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Reopening Of Courts In GCQ Areas; Bayanihan Act IRRs 

by John Christian Joy Regalado

Published: May, 2020

Submission: May, 2020


This is a briefing on the following issuances as of May 4, 2020 in relation to the COVID-19 pandemic:A. Courts in Areas under General Community Quarantine (GCQ) to Reopen on May 4, 2020B. Reduced Bail and Release on Recognizance for Indigent DetaineesC. Bayanihan Act IRRs and Other Issuances

A. Courts in Areas under General Community Quarantine (GCQ) to Reopen on May 4, 2020

  1. Supreme CourtAdministrative Circular No. 36-2020[1](Re: Areas Placed Under General Community Quarantine from 1 to 15 May 2020, dated April 27, 2020) directs the opening of all court branches in areas covered by the General Community Quarantine (GCQ)[2]beginning May 4, 2020, but they “shall function only with a skeleton-staff to assist the judge, and shall act only on urgent matters.”There is an enumeration of the areas under GCQ in the circular.High-risk areas, which include Metro Manila, are under Enhanced Community Quarantine (ECQ) until May 15, 2020 and courts in such places continue to be physically closed (seeSC Administrative Circular No. 35-2020[3]).
  2. The circular further laid out the following conditions:a. Courts in areas under GCQ shall operate from 9:00 AM- 3:00 PM. Night courts and Saturday courts remain suspended until May 15, 2020. All hearings in these GCQ areas shall remain suspended until May 15, 2020, except those on urgent matters. Judges have the discretion to “set for hearing other urgent matters or concerns to expedite the proceedings or the disposition of the cases pending before the courts.” Urgent matters include, but are not limited to, bail andhabeas corpusproceedings, promulgation of judgments of acquittals, reliefs for arrests, and other matters (seeSC Administrative Circular No. 31-2020[4],which we discussed in our bulletin released on March 18, 2020[5]).b. The online filing of (i) criminal complaints and information, (ii) posting of bail, and (iii) submission of other urgent pleadings may be availed of until May 15, 2020. The “filing of petitions, appeals, complaints, motions, pleadings and other court submissions that fall due up to [May 15, 2020] in a GCQ area is extended for 30 calendar days, counted from [May 16, 2020], but pleadings and other court submissions may still be filed by the parties within the reglementary period on or before [May 15, 2020] through electronic means, if preferred and able.”c. Drafted decisions and orders which were made before and during the GCQ may still be promulgated and released during this period, but no hearings are necessary except upon urgent matters. The “service of writs and other court processes on urgent matters within GCQ areas shall proceed.” The periods for court actions in the GCQ areas shall “also be extended for 30 calendar days counted from [May 16, 2020], except court actions on urgent matters.”d. For judges and court personnel (i) who are more than fifty-nine (59) years old, and (ii) with medical conditions which make them vulnerable to a COVID-19 infection, they shall work from their respective residences. Only in “exceptional circumstances” may these persons report to court to act on urgent matters. No court records may be taken out of the court’s premises by these persons.e. Lawyers who are more than fifty-nine (59) years old may attend hearings on urgent matters, except those who “are suffering from any illness” or “appear sickly and weak”. Younger lawyers, if available, should be sent instead. The court appearances shall be limited to urgent matters, and not for trial proper.f. Persons going to court shall observe medical standards and hygiene practices within the court, through (i) obligatory temperature check, (ii) compulsory wearing of face masks, (iii) regular use of alcohol for sanitation, (iv) application of disinfectants within court premises, (v) social or physical distancing, (vi) proper handwashing, and (vii) cough etiquette.For more information about the issuance discussed above, please contact your account partner or the author of this client bulletin: John Christian Joy A. Regalado, Partner,[email protected]

B. Reduced Bail and Release on Recognizance for Indigent Detainees

  1. The Supreme Court has allowed the reduction of bail and the release of indigent detainees on their own recognizance by issuing SC Administrative Circular No. 38-2020 (Reduced Bail and Recognizance as Modes for Releasing Indigent Persons Deprived of Liberty During This Period of Public Health Emergency, Pending Resolution of Their Cases, dated April 30, 2020)[6]. The SC cited the urgent need to decongest the detention facilities and the promotion of social and restorative justice.
  2. The circular provides the following:a. “For [detainees] charged with a crime punishable with the maximum period ofprision correccionalor six (6) months and one (1) day to six (6) years, bail shall be computed by getting the medium period multiplied by [PHP 1,000.00] for every year of imprisonment.”b. “For [detainees] charged with a crime punishable byarresto mayoror one (1) month and one (1) day to six (6) months, andarresto menoror one (1) day to thirty (30) days, they may be released on their own recognizance”.c. Any violation on the bail or recognizance conditions shall (i) be a ground for the cancellation of the bail or recognizance, and (ii) justify the issuance of an arrest warrant against the accused.
  3. For indigent inmates who have not yet been arraigned, they shall be arraigned before being granted bail or recognizance, which shall be done through videoconferencing. Those who have already been arraigned may avail of the benefits under the circular, “unless they have already served the minimum imposable penalty for the crime they are accused, in which case, they may be released on their own recognizance.”
  4. The circular shall not apply to persons already serving sentence. It is also without prejudice to the court’s discretion to deny bail or recognizance when justified.For more information about the issuance discussed above, please contact your account partner or the author of this client bulletin: John Christian Joy A. Regalado,Partner,[email protected]

C. Bayanihan Act IRRs and Other Issuances

Government AgencyIssuanceSummary

Grace Periods

Securities and Exchange Commission (SEC)Extension of the Mandatory Grace Period for Loans During the Extended Enhanced Community Quarantine Period (SEC Noticedated April 29, 2020)[7]This issuance directs “financing companies, lending companies, and microfinance NGOs” to extend the 30-day grace period under Section 4(aa) of R.A. No. 11469 or theBayanihan to Heal As One Act (Bayanihan Act)to “all borrowers with payments due within the extended ECQ period” from March 17, 2020 to May 15, 2020.
Philippine Health Insurance Corporation (PhilHealth)Payment of Premium for all Direct Contributors (PhilHealth Advisory No. 2020-027dated April 24, 2020)[8]This issuance provides for a “moratorium on contribution payments for the applicable months of February to April 2020. Payment of premiums for these applicable months shall be extended until May 31, 2020 without interest for all Direct Contributors.”
Philippine Economic Zone Authority (PEZA)PEZA Provides Grace Period for Rents, Utilities, Old Unpaid Accounts, and Processing Fees (PEZA Memorandum Circular No. 2020-0023dated April 18, 2020)[9]This implements theBayanihan Actby granting a 90-day grace period for payment of rents in public ecozones and a 30-day grace period for payment of utilities. A 90-day grace period is also granted for the payment of “old unpaid accounts covering the months of January to March 2020 prior to the implementation of the ECQ.” The circular also provides for a 15-day grace period for the payment of processing fees.
Philippine Ports Authority (PPA)Grace Period for Rents and Concession Fees for PPA Lessees and Port Terminal Operators (PPA Memorandum Circular No. 17, Series of 2020dated April 23, 2020)[10]This implements Section 4(bb) of theBayanihan Act[11]by granting a minimum of 30-day grace period for the payment of rental and concession fees “falling within the ECQ period, without incurring interest, penalties, fees and other charges” for “qualified PPA lessees and port terminal operators.” Upon the expiration of the grace period, a “12% interest and 25% penalty charges per annum will be imposed on late payment.”
Department of Transportation (DOTr, Civil Aviation Authority of the Philippines (CAAP), and Manila International Airport Authority (MIAA)Extension of Rental Holidays to May 15 for Airport Concessionaires (DOTr – CAAP – MIAA Press Releasedated May 2, 2020)[12]This announces the CAAP’s extension of deferment of “collection of several fees and charges, including lease or rental fees from airport concessionaires” until May 15, 2020. “A one-year deferment [(i.e., from March 12, 2020 to March 12, 2021)] of the collection of landing/take-off and parking fees for domestic and international flights” has also been implemented.The MIAA has also deferred the “collection of aeronautical fees of local carriers” for one year from March 1, 2020. “Rental charges of all concessionaires operating at the terminals … are also waived” from March 15 until the end of the ECQ period.

Extensions for Filing of Pleadings

Department of Trade and Industry (DTI)Guidelines on the Interruption of the Periods Related to the Filing of Appeals Before the Office of the Secretary and Suspension of Rendition of Judgments and Other Actions (Memorandum Circular No. 20-20dated April 27, 2020)[13]This implements Section 4(z) of theBayanihan Act[14]by granting parties “15 calendar days from the lifting of the ECQ to file … appeals, pleadings, and other papers.” The rendition of judgments and other actions is also suspended during the ECQ period. Urgent cases “necessary to enable to government to act expeditiously on matters affecting the current public health emergency” are excluded from the interruption and suspension of periods.

Data Privacy

Department of Health (DOH) and National Privacy Commission (NPC)Privacy Guidelines on the Processing and Disclosure of COVID-19 Related Data for Disease Surveillance and Response (Joint Memorandum Circular No. 2020-0002dated April 24, 2020)[15]This sets out “the guidelines for the collection, processing and disclosure of COVID-19-related data in pursuit of disease surveillance and response, while protecting the data privacy rights of patients and individuals and ensuring the confidentiality, integrity, and availability of their personal data.”
Subsidies and Assistance
Department of Finance (DOF)Extension of Application Period for Small Business Wage Subsidy (DOF Advisorydated April 24, 2020)[16]This advisory extends the application period for the Small Business Wage Subsidy Program from April 30, 2020, to May 8, 2020.
Guidelines for the Availment of the Small Business Wage Subsidy Measure (Joint Memorandum Circular No. 001-2020dated April 28, 2020)[17]This circular prescribes guidelines for the availment of the Small Business Wage Subsidy Program. The circular sets out the eligibility criteria for both employers and employees, additional conditions for the grant of the subsidy, and other general guidelines.
Department of Labor and Employment (DOLE)Realignment of Budget to Aid Workers (DOLE News Releasedated April 29, 2020)[18]This announces the DOLE’s realignment of PhP1.5B from its 2020 budget to give assistance to additional 300,000 workers under the COVID-19 Adjustment Measures Program (CAMP). The DOLE will also disburse PhP1B from realigned funds for the Tulong Panghanapbuhay sa Ating Disadvantaged/Displaced Workers (TUPAD) program starting May.
Department of Interior and Local Government (DILG)Rationalizing the Establishment of an LGU Task Force Against COVID-19 (DILG Memorandum Circular No. 2020-077dated April 24, 2020)[19]This circular implements Section 4(g) of theBayanihan Act[20]by mandating LGUs to create a Local Task Force Against COVID-19. The circular enumerates the members and teams comprising the Task Force and the protocols to be adopted for identifying and treating possible COVID-19 patients.
Banking Regulations
Bangko Sentral ng Pilipinas (BSP)Fees on Interbank Fund Transfer and ATM Transactions (BSP Memorandum No. M-2020-031dated April 25, 2020)[21]This issuance encourages BSFIs to suspend the fees charged for “other fund transfer services and interbank ATM transactions,” in light of the “extraordinary circumstances” brought by the COVID-19 pandemic.
Waiver of Fees Related to the Grant of License or Authority to Provide Types A and B Advanced Electronic Payments and Financial Services (EFPS) as Additional Relief for BSFIs (BSP Memorandum No. M-2020-033dated April 27, 2020)[22]This issuance waives the charges for “filing, processing, and licensing/registration fees related to the grant of Type A and B EPFS license.” Type A license “applies to BSFIs that can be assessed against the prudential criteria provided under the Policy and Regulations on Licensing” while Type B license applies to those which cannot be assessed.The waiver of fees is applicable to “applications received within six months from 8 March 2020” which “may be extended subject to the approval of the Monetary Board.”
Extension of the Temporary Relief Measure on the Transactions withPhilPaSSduring the Enhanced Community Quarantine (ECQ) under the Corona Virus Disease (CoVID-19) Situation, Covering the Period 4 May to 15 May 2020 (BSP Memorandum No. M-2020-035dated April 28, 2020)[23]This issuance extends the waiver of the waiver of the transaction fees charged for fund transfer instructions made with the Philippine Payment and Settlement System (PhilPaSS) until May 15, 2020.
Availability of Digital Financial Services During the Enhanced Community Quarantine (ECQ) Period (BSP Memorandum No. M-2020-030dated April 24, 2020)[24]This issuance urges BSP-supervised financial institutions (BSFIs) to “ramp up access of existing account holders to mobile/internet banking and other alternative digital channels.”
Amendments to the Regulatory Relief for BSFIs Affected by the Corona Virus Disease (COVID-19) (BSP Memorandum No. M-2020-032dated April 27, 2020)[25]This issuance provides that the "exclusion from the past due and non-performing classification" of loans has been extended from March 8, 2021 to December 31, 2021.
Relaxation in the Credit Risk Weight for Loans to MSMEs under the BSP’s Risk-Based Capital Adequacy Frameworks (BSP Memorandum No. M-2020-034dated April 28, 2020)[26]This issuance allows the “temporary relaxation in the assigned credit risk weight for loans to MSMEs for purposes of computing compliance with BSP’s Risk-Based Capital Adequacy Frameworks.” The Memorandum provides that “[t]he following exposures to MSMEs … shall be assigned a credit risk weight of 50 percent: (a) MSME exposures that meet the criteria of a qualified MSME portfolio, and (b) Current MSME exposures that do not qualify as a highly diversified MSME portfolio.”This issuance will be in effect until December 31, 2021.
Amendments to the Risk-Based Capital Adequacy Frameworks for Banks/Quasi-Banks (BSP Circular No. 1084, series of 2020dated April 28, 2020)[27]This issuance reduces the risk weight of “[l]oans to small farmer and fisherfolk to the extent guaranteed by the Agricultural Guarantee Fund Pool (AGFP)” from 20% to 0%. The issuance also qualifies the status of AGFP as an eligible guarantor only for the period “prior to the transfer of the administration of AGFP to the [Philippine Guarantee Corporation].”
Sustainable Finance Framework (BSP Circular No. 1085dated April 29, 2020)[28]This incorporates a “sustainable finance policy framework” in the Manual of Regulations for Banks which “sets out the expectations of the [BSP] on the integration of sustainability principles, including those covering environmental and social risk areas, in the corporate governance and risk management frameworks as well as in the strategic objectives and operations of banks.”All banks are required to implement a sustainable finance framework within “3 years from the effectivity of [the] Circular.”Branches of foreign banks are allowed to adopt policies of their Head Office which are in line with BSP’s framework.
Reminder Against Financial Crimes Amidst COVID-19 Pandemic (BSP Memorandum No. M-2020-036dated April 29, 2020)[29]This issuance reminds BFSIs to take precautions against “[n]ew forms of money laundering/terrorism financing (ML/TF).” The BSP enumerated the illegal schemes, namely: donation or charity scams, impostor, investment, and product scams, money mules, online sex trafficking and exploitation, and veiled donations for terrorism and terrorism financing. The BSP advised BSFIs “to consider said criminal activities and typologies in their [anti-money laundering/combating the financing of terrorism] controls and compliance processes in order to manage the ML/TF threats and to accordingly report suspicious transactions to the Anti-Money Laundering Council.”
Stock Exchange Regulations
Philippine Stock Exchange (PSE)Shortened Trading Hours Extended to May 15, 2020 (PSE Memorandum CN – No. 2020-0042dated April 27, 2020)[30]This issuance extends the PSE’s shortened trading hours until May 15, 2020.
Amendment of Circuit Breaker Rules (PSE Memorandum CN – No. 2020-0044dated April 29, 2020)[31]Starting May 4, 2020, the PSE will be adopting a “three-phase circuit breaker system.”Trading in the stock market will be temporarily halted for a certain period of time (market halt) in case the PSE composite index falls below certain thresholds: (i) a decrease in the PSEI by at least 10% from its previous closing level will result in a 15 minute market halt, (ii) a decrease by at least 15% will result in a 30 minute market halt, and (iii) a decrease by at least 20% will result in a 60-minute market halt. The market halts shall be implemented “once in a trading day for each [circuit breaker] level.”
Maritime Industry Authority (MARINA)

Guidelines for Seafarers Onboard Ships Operating in Philippine Waters Amid Challenges Caused by COVID 19 Pandemic(MARINA Advisory No. 2020-026dated April 14, 2020)[32]

This provides guidelines for the extension of Seafarer’s Record Book or Seafarers’ Identification Record, the filing of applications with the MARINA “upon lifting of the ECQ and issuance of a return-to-work order,” rescheduling of appointments with the MARINA, and the “conduct of examinations for the Certificate of Marine Profession.”
Extension of SIRB/SRB Validity for the Duration of the Enhanced Community Quarantine (ECQ)(MARINA Advisory No. 2020-27dated April 20, 2020)[33]This grants a provisional extension “of 6 months validity” from the date of expiration of the “Seafarer’s Record Book (SRB) or Seafarer’s Identification and Record Book (SIRB)” for SRBs and SIRBs with expiry dates falling between March 13, 2020 and May 31, 2020.The provisional extension applies “to both domestic and overseas seafarers.”

[1]SC Administrative Circular No. 36-2020, dated April 27, 2020;http://sc.judiciary.gov.ph/11258/;last visited at 10:41 AM on May 2, 2020.

[2]The GCQ over places in the Philippines which are not considered to be high-risk areas commenced on May 1, 2020.[3]SC Administrative Circular No. 35-2020, dated April 27, 2020;http://sc.judiciary.gov.ph/11246/;last visited at 5:16 PM on May 4, 2020.

[4]SC Administrative Circular No. 31-2020, dated March 16, 2020;http://sc.judiciary.gov.ph/11037/;last visited at 10:41 AM on May 2, 2020.

[5]For more information aboutSC Administrative Circular No. 31-2020,see our bulletin dated March 18, 2020;https://us5.campaign-archive.com/?u=7487080697dfcf9da2744850e&id=3e83e2d33e

[6]SC Administrative Circular No. 38-2020 dated April 30, 2020;http://sc.judiciary.gov.ph/11306/;last visited at 10:41 AM on May 2, 2020.

[7]SEC Notice dated April 29, 2020;http://www.sec.gov.ph/wp-content/uploads/2020/04/2020Notice_Mandatory-Grace-Period.pdf;last visited at 3:00 pm on May 2, 2020.

[8]PhilHealth Advisory No. 2020-0027 dated April 24, 2020;https://www.philhealth.gov.ph/advisories/2020/adv2020-0027.pdf;last visited at 5:00 pm on May 2, 2020.

[9]PEZA Memorandum Circular No. 2020-0023 dated April 18, 2020;http://www.peza.gov.ph/documents/mc2020023.pdf;last visited at 4:55 PM on April 27, 2020.

[10]PPA Memorandum Circular No. 17, Series of 2020 dated April 23, 2020;https://www.ppa.com.ph/sites/default/files/issuances_docs/MC%20No.%2017-2020.pdf;last visited at 4:40 PM on April 27, 2020

.[11]Bayanihan Act,Section 4(bb). Provide for a minimum of thirty (30)-day grace period on residential rents falling due within the period of the enhanced community quarantine, without incurring interests, penalties, fees, and other charges.

[12]Extension of Rental Holidays to May 15 for Airport Concessionaires,DOTr – CAAP – MIAA Press Release dated May 2, 2020;https://www.facebook.com/DOTrPH/posts/1686739648131831;last visited at 3:34 PM on May 2, 2020.

[13]DTI Memorandum Circular No. 20-20 dated April 27, 2020;https://dtiwebfiles.s3-ap-southeast-1.amazonaws.com/COVID19Resources/COVID-19+Advisories/300420_MC2020.pdf;last visited at 2:53 PM on May 1, 2020.

[14]Bayanihan Act,Section 4(z). Move statutory deadlines and timelines for the filing and submission of any document, the payment of taxes, fees, and other charges required by law, and the grant of any benefit, in order to ease the burden on individuals under Community Quarantine.

[15]DOH and NPC Joint Memorandum Circular No. 2020-0002 dated April 24, 2020;https://dmas.doh.gov.ph:8083/Rest/GetFile?id=653115;last visited at 2:25 PM on May 1, 2020.[16]

DOF Advisory dated April 24, 2020;https://sites.google.com/dof.gov.ph/small-business-wage-subsidy;last visited at 2:26 pm on April 26, 2020.

[17]Joint Memorandum Circular No. 001-2020 dated April 28, 2020;https://www.bir.gov.ph/images/bir_files/internal_communications_2/RMCs/2020%20RMCs/RMC%20No.%2045-2020%20JMC%20No.%20001-2020.pdf;last visited at 2:00 pm on May 2, 2020.BIR Revenue Memorandum Circular No. 45-2020 dated April 30, 2020;https://www.bir.gov.ph/images/bir_files/internal_communications_2/RMCs/2020%20RMCs/RMC%20No.%2045-2020.pdf;last visited at 2:01 pm on May 2, 2020.

[18]DOLE Realigns Budget to Aid Workers,DOLE News Release dated April 29, 2020;https://www.dole.gov.ph/news/dole-realigns-budget-to-aid-workers/?fbclid=IwAR2ukCWEMdlrv0xaRFjrwGHoPfc1ihhQeU0yUXeIGVzXDnCDYf-9eomn2GI#;last visited at 3:23 PM on May 1, 2020.

[19]DILG Memorandum Circular No. 2020-077 dated April 24, 2020;https://www.dilg.gov.ph/PDF_File/issuances/memo_circulars/dilg-memocircular-2020424_a6a4af4ba9.pdf;last visited at 2:19 PM on April 26, 2020.

[20]Bayanihan Act,Section 4(g).Ensure that all Local Government Units (LGUs) are acting within the letter and spirit of all the rules, regulations and directives issued by the National Government pursuant to this Act; are implementing standards of Community Quarantine consistent with what the National Government has laid down for the subject area, while allowing LGUs to continue exercising their autonomy in matters defined by the National Government or are within the parameters it has set; and are fully cooperating towards a unified, cohesive and orderly implementation of the national policy to address COVID-19:Provided, That all LGUs shall be authorized to utilize more than five percent (5%) of the amount allocated for their calamity fund subject to additional funding and support from the National Government.

[21]BSP Memorandum No. M-2020-031 dated April 25, 2020;https://drive.google.com/file/d/1vs8A7yNLNQEniUc21lMTmbka6CnPH_63/view;last visited at 1:05 pm on May 1, 2020.

[22]BSP Memorandum No. M-2020-033 dated April 27, 2020;https://drive.google.com/file/d/14zegV3kqIQifT8mQnzlZ_MFP_NsQLJME/view;last visited at 1:10 pm on May 1, 2020.

[23]BSP Memorandum No. M-3030-035 dated April 28, 2020;https://drive.google.com/file/d/135U1ls-xSxo45h3dXUb_f2UVoeduM97z/view;last visited at 5:00 pm on May 1, 2020.

[24]BSP Memorandum No. M-2020-030 dated April 24, 2020;https://drive.google.com/file/d/1aDCzg-YjlxgNzehM3rNK0o_lS5uwzdTH/view;last visited at 1:00 pm on May 1, 2020.

[25]BSP Memorandum No. M-2020-032 dated April 27, 2020;https://drive.google.com/file/d/1IWe8h84eg3ciafrLr4cmEgDmcNLDSCf_/view;last visited at 2:00 pm on May 1, 2020.

[26]BSP Memorandum No. M-2020-034 dated April 28, 2020;https://drive.google.com/file/d/1xns3zUB9SrOahfDMURUkZacZjNhaCazm/view;last visited at 5:15 pm on May 1, 2020.[27]BSP Circular No. 1084, series of 2020;https://drive.google.com/file/d/1cKntUpVcq-ofVo9nukvpAfAn-Ir60LXF/view;last visited at 8:30 pm on May 1, 2020.

[28]BSP Circular No. 1085 dated April 29, 2020;https://drive.google.com/file/d/1gXlU1PAbvFWHTzhMaLqpxghptWN4Nk4r/view;last visited at 9:00 pm on May 1, 2020.[29]BSP Memorandum No. M-2020-036 dated April 29, 2020;https://drive.google.com/file/d/1kuR1GBI3quWEQbEdC_zGk3z9lIE6fTVQ/view;last visited at 5:30 pm on May 1, 2020.

[30]PSE Memorandum CN – No. 2020-0042 dated April 27, 2020;https://www.pse.com.ph/resource/memos/2020/CN_2020-0042.pdf;last visited at 4:15 pm on May 2, 2020.

[31]PSE Memorandum CN - No. 2020-0044 dated April 29, 2020;https://www.pse.com.ph/resource/memos/2020/CN_2020-0044.pdf;last visited at 4:11 PM on May 2, 2020

.[32]MARINA Advisory No. 2020-026 dated April 14, 2020;https://marina.gov.ph/wp-content/uploads/2020/04/MA-2020-26.pdf;last visited at 2:02 pm on April 26, 2020.

[33]MARINA Advisory No. 2020-027 dated April 20, 2020;https://marina.gov.ph/wp-content/uploads/2020/04/MA-2020-27.pdf;last visited at 2:03 pm on April 26, 2020.


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