CONSTI REVIEW DIGEST JUNE 18, 2018 Convention and other rules of international law in so far as
they are not incompatible with this Part. The Tribunal
Philippines vs. China, Award, PCA Case No. 2013-19, July 12,
2016
Issue: Is China’s claim to historic rights, or other sovereign
rights or jurisdiction, with respect to the maritime areas of
the South China Sea encompassed by the relevant part of
the ‘nine-dash line’ – valid and tenable?
Ruling:No. China’s claim is contrary to the Convention and
without lawful effect to the extent that they exceed the
geographic and substantive limits of China’s maritime
entitlements under the Convention; furthermore, the
Convention superseded any historic rights, or other sovereign
rights or jurisdiction, in excess of the limits imposed therein.
Issue: Do Mischief Reef, Second Thomas Shoal, Reed Bank,
Subi Reef, Gaven Reef, Hughes Reef, Scarborough Shoal
Mckennan Reef, Johnson reef, Cuarteron Reef and Fiery
Cross Reef constitute a fully entitled islands which have the
capacity to generate entitlement to exclusive economic
zones or continental shelves?
Ruling: Scarborough Shoal generates no entitlement to an
exclusive economic zone or continental shelf. Mischief Reef,
Second Thomas Shoal and Subi Reef are low-tide elevations
that do not generate entitlement to a territorial sea, exclusive
economic zone or continental shelf, and are not features that
are capable of appropriation by occupation or otherwise.
Mischief Reef and Second Thomas Shoal are part of the
exclusive economic zone and continental shelf of the
Philippines. Gaven Reef and McKennan Reef (including
Hughes Reef) are low-tide elevations that do not generate
entitlement to a territorial sea, exclusive economic zone or
continental shelf, but their low-water line may be used to
determine the baseline from which the breadth of the
territorial sea of Namyit and Sin Cowe, respectively, is
measured. Johnson Reef, Cuarteron Reef and Fiery Cross
Reef generate no entitlement to an exclusive economic zone
or continental shelf.
Issue: Does China have overlapping entitlements to an
exclusive economic zone or continental shelf in the areas of
Mischief Reef or Second Thomas Shoal?
Ruling: No. Mischief Reef and Second Thomas Shoal are not
capable of generating entitlements
to maritime zones and can only form part of the Philippines’
exclusive economic zone. Article 58(3) of the Convention
provides as follows:
In exercising their rights and performing their duties under
this Convention in the exclusive economic zone, States shall
have due regard to the rights and duties of the coastal State
and shall comply with the laws and regulations adopted by
the coastal State in accordance with the provisions of this
considers that China has failed to show the due regard called
for by Article 58(3) of the Convention to the Philippines’
sovereign rights with respect to fisheries within its exclusive
economic zone. Accordingly, China has breached its
obligations under Article 58(3) of the Convention.
ISSUE: Does China’s land reclamation and/or construction of
artificial islands, installations and structures at Cuarteron
Reef, Fiery Cross Reef, Gaven Reef (North), Johnson Reef,
Hughes Reef, Subi Reef, and Mischief Reef constitute
“military activities” and at the same time breach Philippines’
sovereign rights in its exclusive economic zone and
continental shelf?
RULING:NO. The Tribunal finds that China’s land reclamation
and/or construction of artificial islands, installations, and
structures at Cuarteron Reef, Fiery Cross Reef, Gaven Reef
(North), Johnson Reef, Hughes Reef, Subi Reef, and Mischief
Reef do not constitute “military activities”, within the
meaning of Article 298(1)(b) of the Convention, and that the
Tribunal has jurisdiction to consider the Philippines’
Submissions No. 11 and 12(b) YES. The Tribunal declares that
China has breached Articles 60 and 80 of the Convention with
respect to the Philippines’ sovereign rights in its exclusive
economic zone and continental shelf
The Tribunal will not deem activities to be military in
nature when China itself has consistently resisted such
classifications and affirmed the opposite at the highest level.
Accordingly, the Tribunal accepts China’s repeatedly affirmed
position that civilian use comprises the primary (if not the
only) motivation underlying the dramatic alterations on
Mischief Reef. As civilian activity, the Tribunal notes that
China’s conduct falls outside the scope of Article 298(1)(b)
and concludes that it has jurisdiction to consider the
Philippines’ Submission. The Tribunal takes China at its word
that the original purpose of the structures was to provide
shelter for fishermen and concludes that this is an economic
purpose. The Tribunal also notes that the original structures,
which China declined to permit fishermen from the
Philippines to use, also had the potential to interfere with the
exercise by the Philippines of its rights in the exclusive
economic zone. Accordingly, pursuant to Article 60 of the
Convention, only the Philippines could construct or authorize
such structure.
Issue: Who has a better right over the fishing grounds of
Scarborough Shoal: Chinese fishermen, Philippine fishermen,
or fishermen of many nationalities?
Ruling: The Tribunal is of the view that Scarborough Shoal has
been a traditional fishing ground for fishermen of many
nationalities, including the Philippines, China (including from
Taiwan), and Viet Nam. The stories of most of those who
have fished at Scarborough Shoal in generations past have
not been the subject of written records, and the Tribunal
considers that traditional fishing rights constitute an area
where matters of evidence should be approached with
sensitivity. That certain livelihoods have not been considered
of interest to official record keepers or to the writers of
history does not make them less important to those who
practise them. With respect to Scarborough Shoal, the
Tribunal accepts that the claims of both the Philippines and
China to have traditionally fished at the shoal are accurate
and advanced in good faith.
Additional (for recit purposes only): The Tribunal is satisfied
that the complete prevention by China of fishing by Filipinos
at Scarborough Shoal over significant periods of time after
May 2012 is not compatible with the respect due under
international law to the traditional fishing rights of Filipino
fishermen. This is particularly the case given that China
appears to have acted to prevent fishing by Filipinos,
specifically, while permitting its own nationals to continue.
Saguisag vs. Ochoa, G.R. No. 212426, Jan 12, 2016
Issue: For allowing the US a rent-free access and use of
Philppine bases and other “agreed locations” around the
country by the US troops and its vessels and with authority
to construct facilities thereat and to preposition and store
defense equipment, supplies and materiels at these
Philippine bases and other “agreed locations”, is EDCA
consistent with the content, purpose and framework of the
MDT and the VFA and not violative of Philippine
sovereignty?
Ruling: Yes, EDCA is consistent with MDT and VFA. The
facilities constructed, while built by U.S. forces, are to be
owned by the Philippines once finished. Even the VFA allowed
construction for the benefit of U.S. forces during their
temporary visits. Moreover, the VFA already allows the same
kind of equipment, vehicles, vessels, and aircraft to be
brought into the country. Furthermore, from the text of EDCA
itself, Agreed Locations are territories of the Philippines that
the U.S. forces are allowed to access and use. By withholding
ownership of these areas and retaining unrestricted access to
them, the Philippine government asserts sovereignty over its
territory.
Issue: For allowing nuclear weapons in the Philippines, is
EDCA invalid and unconstitutional?
Ruling: No. The charge that EDCA allows nuclear weapons
within Philippine territory is entirely speculative. The
agreement in fact specifies that the prepositioned materiel
shall not include nuclear weapons. Petitioners argue that only
prepositioned nuclear weapons are prohibited by EDCA; and
that, therefore, the U.S. would insidiously bring nuclear
weapons to Philippine territory. The general prohibition on
nuclear weapons, whether prepositioned or not, is already
expressed in the 1987 Constitution. It would be unnecessary
or superfluous to include all prohibitions already in the
Constitution or in the law through a document like EDCA.
There is no basis to invalidate EDCA on fears that it increases
the threat to our national security. If anything, EDCA
increases the likelihood that, in an event requiring a
defensive response, the Philippines will be prepared
alongside the U.S. to defend its islands and insure its
territorial integrity pursuant to a relationship built on the
MDT and VFA.
Imbong vs. Ochoa, G.R. No. 204819, April 8, 2014
Issue: Does R.A. No. 10354, The Responsible Parenthood
and Reproductive Health Act of 2012, violate the principle of
separation of the church and the state?
Ruling: Qualified. The principle of separation of Church and
State was enshrined in Article II, Section 6 of the 1987
Constitution, viz:
Section 6. The separation of Church and State shall be
inviolable.
In case of conflict between the free exercise clause and the
State, the Court adheres to the doctrine of benevolent
neutrality. The benevolent neutrality theory believes that
with respect to these governmental actions, accommodation
of religion may be allowed, not to promote the government's
favored form of religion, but to allow individuals and groups
to exercise their religion without hindrance. In the case at
bench, it is not within the province of the Court to determine
whether the use of contraceptives or one's participation in
the support of modem reproductive health measures is moral
from a religious standpoint or whether the same is right or
wrong according to one's dogma or belief. For the Court has
declared that matters dealing with "faith, practice, doctrine,
form of worship, ecclesiastical law, custom and rule of a
church ... are unquestionably ecclesiastical matters which are
outside the province of the civil courts." The jurisdiction of
the Court extends only to public and secular morality.
Whatever pronouncement the Court makes in the case at
bench should be understood only in this realm where it has
authority. Stated otherwise, while the Court stands without
authority to rule on ecclesiastical matters, as vanguard of the
Constitution, it does have authority to determine whether
the RH Law contravenes the guarantee of religious freedom.
Consequently, the petitioners are misguided in their
supposition that the State cannot enhance its population
control program through the RH Law simply because the
promotion of contraceptive use is contrary to their religious
beliefs. Indeed, the State is not precluded to pursue its
legitimate secular objectives without being dictated upon by
the policies of any one religion. One cannot refuse to pay his
taxes simply because it will cloud his conscience. The
demarcation line between Church and State demands that
one render unto Caesar the things that are Caesar's and
unto God the things that are God's.
While the RH Law, in espousing state policy to promote
reproductive health manifestly respects diverse religious
beliefs in line with the Non-Establishment Clause, the same
conclusion cannot be reached with respect to Sections 7, 23
and 24 thereof. The said provisions commonly mandate that
a hospital or a medical practitioner to immediately refer a
person seeking health care and services under the law to
another accessible healthcare provider despite their
conscientious objections based on religious or ethical beliefs.
In a situation where the free exercise of religion is allegedly
burdened by government legislation or practice, the
compelling state interest test in line with the Court's espousal
of the Doctrine of Benevolent Neutrality in Escritor, finds
application. In this case, the conscientious objector's claim to
religious freedom would warrant an exemption from
obligations under the RH Law, unless the government
succeeds in demonstrating a more compelling state interest
in the accomplishment of an important secular objective.
Necessarily so, the plea of conscientious objectors for
exemption from the RH Law deserves no less than strict
scrutiny.
The Court is of the view that the obligation to refer imposed
by the RH Law violates the religious belief and conviction of
a conscientious objector. Once the medical practitioner,
against his will, refers a patient seeking information on
modem reproductive health products, services, procedures
and methods, his conscience is immediately burdened as he
has been compelled to perform an act against his beliefs. As
Commissioner Joaquin A. Bernas (Commissioner Bernas) has
written, "at the basis of the free exercise clause is the respect
for the inviolability of the human conscience.
Issue: Does R.A. No. 10354, “The Responsible Parenthood
and Reproductive Health Act of 2012, violate the
constitutional right to life of the unborn?
Ruling: No. Majority of the Members of the Court believe that
the question of when life begins is a scientific and medical
issue that should not be decided, at this stage, without
proper hearing and evidence. However, they agreed that
individual Members could express their own views on this
matter.
Article II, Section 12 of the Constitution states:
“The State recognizes the sanctity of family life and shall
protect and strengthen the family as a basic autonomous
social institution. It shall equally protect the life of the mother
and the life of the unborn from conception.”
In its plain and ordinary meaning (a canon in statutory
construction), the traditional meaning of “conception”
according to reputable dictionaries cited by the ponente is
that life begins at fertilization. Medical sources also support
the view that conception begins at fertilization.
The framers of the Constitution also intended for
(a) “conception” to refer to the moment of “fertilization” and
(b) the protection of the unborn child upon fertilization. In
addition, they did not intend to ban all contraceptives for
being unconstitutional; only those that kill or destroy the
fertilized ovum would be prohibited. Contraceptives that
actually prevent the union of the male sperm and female
ovum, and those that similarly take action before fertilization
should be deemed non-abortive, and thus constitutionally
permissible.
The intent of the framers of the Constitution for protecting
the life of the unborn child was to prevent the Legislature
from passing a measure prevent abortion. The Court cannot
interpret this otherwise. The RH Law is in line with this intent
and actually prohibits abortion. By using the word “or” in
defining abortifacient (Section 4(a)), the RH Law prohibits not
only drugs or devices that prevent implantation but also
those that induce abortion and induce the destruction of a
fetus inside the mother’s womb. The RH Law recognizes that
the fertilized ovum already has life and that the State has a
bounded duty to protect it.
However, the authors of the IRR gravely abused their office
when they redefined the meaning of abortifacient by using
the term “primarily”. Recognizing as abortifacients only those
that “primarily induce abortion or the destruction of a fetus
inside the mother’s womb or the prevention of the fertilized
ovum to reach and be implanted in the mother’s womb” (Sec.
3.01(a) of the IRR) would pave the way for the approval of
contraceptives that may harm or destroy the life of the
unborn from conception/fertilization. This violates Section 12,
Article II of the Constitution. For the same reason, the
definition of contraceptives under the IRR (Sec 3.01(j)), which
also uses the term “primarily”, must be struck down.
Issue: Does R.A. No. 10354, “The Responsible Parenthood
and Reproductive Health Act of 2012, violate the
constitutional right to health and the right to protection
against hazardous products?
Ruling: No. A component to the right to life is the
constitutional right to health. In this regard, the Constitution
is replete with provisions protecting and promoting the right
to health. These provisions are self-executing. The legislative

intent in the enactment of the RH Law in this regard is to
leave intact the provisions of R.A. No. 4729. There is no
intention at all to do away with it. It is still a good law and its
requirements are still in to be complied with. With RA 4729
in place, the Court believes adequate safeguards exist to
ensure that only safe contraceptives are made available to
the public. In fulfilling its mandate under Sec. 10 of the RH
Law, the DOH must keep in mind the provisions of RA 4729:
the contraceptives it will procure shall be from a duly
licensed drug store or pharmaceutical company and that the
actual distribution of these contraceptive drugs and devices
will be done following a prescription of a qualified medical
practitioner. Thus, the Court agrees with the observation of
respondent Lagman that the effectivity of the RH Law will not
lead to the unmitigated proliferation of contraceptives since
the sale, distribution and dispensation of contraceptive drugs
and devices will still require the prescription of a licensed
physician. With R.A. No. 4729 in place, there exists adequate
safeguards to ensure the public that only contraceptives that
are safe are made available to the public
Meanwhile, the requirement of Section 9 of the RH Law is to
be considered “mandatory” only after these devices and
materials have been tested, evaluated and approved by the
FDA. Congress cannot determine that contraceptives are
“safe, legal, non-abortificient and effective”.
Re: Letter of Valenciano, A.m. no. 10-4-19-sc, March 7, 2017
ISSUE: Does holding of masses at the basement of the
Quezon City hall of justice violates the constitutional
principle of separation of church and state?
RULING: NO. The holding of religious rituals in the halls of
justice does not amount to a union of church and state. The
court once pronounced that "our history, not to speak of the
history of mankind, has taught us that the union of church
and state is prejudicial to both, for occasions might arise
when the state will use the church, and the church the state,
as a weapon in the furtherance of their respective ends and
aims. Justice Isagani Cruz expounded on this doctrine: “the
idea is to delineate the boundaries between the two
institutions and, thus, avoid encroachments by one against
the other because of a misunderstanding of the limits of their
respective exclusive jurisdictions. The demarcation line calls
on the entities to ‘render therefore unto caesar the things
that are caesar's and unto god the things that are god's.” The
state still recognizes the inherent right of the people to have
some form of belief system, whether such may be belief in a
supreme being, a certain way of life, or even an outright
rejection of religion.
International School Manila v. ISEA GR. No.167286Feb. 5,
2014
Issue: Shall separation bay be allowed as a measure of social
justice to all employees who have been dismissed?
Ruling: No. In Philippine Long Distance Telephone Co. (PLDT)
v. National Labor Relations Commission the Court ruled that
separation pay shall be allowed as a measure of social justice
only in those instances where the employee is validly
dismissed for causes other than serious misconduct or those
reflecting on his moral character. The policy of social justice is
not intended to countenance wrongdoing simply because it is
committed by the underprivileged. At best it may mitigate
the penalty but it certainly will not condone the offense.
Compassion for the poor is an imperative of every humane
society but only when the recipient is not a rascal claiming an
undeserved privilege. Social justice cannot be permitted to be
refuge of scoundrels any more than can equity be an
impediment to the punishment of the guilty. Those who
invoke social justice may do so only if their hands are clean
and their motives blameless and not simply because they
happen to be poor. This great policy of our Constitution is not
meant for the protection of those who have proved they are
not worthy of it, like the workers who have tainted the cause
of labor with the blemishes of their own character. (Can be
cut, I placed this for recit purposes)
This ruling has been modified by Toyota Motor Phils.
Corp. Workers Association v. National Labor Relations
Commission to include the as basis for not granting
separation pay: dismissals based on other grounds under Art.
282 like willful disobedience, gross and habitual neglect of
duty, fraud or willful breach of trust, and commission of a
crime against the employer or his family.
Cadiz vs Brent Hospital and Colleges, G.R. No. 187417,
February 24, 2016.
Issue: Is the condition imposed on Cadiz by Brent Hospital
and Colleges that “she subsequently contract marriage with
her then boyfriend for her to be reinstated” --- in
consonance with “the policy against encouraging illicit or
common-law relations that would subvert the sacrament of
marriage”?
Note: I think nay sayop sa pag formulate sa issue.
Ruling: No. Brent's condition is coercive, oppressive and
discriminatory. There is no rhyme or reason for it.1âwphi1 It
forces Cadiz to marry for economic reasons and deprives her
of the freedom to choose her status, which is a privilege that
inheres in her as an intangible and inalienable right.
Additional:
Statutory law is replete with legislation protecting labor and
promoting equal opportunity in employment. No less than
the 1987 Constitution mandates that the "State shall afford
full protection to labor, local and overseas, organized and
unorganized, and promote full employment and equality of
employment opportunities for all."
The Labor Code of the Philippines, meanwhile, provides:
Art. 136. Stipulation against marriage. It shall be unlawful for
an employer to require as a condition of employment or
continuation of employment that a woman employee shall
not get married, or to stipulate expressly or tacitly that upon
getting married, a woman employee shall be deemed
resigned or separated, or to actually dismiss, discharge,
discriminate or otherwise prejudice a woman employee
merely by reason of her marriage.
With particular regard to women, Republic Act No. 9710 or
the Magna Carta of Women protects women against
discrimination in all matters relating to marriage and family
relations, including the right to choose freely a spouse and to
enter into marriage only with their free and full consent.
FDCP vs Colon Heritage GR no. 203754, June 16,2015
Issue: Are Secs 13 and 14 of RA 9167 invalid for being
unconstitutional and violative of local fiscal autonomy?
Ruling: Yes. per RA 9167, covered LGUs still have the power
to levy amusement taxes, albeit at the end of the day, they
will derive no revenue therefrom. Taking the resulting
scheme into consideration, it is apparent that what Congress
did in this instance was not to exclude the authority to levy
amusement taxes from the taxing power of the covered
LGUs, but to earmark, if not altogether confiscate, the income
to be received by the LGU from the taxpayers in favor of and
for transmittal to FDCP, instead of the taxing authority. This,
to Our mind, is in clear contravention of the constitutional
command that taxes levied by LGUs shall accrue exclusively to
said LGU and is repugnant to the power of LGUs to apportion
their resources in line with their priorities. Through the
application and enforcement of Sec. 14 of RA 9167, the
income from the amusement taxes levied by the covered
LGUs did not and will under no circumstance accrue to them,
not even partially, despite being the taxing authority
therefor. Congress, therefore, clearly overstepped its plenary
legislative power, the amendment being violative of the
fundamental law's guarantee on local autonomy, as echoed
in Sec. 130(d) of the LGC, thus: Section 130. Fundamental
Principles. - The following fundamental principles shall govern
the exercise of the taxing and other revenue-raising powers
of local government units:
xxxx
(d) The revenue collected pursuant to the provisions of this
Code shall inure solely to the benefit of, and be subject to the
disposition by, the local government unit levying the tax, fee,
charge or other imposition unless otherwise specifically
provided herein x x x.
Additional: In Pimentel v. Aguirre, fiscal autonomy was
defined as "the power [of LGUs] to create their own sources
of revenue in addition to their equitable share in the national
taxes released by the national government, as well as the
power to allocate their resources in accordance with their
own priorities. It extends to the preparation of their budgets,
and local officials in tum have to work within the constraints
thereof." The authority of provinces, cities, and municipalities
to create their own sources of revenue and to levy taxes,
therefore, is not inherent and may be exercised only to the
extent that such power might be delegated to them either by
the basic law or by statute. Under the present Constitution,
where there is neither a grant nor a prohibition by statute,
the tax power of municipal corporations must be deemed to
exist although Congress may provide statutory limitations and
guidelines.
Section 13. Privileges of Graded Films. - Films which have
obtained an "A" or "B" grading from the Council pursuant to
Sections 11 and 12 of this Act shall be entitled to the
following privileges: a. Amusement tax reward. - A grade "A"
or "B" film shall entitle its producer to an incentive equivalent
to the amusement tax imposed and collected on the graded
films by cities and municipalities in Metro Manila and other
highly urbanized and independent component cities in the
Philippines pursuant to Sections 140 to 151 of Republic Act
No. 7160 at the following rates:
1. For grade "A" films - 100% of the amusement tax collected
on such film; and
2. For grade "B" films - 65% of the amusement tax collected
on such films. The remaining thirty-five (35%) shall accrue to
the funds of the Council.
Section 14. Amusement Tax Deduction and Remittance. -All
revenue from the amusement tax on the graded film which
may otherwise accrue to the cities and municipalities in
Metropolitan Manila and highly urbanized and independent
component cities in the Philippines pursuant to Section 140
of Republic Act. No. 7160 during the period the graded film is
exhibited, shall be deducted and withheld by the proprietors,
operators or lessees of theaters or cinemas and remitted
within thirty (30) days from the termination of the exhibition contributor to the overall growth of our country's economy
to the Council which shall reward the corresponding easily makes the information sought a matter of public
amusement tax to the producers of the graded film within concern or interest.
fifteen (15) days from receipt thereof.

The second requisite is that the information requested must

Sereno vs. Committee on Trade and Related Matters, G.R. not be excluded by law from the constitutional guarantee.
No. 175210, Feb. 1 2016 The Court has ruled that the right to information does not
extend to matters acknowledged as "privileged information
under the separation of powers," which include "Presidential
conversations, correspondences, or discussions during
ISSUE: Whether or not the CTRM may be compelled
closed-door Cabinet meetings." Likewise exempted from the
by mandamus to furnish the petitioner with a copy of the
right to information are "information on military and
minutes of the May 23, 2005 meeting based on the
diplomatic secrets, information affecting national security,
constitutional right to information on matters of public
and information on investigations of crimes by law
concern and the State's policy of full public disclosure?
enforcement agencies before the prosecution of the
accused.The government agency concern (CTRM as the
advisory body of the President and the NEDA) claim
RULING: exemption on the ground that the May 23, 2005 meeting was
NO. The constitutional guarantee to information "does not classified as a closed-door Cabinet meeting by virtue of the
open every door to any and all information." It is limited to committee's composition and the nature of its mandate
matters of public concern, and is subject to such limitations dealing with matters of foreign affairs, trade and policy-
as may be provided by law Likewise, the State's policy of full making. The burden has been well discharged herein by the
public disclosure is restricted to transactions involving public government agency concerned that has the burden of
interest, and is further subject to reasonable conditions showing that the information sought to be obtained is not a
prescribed by law. Two requisites must concur before the matter of public concern, or that the same is exempted from
right to information may be compelled by writ of mandamus. the coverage of the constitutional guarantee.
Firstly, the information sought must be in relation to matters
of public concern or public interest. And, secondly, it must
not be exempt by law from the operation of the
constitutional guarantee. Although the information sought is
a matter of public concern or interest, the government
agency concern (CTRM as the advisory body of the President
and the NEDA) claim exemption on the ground that the May
23, 2005 meeting was classified as a closed-door Cabinet
meeting by virtue of the committee's composition and the
nature of its mandate dealing with matters of foreign affairs,
trade and policy-making.

ADDITIONAL INFO:

As to the first requisite, whether or not the information

sought is of public interest or public concern is left to the
proper determination of the courts on a case to case basis. In
his capacity as a citizen and as the Executive Director of the
APMP, the petitioner has sought to obtain official information
dealing with the policy recommendation of the CTRM with
respect to the reduction of tariffs on petrochemical resins
and plastic products. The Philippine petrochemical industry
centers on the manufacture of plastic and other related
materials, and provides essential input requirements for the
agricultural and industrial sectors of the country. Thus, the
position of the petrochemical industry as an essential