Win-WIN Labor Relations and HR Law (version April 29-30, 2015)

Atty. Apollo X.C.S. Sangalang
Business Lawyer & Legal Coach
April 29-30, 2015
Cebu City, Philippines

FVR Skills and Services Exponent, Inc.
(SKILLEX), Fulgencio V. Rana, and
Monina R. Burgos
-versus-
Jovert Seva, et. al. (and 27 other workers)
G.R. No. 200857
October 22, 2014
Supreme Court of the Philippines

LABOR ARBITER
-WINNERS-
SKILLEX et. al.
-AWARDS-
Valid Dismissal.*
BUT workers were awarded money
claims worth at least PhP100,000.

National Labor Relations Commission
-WINNERS-
Jovert Seva and 27 other workers.
-AWARDS-
1. Regularization.
2. Separation Pay in lieu of Reinstatement.
3. Backwages.
4. Money claims of PhP100,000+

Court of Appeals
-WINNERS-
-AWARDS-
1. Regularization.
3. Backwages.
5. Rana and Burgos solidarily liable!!!

Supreme Court
-WINNERS-
-AWARDS-
1. Regularization.
3. Backwages.
BUT Rana and Burgos ABSOLVED!!!

OFFICER OF THE COURT
and
MEMBER OF THE BAR

COUNSELOR
and
ATTORNEY
-AT-
LAW

OWNER and PARTNER
of a LAW FIRM

University Legal Counsel
University of the Philippines

Executive Director
National Labor Relations
Commission

Chief Legislative Officer
Senate of the Philippines

Labor Law
LABOR LAW is HARD!!!

Labor Law Made
Easy
PoL Sangalang’s

https://www.facebook.com/legalcoach
- Free consultation!
- Free learning!
- Free links!

Labor Law made easy?
Really? How?
D.O.C.U.M.E.N.T.© 2013
GOOD
FAITH

How to D.O.C.U.M.E.N.T. © 2013
D ocumentation, documentation, documentation!!!
O pen-mindedness.
C larity.
U nderstand Labor Law principles.
M aster HR.
E mbrace best practices.
N egotiate, negotiate, negotiate!!!
T ake advice only from experts.

Disclaimers
 No lawyer-client relationship.
 Consult your own legal counsel.
 Remember: Legal opinions differ.
 Respect the sub judice rule.
 Avoid conflicts of interest.

This seminar is INTERACTIVE.
And yes, I mean it!

Omni Hauling Services Inc., Lolita Franco
and Aniceto Franco
-versus-
Bernardo Bon, et. al. (and 17 other workers)
G.R. No. 199388
September 3, 2014

-WINNERS-
Bernardo Bon and 17 other workers
-AWARDS-
1. Regularization.
2. Reinstatement
(or Separation Pay in lieu of Reinstatement).
3. Backwages.

Documentation X 3
Pre-Employment.
Employment (Proper).
Pre-Termination and Post-
Employment.

Open-Mindedness
Be tolerant with your workers.
Be receptive to new ideas and
possibilities.
Be accepting of the outcome.

Philippine Spring Water Resources Inc.,
and Danilo Y. Lua
-versus-
Court of Appeals
and Juvenstein B. Mahilum
G.R. No. 205278
June 11, 2014

-WINNER-
Juvenstein B. Mahilum
-AWARDS-
1. Regularization.
3. Backwages.
4. 10% Attorney’s Fees.
5. Unpaid benefits (proportionate 13th month
pay and unused leave credits)
6. 6% Legal Interest until fully paid.

Clarity
…in written communication.
…in talk and action.
…in purpose and objective.

Dionarto Q. Noblejas
-versus-
Italian Maritime Academy Phils., Inc.,
Capt. Nicolo S. Terrei, Raceli B. Ferrez,
and Ma. Teresa R. Mendoza
G.R. No. 207888
June 9, 2014

“No, you better pack up all your
things now and go, you are now
dismissed and you are no longer
part in this office – clearly, you are
terminated from this day on!”
– Raceli B. Ferrez

-WINNER-
Dionarto Q. Noblejas
-AWARDS-
1. Regularization.
2. Reinstatement BUT WITHOUT
Backwages.
3. Proportionate 13th month pay.

Understand Labor Law
Principles
1. Labor Law is a “Game”.
2. Rules of the Game.
3. Goals of the Game.

Win-Win Lose-Win
Win-Lose Lose-Lose
Game Results
Scenarios

Hiring Process
Firing Process
Employee
Employee
Employee

Master HR
LR/ ER is essentially HR.
HR is exemplified by MR.
MR is enhanced by GR.

HR means Human Relations
Human Relations, Civil Code:
“Article 19. Every person must, in the
exercise of his rights and in the
performance of his duties, act with
justice, give everyone his due, and
observe honesty and good faith.”

Takata (Philippines) Corporation
-versus-
Bureau of Labor Relations and
Samahang Lakas Manggagawa ng Takata
(SALAMAT)
G.R. No. 196276
June 4, 2014

Embrace Best Practices
 Good Practices.
Better Practices.
Best Practices

Nancy S. Montinola
-versus-
Philippine Airlines
G.R. No. 198656
September 8, 2014

-WINNER-
Nancy S. Montinola
-AWARDS-
1. Reinstatement.
2. Backwages.
3. Moral Damages.
4. Exemplary Damages.
5. Attorney’s Fees.

Negotiate X 3
…before a labor dispute.
…during a labor dispute.
…after a labor dispute.

Roy D. Pasos
-versus-
Philippine National Construction
Corporation
G.R. No. 192394
July 3, 2013

Take advice only from experts
 Licensed or seasoned experts.
 Local labor law experts.
 Practical and trust-worthy experts.

Slavery
Tribal
Serfdom
Feudal
Employment
Contractual

Law on Contracts
“The contracting parties may establish
such stipulations, clauses, terms and
conditions as may be deemed
convenient, provided they are not
contrary to law, morals, good customs,
public order, or public policy.” (Art. 1306,
Civil Code)

Slavery
Labor
Serfdom
Land
Employment
Capital

Law on Ownership
“The owner has the
right to enjoy and
dispose of a thing,
without other limitations
other than those
established by law.”
 (Art. 428, Civil Code).

Employer Power Equation
Ownership Contracts Power

Employer Power!
“The State recognizes the indispensable role
of the private sector, encourages private
enterprises, and provides incentives to
needed investments.”
(Sec. 20, Art. II, Constitution)
“The State…x x x… recognizing the right of
enterprises (1) to reasonable returns on
investments, and (2) to expansion and
growth.” (Sec. 3, Art. XIII, Constitution)

Slavery
Might is
Right
Serfdom
Divine Right
Employment
Constitutional
Right

Management Prerogative
1. Right to hire;
1. Right to fire;
1. Right to fix compensation &
benefits; and
1. Right to control.

Limitation No. 1

Article 291 paragraph 2, Labor Code
(Formerly Article 277)

Limitation No. 2

Article 4, Labor Code

Burden
of
Proof
All
Doubts E.A.P.G.

Slavery
Masters
Serfdom
Lords
Employment
HR
Managers

A person who surrenders when he
is WRONG is HONEST.
A person who surrenders when
NOT sure is WISE.
A person who surrenders even if
he’s RIGHT is a HUSBAND!!!

Pre-Employment
Employment
Post Employment

Courtship +
Engagement
Marriage
Separation +
Annulment

Placement
Selection
Recruitment

Job Analysis
Job
Description
Advertise
Vacancies
Receive Job
Applications
Job
Interview
Background
Checks
Testing
Short-
Listing
Job Offer &
Acceptance

Happy
Ending
•Golden
Anniversary
Tragic
Ending
•Separation
•Law suit
MARRIAGE

Happy
Ending
• Retirement
• Cordial
Resignation
Tragic
Ending
• Termination
• Labor case
• Other law suits
EMPLOYMENT

Anatomy of a Labor Dispute
Capitalist Worker

Win-Win Lose-Win
Win-Lose Lose-Lose
Conflict
Resolution
Scenarios

Labor Relations Game
Unionism and
Right to
Strike
Labor
Standard
Social
Justice
Security of
Tenure

Rule of Law
Constitution
Laws (including Labor Laws)
Rules & Regulations
Jurisprudence
Public Policies
and Principles
of Equity
Contracts
Company
Policies

Shared Responsibility Model
Business
Labor
Progress
and
Development

Tripartite Model
Government
BusinessLabor

What is Social Justice?
Business Labor

Elements of Labor Law
Labor
Law
Shared
Responsibility
Social
Justice
Rule of
Law

Employee
•Labor Law
•Control
Independent
Contractor
•Civil Law
•No Control
Hiring Process

Labor Law
1. Full protection
2. Living wage
3. Humane conditions of work
4. Security of tenure
5. Participation in policy and decision-making
6. Just share in the fruits of production
1. Self-organization and collective bargaining;
2. Freedom of expression; and
3. Strike and other peaceful concerted activities

Monetary Benefits
Minimum Wage Holiday Pay
Premium Pay Overtime Pay
Night Shift Differential Service Charges
Service Incentive Leave Maternity Leave
Paternity Leave Solo Parents Leave
VAWC Leave Special Leave for Women
13th Month Pay Separation Pay
Retirement Pay Compensation Benefit*
(ECC)
PhilHEALTH Benefit* Social Security Benefit*
Pag-IBIG Benefit*

Test of Employment
Hire Fire
Pay Control
4-Fold Test

What’s Control?
End
Means
Control

Control Test
 CONTROL is the power to
determine the end results and the
means of doing the work.
 Only an employer has control over
his employees.
 The power of control need not be
actually exercised.

Non-employment Options
Independent Contractors Job Contractors
Consultants Freelancers
Agents Industrial Partners
Corporate Officers Cooperative Members
Volunteers Academic Interns

Private
Recruitment
and
Placement
Agency
•Outsource
HIRING
Independent
Contractor
•Outsource
CONTROL
Hiring Process

Bilateral Relationship
Vendee
EmployeeVendor
Contract of Labor

Trilateral Relationship
User
Enterprise
EmployeeContractor
Contract of Labor

Job Contracting
Client
EmployeeContractor
CONTROL
NO CONTROLNO CONTROL

Labor ONLY Contracting
Principal
EmployeeAgent
NO CONTROL
CONTROLNO CONTROL

Manpower Cooperative
Client
EmployeeCooperative
CONTROL

Self-Employed Cooperative
Client
Self-
Employed
Cooperative
NO CONTROL

Labor ONLY Cooperative
Principal
WorkerCooperative
NO CONTROL
CONTROLNO CONTROL

Direct Contracting
Employer
Employee
Fixed-term5-5-5

Types of Employment
Private Sector vs. Government
Regular (By Nature) vs. Casual
Regular (By Tenure) vs. Non-Regular
Rank-and-file vs. Manager & Supervisor
Time-based vs. Results-based

Private Sector vs. Government
Labor Code and
other labor laws
Civil Service Law
DOLE Civil Service
Commission
CBA + Strike CNA + No Strike
Labor Standards Not covered by
Labor Standards

Regular vs. Casual
Work is “Usually
Necessary or
Desirable in the
Usual Business or
Trade of the
Employer”
Work is NOT “Usually
Necessary or
Desirable in the Usual
Business or Trade of
the Employer”
Security of Tenure No Security of Tenure

What’s Just Cause?
1. Serious misconduct;
2. Willful disobedience (or insubordination);
3. Gross and habitual neglect of duties;
4. Fraud;
5. Willful breach of trust; and
6. Crime against person of the employer or
his immediate family or representatives.

Other Just Causes?
1. Loss of trust and confidence;
2. Gross negligence coupled with a grave
consequence;
3. Incompetence without improvement;
4. Habitual commission of minor offenses;
and
5. Unfit for continued employment based
on the “Totality of Infraction” doctrine.

What’s Authorized Cause?
1. Installation of labor-saving devices;
2. Redundancy;
3. Retrenchment to prevent losses;
4. Closing or cessation of establishment or
undertaking;
5. Disease prejudicial to health; and
6. Compulsory retirement.

What’s a Regularized Casual?

Regular vs. Non-Regular
Work is “Usually
Necessary or Desirable in
the Usual Business or
Trade of the Employer”
Same Nature
Security of Tenure Same Security
Tenure is until the age of
compulsory retirement
(65 years old).
Shorter Tenure

Non-Regular Security of Tenure (?)
Project Yes, but tenure expires upon
completion of the project.
Seasonal Yes, but tenure expires upon the
ending of the season.
Contractual or
Fixed-term
Yes, but tenure expires upon the
end of contract (“endo”).
Temporary or
Emergency
Yes, but tenure expires upon the
cessation of the emergency or
contingency.

Contractual Employment
Employer
Employee
Fixed-term5-5-5

Regular vs. Probationary
Work is “Usually Necessary
or Desirable in the Usual
Business or Trade of the
Employer”
Same Nature
Security of Tenure Same Security
Tenure is until the age of
compulsory retirement
(65 years old).
Same Tenure
No Trial Period With Trial Period

How SHOULD we fire?
D.O.C.U.M.E.N.T.© 2013
GOOD
FAITH

Model Employment Contract
 Written, dated, and signed
 Pre-employment & probation clauses
 Regular or other employment status
 Obedience to company policies
 Starting wages & specific benefits
 Reference to job offer, handbook, etc.

Model Employee Handbook
 Written, dated, and signed receipt
 Code of discipline
 Code of ethics & performance criteria
 Resignation & clearance process
 Address changes & notification
 Only common benefits are listed

Model 201 File
 Employment contract
 Job description and job offer sheet
 Pre-employment documentation
 Job application and bio-data sheet
 Acknowledgment receipts
 Certifications and test results

What’s the purpose?
The purpose of an “Administrative
Investigation” (or “AI”) is to support
a decision to impose or not to
impose disciplinary action.
The goal is to impartially gather and
compile all relevant evidence.
Conduct problems are the scope.

Burden
of Proof
All
Doubts
E.A.P.G.
Full Protection Equation

3 Ways to Investigate,
Discipline and Terminate (IDT)
Efficient but NOT necessarily legal.
Legal but NOT necessarily effective.
Effective (which is more than legal).

3 Reasons to Avoid ILLEGAL
Dismissal Cases
 Monetary and Business Costs.
 Emotional, Mental, Physical and Spiritual
Costs.
 Social and Macro-Economic Costs.

3 Most Fearsome Monetary
and Business COSTS
Reinstatement.
Backwages.
Damages.

3 Hidden Monetary and
Business COSTS
Direct Costs of Litigation.
Indirect Costs of Litigation.
Business Losses and Closure.

3 Kinds of Workers to
I.D.T.
 Employees guilty of JUST CAUSE.
 Employees NOT guilty of just cause.
 Workers who are NOT employees.

3 Kinds of Employees who
are Guilty of Just Cause
 Guilty under Article 296 Labor Code.
 Guilty under Causes Analogous.
 Guilty under Company Policy.

Article 296*, Labor Code
1. Serious misconduct;
2. Willful disobedience (or insubordination);
3. Gross and habitual neglect of duties;
4. Fraud;
5. Willful breach of trust; and
6. Crime against person of the employer or his
immediate family or representatives.

Causes Analogous
2. Gross negligence coupled with grave
consequence;
4. Habitual commission of minor offenses; and
5. Unfit for continued employment based on
the “Totality of Infraction” doctrine.

Company Policy
 Causes Analogous is the LEGAL BASIS for
employers to create new offenses penalized
by termination.
 Offenses created by employers must have the
same gravity as the offenses listed in Article
296.
 Must be written, well defined and circulated
(e.g. Employee Handbook).

Other Problem Employees
1. Employee isn’t the problem (what then?);
2. Problem employee, yes; but he isn’t
dismissible (yet);
3. Problem employee, yes; but he can be
severed without firing him;
4. Employee who lacks motivation or skills;
and
5. Non-employee worker;

3 Ways to I.D.T.
Efficient but not necessarily legal.
Legal but not necessarily effective.
Effective (which should be legal).

Legal Way To I.D.T.
Substantive Due Process.
Procedural Due Process.
Substantial Evidence.

Substantive
Due Process
• Just Cause
• Reasonableness
• Good Faith
Procedural
Due Process
• Notice to Explain
• Notice of Hearing
• Notice of Termination
Substantial
Evidence
• Proof of Substantive
Due Process
• Proof of Procedural
Due Process
• Proof of Good Faith
LEGAL WAY

Substantive Due Process
Just Cause.
Reasonableness.
Good Faith.

JUST CAUSE:
based on Article 296*, Labor Code.
based on “Causes Analogous”.
must overcome:
“Security of Tenure.”

Causes Analogous
2. Gross negligence coupled with a grave
consequence;
4. Habitual commission of minor offenses; and
5. Unfit for continued employment based on
the “Totality of Infraction” doctrine.

REASONABLENESS:
Penalty is proportionate to the
offense.
Offense is NOT against Law or
Public Policy.
Offense is business-related or
employment-connected.

GOOD FAITH:
Good faith is presumed.
Bad faith must be proven.
But in labor law, it’s the reverse!
Because ALL DOUBTS
favor employees!

Procedural Due Process
Notice to Explain.
Notice of Hearing.
Notice of Termination.

NOTICE TO EXPLAIN:
 Describes the who, what, when, where,
why and the how much or the manner the
offense was committed.
 Gives at least 5 DAYS to submit the
written explanation.
 Specifies TERMINATION as possible
penalty, if found guilty.

NOTICE OF HEARING:
 Gives opportunity to the employee to
verbally explain his side and present his
evidence.
 States that he has right to counsel or
representative of his own choice.
 Lays down the hearing procedure.

NOTICE OF TERMINATION:
 Summarizes what happened since the
start of the disciplinary process.
 Enumerates the basis of the decision.
 States the verdict clearly, including
monetary liability (if any); and advises
employee of the next step.

Substantial Evidence
Proof of substantive due process.
Proof of procedural due process.
Proof of good faith.

PROOF OF SUBSTANTIVE DUE
PROCESS:
 Offense has been defined and justified.
 Employee committed the offense.
Affidavits and Testimonial Evidence.
Admissions.
Documentary Evidence.
Object Evidence.

PROOF OF PROCEDURAL DUE
PROCESS:
 Notices are written and served.
Personal service.
Substituted service.
 Hearings are recorded.
Attendance.
Minutes.

PROOF OF GOOD FAITH:
 Show the effect of the offense on the
organization or on the business.
 Show that you walked the Extra Mile.
Because employers have the
BURDEN OF PROOF*.
Because ALL DOUBTS favor the
employees.

Substantive
Due Process
• Just Cause
• Reasonableness
• Good Faith
Procedural
Due
Process
• Notice to Explain
• Notice of Hearing
• Notice of
Termination
Substantial
Evidence
• Proof of Substantive
Due Process
• Proof of Procedural
Due Process
• Proof of Good Faith
LEGAL WAY

CONSTRUCTIVE DISMISSAL
• A form of ILLEGAL TERMINATION;
• No formal termination or disciplinary proceeding
was initiated;
– No due process;
– Presumably, no just or authorized cause as well.
• Employee was forced to resign because:
– Demotion or diminution of benefits; or
– Impossible or unbearable for the employee to
continue with his employment; or
– Directed by the employer to resign.

PREVENTIVE SUSPENSION
Ground:
– Serious and imminent threat to the:
• Life and/or property of the…
• Employer and/or co-workers.
Maximum period: 30 days.
Otherwise, it shall be CONSTRUCTIVE DISMISSAL.
CONSTRUCTION INDUSTRY: 15 DAYS MAXIMUM.

TEMPORARY TRANSFER
Requirements:
– Genuine business need or necessity;
– Good faith;
– No undue hardship upon employee; and
– Not meant as a form of penalty.
Otherwise, the transfer will be considered as a form of CONSTRUCTIVE
DISMISSAL.
If there is just cause, transfer may be resorted to as an alternative to preventive
suspension; but a disciplinary proceeding must be initiated.

Effective Way
 Legal Way isn’t enough. Why?
 Because…
 Filing a labor case is so easy and it’s free;
 An employee who felt mistreated will try to
vindicate himself or get even;
 A guilty employee will try to save face;
 Many lawyers, paralegals, and labor leaders
accept contingency fees.

How to D.O.C.U.M.E.N.T. © 2013
D ocumentation, documentation, documentation!!!
O pen-mindedness.
C larity.
U nderstand Labor Law principles.
M aster HR.
E mbrace best practices: Progressive Discipline
N egotiate, negotiate, negotiate!!!
T ake advice only from experts.

Evolution of Work Arrangement
Slavery
Serfdom
Contractual

Capitalist Model
Social
Benefits
Free
Market
Competition

Capitalist Exploitation
Profit,
Expansion and
Growth
Workers’
Compensation
and Benefits

Revolution!!!
Socialist
Democratic

Socialist Model
People’s Ownership
Management’s
Stewardship
Party’s
Guardianship

Democratic Model
Elite
Class
Middle
Class
Working Class

Labor Law Revolution!
Unionism +
Strike
Labor
Standards
Social
Justice
Security of
Tenure

Shared Responsibility Model
Business
Labor
Progress and
Development

3 Kinds of Win Scenarios
Win – Lose
Compromise (or Half-baked Win)
Win – Win (Mindset)
 “Think Win-Win” by Stephen Covey

3 Ways To Win
By “Hook” or by “Crook”.
Out Last. Out Wit. Out Pay!
(“Survivor”).
WIN with INtegrity (“WIN-wIN”).
 It’s more than just winning legally.

Why WIN-wIN?
 I can’t compartmentalize my life.
 I can’t justify the means with the end.
 I reaped what I’ve sown.
 I almost lost my soul.

What’s WIN-wIN?
“… what king would go to war against
another king without first sitting down
with his counselors to discuss whether
his army of 10,000 could defeat the 20,000
soldiers marching against him? And if he
can’t, he will send a delegation to discuss
terms of peace while the enemy is still
far away.”
- Jesus Christ
(Luke 14:31-32 NLT)

Progressive Discipline
Definition:
It is a system of discipline where penalties increase
upon repeat occurrences.
Purpose:
It primarily aims to correct the negative behavior rather
than to punish the erring employee.
Range of Responses:
1. Counseling or coaching.
2. Verbal warning.
3. Written warning.
4. Suspension or demotion or fine or forfeiture.
5. Performance Improvement Plan (PIP).
6. Termination.

What’s Progressive
Discipline?
System
Documentation
Mindset

Progressive Discipline Mindset
1. Do no harm.
2. Make things better.
3. Respect others.
4. Be fair.
5. Be compassionate.

Advantages:
1. It addresses the silence of the Labor Code
regarding “Incompetence” as a ground for
termination.
2. It helps the Employer document habitual negative
behaviors, which is essential in establishing
“Gross and Habitual Negligence” as a ground
for termination.
3. It helps the Employer prove that he was in Good
Faith in dealing with the Employee.

Advantages (continuation):
4. It helps build up a case for “Analogous Cause” as
a ground for termination.
5. Since it is corrective in approach, it helps preserve
the existing members of the team while improving
their performance and behavior.
6. It saves the Employer costly recruitment and
training expenses for new hires, as well as
prevents downtime due to vacancies.
7. It promotes Employee morale.

Requirements:
1. Employee Manual (Progressive Offenses & Penalties).
2. Step-by-step Implementation Guide.
3. Training for Managers and Supervisors.
a. Counseling or Coaching Skills.
b. Verbal and Written Warnings.
c. Performance Agreement
d. Performance Improvement Plan.
4. Employee Interview Log Sheets.
5. 201 File.
6. Templates and Scripts.

1. Pre-Investigation Stage.
a. Prepare: Company Policies and Employee Manual.
b. Prepare: Employment Contracts and 201 File.
c. Progressive Discipline: Train the Managers.
d. Progressive Discipline: Counsel or Warn Employees.
e. Preliminary: Fact-finding Activities.
2. Investigation Proper.
a. Start: Notice to Explain or Show Cause Memo.
b. Progressive Discipline: Performance Improvement Plan.
c. End: Notice of Decision.
3. Post-Investigation Stage.
a. Review: Company Policies and Employee Manual.
b. Review: Employment Contracts and 201 File.
c. Progressive Discipline: Re-train the Managers.

Progressive Discipline Cycle
Pre-
Investigation
Feedback
PA/ PIP
Investigation
1st Notice
Investigation
2nd Notice
Post-
Investigation

ER Best Practices
Probationary Employment.
Code of Discipline.
Code of Ethics.

HR Best Practices
Performance Appraisal.
Performance Improvement Plan.
Performance-based Rewards.

LR Best Practices
Walk-in Compromise Settlement.
SEnA (Single Entry Approach).
“The Cordial Resignation Letter.”

Spiritual Best Practice
The Bible:
“Do not seek revenge or bear a
grudge against a fellow Israelite,
but love your neighbor as
yourself.”
(Leviticus 19:18)

How to love your workers?
1. Do no harm.
2. Make things better.
3. Respect others.
4. Be fair.
5. Be compassionate.

Win-WIN Labor Relations and HR Law (version April 29-30, 2015)

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