be resisted by the neutral state, with armed force if necessary and much resistance are not to be regarded as a hostile act.
There are exceptions to the general rule. State some of these exceptions.

ANSWER: 1. PASSAGE OF the sick and wounded troops is allowed through a neutral state provided personnel and materials of war are not carried,
2. Person bound for enlistment in the belligerent armies may cross neutral frontiers if they do so individually or separately and not as a body
3.the neutral state itself may give refuge to troops from the belligerent forces but must intern them as far as possible at a distance from the theater of war
4. Escaped POWs need not be detained by the neutral state but must be assigned a place of residence if they are allowed to remain.
5. Passage of warships or prizes belongng to belligerents, but they cannot enter neutral ports except only in cases of unseaworthiness, lack of fuel, lack of provisions, or stress of weather.
6. Repairs of vessels may also be made in neutral ports provided that they are not intended to increase the fighting force of the vessel 7.

12. The Extradition Treaty between France and the Philippines is silent as to its applicability with respect to crimes committed prior to its effectivity.
i) Can France demand the extradition of “A”, a French National residing in the Philippines, for an offense committed in France prior to the effectivity of the treaty?
ii) Can “A” contest his extradition on the ground that it violates the ex post facto provision of the Philippine Constitution? Explain.

ANSWER: By analogy to the ruling of Wright v. Court of Appeals, the extradition can be demanded, because a treaty can be given retroactive effect, it being not a penal law, but a sui generis.By the same, reasont he principle of ex post facto law cannot be also applied.
13. The Federation of Islamabad concluded an agreement with the Republic of Baleria, concerning the facilitation of entry of Balerian contract workers into Islamabad.Thereafter, a revolution broke out in Islamabad, which is now governed by a military junta. Most of the Balerian contract workers were arrrested by Islamabad Immigration Officers for not having with them necessary papers and proper documents. Upon learning of the incident, the government of Baleria loadge a formal protest with the Islamabad revolutionary government invoking certain provisions of the aforementioned agreement. The latter replied, however, that the new governmentis not “internationally bound” by the same. Moreover, Islamabad further contended that said agreement is contrary to its Islamic Law.
Is the new revolutionary government under obligation, pursuant to international law, to comply with what have been agreed upon and set forth in the agreement concluded with Baleria by its former government? Reason.
Answer: The revolutionary government is bound by the contract since it is pure commercial in nature, sans political complexion. TO invoke Islamic law is to invoke an internal (religious) law, which cannot be allowed under International law, simply to evade an obligation to a treaty.
14. Patrick Cruz, a Filipino, solicited P40, 000 each from Juan, Pedro, Maria, Petra and Pablo in the Philippines, as downpayment for a contractual teaching job in the United States. The job abroad did not materialize, and it was later known that Patrick was an unlicensed recruiter. The victims filed a case for Illegal recruitment in large scale and Estafa before the RTC in Manila. A warrant of arrest was issued against him.
In the meantime, he eluded arrest and escaped in the United States, where he is now presently residing.
The Philippines has an extradition treaty with the U.S., which does not include “illegal recruitment” as an extraditable crime. Estafa is included.
1. Juan comes to you for advice. He desires that Patrcik should be made answerable for the offense he committed. What should be your advice to Juan?
2. Patrick claims that he could not be extradited and tried because “illegal recruitment” is not an extraditable offense as listed in the treaty. Is he correct? Reason.
3. Upon an extradition request made by the Philippine government before the Department of Foreign Affairs in the U.S., is Patrick, under International Law, given the right to be furnished the copies of the extradition documents so that he can properly defend himself? Reason.
4. It is stated that a proceeding for extradition is a sui generis. What do you understand by this?
5. In the case at bar, is deportation applicable?
ANSWER:1. Juan should file first the criminal case for Estafa and illegal recruitment in the Court. Then he applies for an extradition request to Department of Foreign Affairs in the Philippines, who may, if it finds the request valid, may make the formal request to its counterpart in the USA.2.Patrick is wrong. Estafa is clearly listed, and even if illegal recruitment is not, it may be considered as an extraditable offense, depending on the congruity of the other listed cases. The sameness of the offense is not in its nomenclature but on the elements. 3. No, Patrick is not yet entitled to notice, since, the matter is still strictly between the agencies of both states. 4. sui generis means “a class by itself”, which means that the extradition can simply be characterized by the strict provision of the treaty. It is not a criminal, neither a civil case.5.Deportation from the Philippine viewpoint is not applicable Extradition is the surrender of a person by one state to another state where he is wanted for protection of, or if already convicted, for punishment.
It differs from deportation in that it is effected at the request of the state of origin whereas deportation is the unilateral act of the local state; it is based on offenses generally committed in the state of origin, whereas deportation is based on causes arising in the local state; and it calls for the return of the fugitive to the state of origin whereas an undesirable alien a may be deported to a state other than his own or the state of origin.

15. A. In extradition proceedings, are prospective extraditees entitled to notice and hearing before warrants for their arrest can be issued?
B. Equally important, are they entitled to the right to bail and provisional liberty while the extradition proceedings are pending? Reason out your answer in the light of the Mark Jimenez case.
C. In the Jimenez case, what are the so-called five postulates of extradition?
ANSWERS: NO. In general, the answer to these two novel questions is "No."
The five postulates are as follows:
1. Extradition Is a Major Instrument for the Suppression of Crime.
2. The Requesting State Will Accord Due Process to the Accused
3. The Proceedings Are Sui Generis
4. Compliance Shall Be in Good Faith.
5. Persons to be extradited are presumed to be flight risks

16. In the case of THE HOLY SEE vs. ERIBERTO U. ROSARIO, JR., ET AL. (G.R. No. 101949 December 1, 1994) the procedure is outlined pursuant to public international law in pleading sovereign or diplomatic immunity in a foreign court.
l. State the procedure.
2. In the United States the procedure followed is the process of “suggestion”. EXPLAIN THE “process of suggestion”
ANSWER: 1.In Public International Law, when a state or international agency wishes to plead sovereign or diplomatic immunity in a foreign court, it requests the Foreign Office of the state where it is sued to convey to the court that said defendant is entitled to immunity.

2.In the United States, the procedure followed is the process of "suggestion," where the foreign state or the international organization sued in an American court requests the Secretary of State to make a determination as to whether it is entitled to immunity. If the Secretary of State finds that the defendant is immune from suit, he, in turn, asks the Attorney General to submit to the court a "suggestion" that the defendant is entitled to immunity. In England, a similar procedure is followed; only the Foreign Office issues a certification to that effect instead of submitting a "suggestion" (O'Connell, I International Law 130 [1965]; Note: Immunity from Suit of Foreign Sovereign Instrumentalities and Obligations, 50 Yale Law Journal 1088 [1941]).
In the Philippines, the practice is for the foreign government or the international organization to first secure an executive endorsement of its claim of sovereign or diplomatic immunity. But how the Philippine Foreign Office conveys its endorsement to the courts varies.
In the case at bench, the Department of Foreign Affairs, through the Office of Legal Affairs moved with this Court to be allowed to intervene on the side of petitioner. The Court allowed the said Department to file its memorandum in support of petitioner's claim of sovereign immunity.
In some cases, the defense of sovereign immunity was submitted directly to the local courts by the respondents through their private counsels (Raquiza v. Bradford, 75 Phil. 50 [1945]; Miquiabas v. Philippine-Ryukyus Command, 80 Phil. 262 [1948]; United States of America v. Guinto, 182 SCRA 644 [1990] and companion cases). In cases where the foreign states bypass the Foreign Office, the courts can inquire into the facts and make their own determination as to the nature of the acts and transactions involved
17. How was immunity from suit invoked/or conveyed in the following cases?
(a) International Catholic Migration Commission v. Calleja, 190 SCRA 130 (1990),
(b) World Health Organization v. Aquino, 48 SCRA 242 (1972)

ANSWER: (A)In International Catholic Migration Commission v. Calleja, 190 SCRA 130 (1990), the Secretary of Foreign Affairs just sent a letter directly to the Secretary of Labor and Employment, informing the latter that the respondent-employer could not be sued because it enjoyed diplomatic immunity.
(B)In World Health Organization v. Aquino, 48 SCRA 242 (1972), the Secretary of Foreign Affairs sent the trial court a telegram to that effect. In Baer v. Tizon, 57 SCRA 1 (1974), the U.S. Embassy asked the Secretary of Foreign Affairs to request the Solicitor General to make, in behalf of the Commander of the United States Naval Base at Olongapo City, Zambales, a "suggestion" to respondent Judge. The Solicitor General embodied the "suggestion" in a Manifestation and Memorandum as amicus curiae.

18.There are two Minucher cases decided by the Supreme Court. State the respective issues and rulings of the respective cases.
Answer: The first Minucher case concerns the validity of Scalzo’s claim for immunity. The SC ruled that it must be duly invoked and must be threshed out during trial. In the second Minucher case, the SC ruled that the proof submitted by Scalzo as to his immunity was sufficient, hence the case against him was duly dismissed.

19.Explain the folllowing fundamental principles of extradition:

a. principle of specialty-only listed crimes are subject to extradition.
b. nationality principle of criminal jurisdiction-the state may refuse to extradite its nationals which may simply be subjected to its own penal law.
c. attentat clause-that the murder of a head of state or any member of his family shall not be considered as a political offense, hence extraditable.
d. rule on double criminality- the at for which the extradition is sought must be punishable in both the requesting and requested states.
e. “political and religious leader rule”-political and religious leaders are generally not extraditable.

20.Distinguish the following:

a. dispute from a situation- a situation is merely the initial stage of a dispute, which involves now an actual disagreement.
b.retorsion from reprisal- Retorsion is any action taken in retaliation where the acts complained of do not constitute a legal ground of offense but are rather in the nature of unfriendly acts but indirectly hurtful of the other states. The act of retaliation is also unfriendly or of different nature than the act that provoked it. Examples: Severance of diplomatic or consular relations, suspension of commercial intercourse, boycott, stoppage of travel to the other state, denunciation of treaties, imposition of higher tariff rates and other trade barriers, currency restrictions, denial of loans and withdrawal of privileges previously enjoyed, recognition of a rival government, and adverse propaganda.
Reprisals are acts of self-help on the part of an injured stat, responding after an unsatisfied demand to act contrary to international law on the part of the offending state. They have an effect of suspending momentarily in the relations of the tow states the observance of this or that rule of international law. They aim to impose of the offending state reparation for the offense or the return to legality in avoidance of new offenses. Examples. Display of force, occupation of territory, embargo, and pacific blockade.

c.preventive from enforcement action- ENFORCEMENT ACTION involves the use of military force while preventive does not.
d.military necessity from chivalry- Military necessity—the belligerent may, subject to the other two principles, employ any amount and kind of force to compel the complete submission of the enemy with the least possible loss of lives, time and money. Principles of chivalry- require belligerents to give proper warning before launching a bombardment or prohibit the use of perfidy in the conduct of hostilities.

e.armistice from suspension of arms-armisticeis the cessation of all hostilities agreed upon by to belligerent governments, for a political purpose, by the commander-in-chiefs, and must be written.Suspension is lower in the sense that it is merely forged by local commanders for military purposes and may even be oral.

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