Atty. Habib U. Simban

14/06/2026

No, boss. You can’t just fire me—not without due process.

Fact—labor laws in the Philippines provide some of the strongest security of tenure protections in the world. For your employer to legally terminate you, they must strictly follow two requirements: substantive due process (legal causes) and procedural due process (legal steps).

Under the Labor Code, there are two categories of legal grounds for termination: Just Causes (your fault) and Authorized Causes (the company’s or the economy’s fault).

If you did something wrong (Just Causes)...

You may be terminated without separation pay for serious misconduct, willful disobedience, gross and habitual neglect of duties, fraud, breach of trust, or committing a crime (under Article 297 of the Labor Code).

Under the doctrine of management prerogative, your employer has the inherent right to regulate, according to his own discretion and judgment, all aspects of your employment, including…discipline, dismissal, and recall (Rural Bank of Cantilan, Inc. vs. Julve, G.R. No. 169750 (02-27-2007). So, ‘wag ka namang pasaway!

But not on the spot…

For just causes, your employer must comply with the mandatory Twin-Notice Rule: a Notice to Explain (NTE) giving you at least 5 calendar days to respond, and a Notice of Termination issued after evaluating your defense (and after an administrative hearing, if you request one or if company policy requires it).

Your employer may also place you under Preventive Suspension (max 30 days) during the investigation if your continued presence poses a serious and imminent threat to life or property. This is NOT the same as being fired (Huwag ka munang OA).

Now, even if it's not your fault (Authorized Causes)...

You may still get fired due to business realities. Your employer may legally terminate your employment under Articles 298 and 299 for redundancy, retrenchment, closure, or disease—generally, with separation pay.

Your employer may exercise management prerogative to reorganize or reduce its workforce to survive, even if you are unaware of the underlying financial distress.

But still, not on the spot...

For authorized causes, your employer must give both you and the DOLE a written 30-day notice before your actual last day of work.

So...

If you are fired on the spot without these notices, it may constitute Illegal Dismissal. In such cases, you can file a complaint with the National Labor Relations Commission (NLRC) and seek remedies such as reinstatement (getting your job back), backwages (all the pay you missed while fired), and if the termination was done in bad faith, moral and exemplary damages.

Disclaimer: This post is for informational purposes only and does not constitute formal legal advice. Because every labor dispute involves unique facts, circumstances, and employment contracts, the information provided here may not apply to your specific situation. For tailored legal counsel, always consult a qualified professional.

Duran & Duran-Schulze Law ("DDS Law") is an employment litigation law firm in the Philippines dedicated to helping employers and employees resolve labor disputes. Send us an email at [email protected] for assistance.

11/06/2026

In 𝐀𝐧𝐭𝐨𝐧𝐢𝐧𝐨 𝐯. 𝐁𝐚𝐧𝐜𝐨 𝐃𝐞 𝐎𝐫𝐨 𝐔𝐧𝐢𝐯𝐞𝐫𝐬𝐚𝐥 𝐁𝐚𝐧𝐤, 𝐈𝐧𝐜., 𝐆.𝐑. 𝐍𝐨𝐬. 𝟐𝟕𝟑𝟒𝟒𝟔 & 𝟐𝟕𝟑𝟒𝟗𝟑, 𝐀𝐩𝐫𝐢𝐥 𝟐𝟑, 𝟐𝟎𝟐𝟓, SC reiterated the diligence required of banks to protect commercial transactions.

The Antoninos, U.S.-based green card holders, placed over USD 150,000 in time deposits with BDO San Lorenzo, with an arrangement that unwithdrawn deposits would roll over into savings accounts. The original time deposit certificates (TDCs) were kept in a Banco Filipino deposit box, which later became inaccessible after the bank’s closure and PDIC takeover.

When the Antoninos eventually sought to withdraw their funds, they discovered that BDO San Lorenzo had already closed. BDO claimed the deposits had been withdrawn through a demand draft allegedly signed by Angelita, but she denied this. Evidence showed she was abroad at the time, and a PNP handwriting expert found the signature likely forged.

Both the RTC and Court of Appeals ruled in favor of the Antoninos, noting they still possessed the original TDCs—proof the deposits were not withdrawn.

SC affirmed, emphasizing that withdrawal requires surrender of the TDCs, which never happened. The Court held BDO liable for failing to exercise the high degree of diligence required of banks, citing its failure to verify the withdrawal, produce key documents, and detect the apparent forgery. It also ruled that moral damages may be awarded based on negligence alone, even without bad faith.

07/06/2026

🙄

07/06/2026

07/06/2026

SC Rules Lazada Riders Are Employees, Not Independent Contractors

The Supreme Court (SC) ruled that delivery riders engaged by Lazada E-Services Philippines, Inc. under so-called "Independent Contractor Agreements" were in fact regular employees entitled to the protection of labor laws.

### The Court likewise applied the "economic reality test" and found that the riders' services were integral to Lazada's business operations. While Lazada characterized itself as an online platform connecting buyers and sellers, the Court observed that its business model included the delivery of products, making the riders' work necessary and indispensable to its operations.- SC, Second Division, Per LOPEZ, J., J.

Read the full text in the comments.

07/06/2026

Atty. Mark Virgilio Says IBP Statement on Senate Quorum Does Not Necessarily Reflect Views of All Members

Lawyer Mark Virgilio has expressed reservations regarding the recent statement issued by the Board of Governors of the Integrated Bar of the Philippines (IBP) on the Senate quorum controversy, emphasizing that it should not be construed as the collective position of all IBP members.

In a public statement, Virgilio noted that no prior consultation was conducted with the IBP's general membership before the issuance of the Board's position.

"As a member of the Integrated Bar of the Philippines, I respectfully state that the recent statement issued by the IBP Board of Governors on the issue of Senate quorum should not be construed as the collective position of all IBP members," Virgilio said.

According to him, while the statement reflects the views of the IBP Board of Governors, it does not necessarily represent the opinions of every lawyer who belongs to the mandatory national organization of the Philippine legal profession.

"No prior consultation was conducted with the general membership before its issuance. While the statement reflects the views of the Board, it does not necessarily reflect my views or those of many other members of the IBP," he added.

Virgilio further urged the IBP to exercise prudence and institutional neutrality, particularly when addressing issues that are political and highly divisive in nature.

"The IBP should exercise prudence and institutional neutrality, particularly on matters that are political and highly divisive in nature," he stated.

The statement comes amid continuing public debate over the legality of recent developments in the Senate leadership controversy and the role of legal institutions in commenting on issues involving the internal affairs of a co-equal branch of government.

The Integrated Bar of the Philippines is the official organization of all Philippine lawyers created under the authority of the Supreme Court. Its Board of Governors serves as its policy-making body and acts on matters affecting the legal profession and the administration of justice.



See the original post in the comments.

07/06/2026

⚖️ 𝑳𝒆𝒕’𝒔 𝒔𝒆𝒆 𝒕𝒉𝒆 𝒘𝒊𝒔𝒅𝒐𝒎 𝒇𝒓𝒐𝒎 𝑭𝒐𝒓𝒎𝒆𝒓 𝑪𝒉𝒊𝒆𝒇 𝑱𝒖𝒔𝒕𝒊𝒄𝒆 𝑴𝒐𝒓𝒂𝒏 𝒉𝒊𝒎𝒔𝒆𝒍𝒇 𝒘𝒉𝒐 𝒑𝒓𝒆𝒔𝒊𝒅𝒆𝒅 𝒘𝒉𝒆𝒏 𝒕𝒉𝒆𝒚 𝒅𝒆𝒄𝒊𝒅𝒆𝒅 𝒕𝒉𝒆 𝑨𝒗𝒆𝒍𝒊𝒏𝒐 𝒗𝒔. 𝑪𝒖𝒆𝒏𝒄𝒐 𝒄𝒂𝒔𝒆 𝒊𝒏 1949. 𝑭𝑪𝑱 𝑴𝒐𝒓𝒂𝒏’𝒔 𝒄𝒐𝒏𝒄𝒖𝒓𝒓𝒊𝒏𝒈 𝒐𝒑𝒊𝒏𝒊𝒐𝒏 𝒎𝒂𝒕𝒕𝒆𝒓𝒔 𝒏𝒐𝒘. 𝑹𝒆𝒎𝒊𝒏𝒅𝒆𝒓, 𝒉𝒆 𝒊𝒔 𝒏𝒐𝒕 𝑫𝑫𝑺, 𝒏𝒐𝒕 𝑷𝒓𝒐 𝑩𝑩𝑴, 𝒏𝒐𝒕 𝑷𝒊𝒏𝒌, 𝒏𝒐𝒕 𝒀𝒆𝒍𝒍𝒐𝒘 𝒐 𝒌𝒂𝒉𝒊𝒕 𝒂𝒏𝒐𝒏𝒈 𝒌𝒖𝒍𝒂𝒚.

Here is the FULL TEXT of his opinion:

“MORAN, C.J., concurring:

I believe that this Court has jurisdiction over the case. The present crisis in the Senate is one that imperatively calls for the intervention of the Court.

Respondent Cuenco cannot invoke the doctrine of non-interference by the courts with the Senate because the legal capacity of his group of twelve senators to acts as a senate is being challenged by petitioner on the groundof lack of quorum (Attorney General ex rel. Werts vs. Rogers et al., Atl. 726; 23 L. R. A., 352). If this group is found sufficient to constitute a quorum under the Constitution, then its proceedings should be free from interference. But if it is not possessed of a valid quorum, then its proceedings should be voided.

The issue as to the legal capacity of the Cuenco group to act as a senate cannot be considered a political question the determination of which devolves exclusively upon the Senate. That issue involves a constitutional question which cannot be validly decided either by the Cuenco group or by the Avelino group separately, for, if the Cuenco group has no quorum, the Avelino has decidedly less. And for obvious reasons, the two groups cannot act together inasmuch as the members of the Avelino group, possibly to avoid trouble, do not attend the sessions presided by the respondent believing as they do that the latter was illegally elected. Upon the other hand, the Cuenco group believing itself as possessing the constitutional quorum and not desiring to make any semblance of admission to the contrary, does not find it convenient to compel the attendance of any senator of the Avelino group. Then the question arises--who will decide the conflict between the two groups? This anomalous situation will continue while the conflict remains unsettled, and the conflict will remain unsettled while this Court refuses to intervene. In the meantime the validity of all the laws, resolutions and other measures which may be passed by the Cuenco group will be open to doubt because of an alleged lack of quorum in the body which authored them. This doubt may extend, in diverse forms, to the House of Representative and to the other agencies of the government such as the Auditor General's Office. Thus, a general situation of uncertainty, pregnant with grave dangers, is developing into confusion and chaos with severe harm to the nation. This situation may, to a large extent, be stopped and constitutional processes may be restored in the Senate if only this Court, as the guardian of the Constitutional, were to pronounce the final word on the constitutional mandate governing the existing conflict between the two groups. And, in my opinion, under the present circumstances, this Court has no other alternative but to meet challenge of the situation which demands the utmost of judicial temper and judicial statesmanship. As hereinbefore stated, the present crisis in the Senate is one that imperatively calls for the intervention of this Court.

𝐀𝐬 𝐭𝐨 𝐭𝐡𝐞 𝐥𝐞𝐠𝐚𝐥𝐢𝐭𝐲 𝐨𝐟 𝐫𝐞𝐬𝐩𝐨𝐧𝐝𝐞𝐧𝐭'𝐬 𝐞𝐥𝐞𝐜𝐭𝐢𝐨𝐧 𝐚𝐬 𝐚𝐜𝐭𝐢𝐧𝐠 𝐏𝐫𝐞𝐬𝐢𝐝𝐞𝐧𝐭 𝐨𝐟 𝐭𝐡𝐞 𝐒𝐞𝐧𝐚𝐭𝐞,𝐈 𝐟𝐢𝐫𝐦𝐥𝐲 𝐛𝐞𝐥𝐢𝐞𝐯𝐞 𝐭𝐡𝐚𝐭 𝐚𝐥𝐭𝐡𝐨𝐮𝐠𝐡 𝐩𝐞𝐭𝐢𝐭𝐢𝐨𝐧𝐞𝐫'𝐬 𝐚𝐝𝐣𝐨𝐮𝐫𝐧𝐦𝐞𝐧𝐭 𝐨𝐟 𝐭𝐡𝐞 𝐬𝐞𝐬𝐬𝐢𝐨𝐧 𝐨𝐟 𝐅𝐞𝐛𝐫𝐮𝐚𝐫𝐲 𝟐𝟏, 𝟏𝟗𝟒𝟗, 𝐰𝐚𝐬 𝐢𝐥𝐥𝐞𝐠𝐚𝐥𝐢𝐭𝐲 𝐜𝐚𝐧𝐧𝐨𝐭 𝐛𝐞 𝐜𝐨𝐮𝐧𝐭𝐞𝐫𝐞𝐝 𝐰𝐢𝐭𝐡 𝐚𝐧𝐨𝐭𝐡𝐞𝐫 𝐢𝐥𝐥𝐞𝐠𝐚𝐥𝐢𝐭𝐲. 𝐓𝐡𝐞 𝐬𝐞𝐬𝐬𝐢𝐨𝐧 𝐰𝐡𝐞𝐫𝐞𝐢𝐧 𝐫𝐞𝐬𝐩𝐨𝐧𝐝𝐞𝐧𝐭 𝐰𝐚𝐬 𝐞𝐥𝐞𝐜𝐭𝐞𝐝 𝐚𝐬 𝐚𝐜𝐭𝐢𝐧𝐠 𝐏𝐫𝐞𝐬𝐢𝐝𝐞𝐧𝐭 𝐨𝐟 𝐭𝐡𝐞 𝐒𝐞𝐧𝐚𝐭𝐞 𝐰𝐚𝐬 𝐢𝐥𝐥𝐞𝐠𝐚𝐥 𝐛𝐞𝐜𝐚𝐮𝐬𝐞 𝐰𝐡𝐞𝐧 𝐒𝐞𝐧𝐚𝐭𝐨𝐫 𝐌𝐚𝐛𝐚𝐧𝐚𝐠 𝐫𝐚𝐢𝐬𝐞𝐝 𝐭𝐡𝐞 𝐪𝐮𝐞𝐬𝐭𝐢𝐨𝐧 𝐨𝐟 𝐚 𝐪𝐮𝐨𝐫𝐮𝐦 𝐚𝐧𝐝 𝐭𝐡𝐞 𝐫𝐨𝐥𝐥 𝐰𝐚𝐬 𝐜𝐚𝐥𝐥𝐞𝐝, 𝐨𝐧𝐥𝐲 𝐭𝐰𝐞𝐥𝐯𝐞 𝐬𝐞𝐧𝐚𝐭𝐨𝐫𝐬 𝐰𝐞𝐫𝐞 𝐩𝐫𝐞𝐬𝐞𝐧𝐭. 𝐈𝐧 𝐭𝐡𝐞 𝐏𝐡𝐢𝐥𝐢𝐩𝐩𝐢𝐧𝐞𝐬 𝐭𝐡𝐞𝐫𝐞 𝐚𝐫𝐞 𝐭𝐰𝐞𝐧𝐭𝐲-𝐟𝐨𝐮𝐫 𝐬𝐞𝐧𝐚𝐭𝐨𝐫𝐬, 𝐚𝐧𝐝 𝐭𝐡𝐞𝐫𝐞𝐟𝐨𝐫𝐞, 𝐭𝐡𝐞 𝐪𝐮𝐨𝐫𝐮𝐦 𝐦𝐮𝐬𝐭 𝐛𝐞 𝐭𝐡𝐢𝐫𝐭𝐞𝐞𝐧. 𝐓𝐡𝐞 𝐚𝐮𝐭𝐡𝐨𝐫𝐢𝐭𝐢𝐞𝐬 𝐨𝐧 𝐭𝐡𝐞 𝐦𝐚𝐭𝐭𝐞𝐫 𝐚𝐫𝐞 𝐜𝐥𝐞𝐚𝐫.

The constitution of our state ordains that a majority of each house shall constitute a quorum. the house of representative consist of 125 members; 63 is a majority and quorum. When a majority or quorum are present, the house can do business; not otherwise. A quorum possessed all the powers of the whole body, a majority of which quorum must, of course, govern. (In re Gunn, 50 Kan., 155; 32 P., 470, 476; 19 L.R.A., 519.)

Quorum as used in U. S. C. A. Const. Art. 4 sec. 8, providing that a majority of each house shall constitute a quorum to do business, is, for the purpose of the Assembly, not less than the majority of the whole number of which the house may be composed. Vacancies from death, resignation or failure to elect cannot be deducted in ascertaining the quorum. (Opinion of Justice, 12 Fla. 653.)

The general rule is that a quorum is a majority of all the members and a majority of this majority may legislate and do the work of the whole. (State vs. Ellington 117 N. C., 158; 23 S. E. 250-252, 30 L.R.A., 532; 53 Am. SR., 580.)
. . a majority of each House is necessary to transact business, and a minority cannot transact business, this view being in keeping with the provision of the Constitution permitting a smaller number than a quorum to adjourn from day to day merely. (Earp vs. Riley, 40 OKL., 340; p. 164; Ralls vs. Wyand, 40 OKL., 323; 138 P. 158.)

The Constitution provides that "a majority of each (house) shall constitute a quorum to do business." In other words, when a majority are present the House is in a position to do business. Its capacity to transact business is then established, created by the mere presence of a majority, and depend upon the disposition or assent or action of any single member or faction of the majority present. All that the Constitution required is the presence of a majority, and when that majority are present, the power of the House arises. (U. S. vs. Ballin, Joseph & Co., 36 Law ed. 321, 325.)

If all the members of the select body or committee, or if all the agents are assembled, or if all have been duly notified, and the minority refuse, or neglect to meet with the other, a majority of those present may act, provided those present constitute a majority of the whole number. In other words, in such case, a major part of the whole is necessary to constitute a quorum, and a majority of the quorum may act. If the major part withdraw so as to leave no quorum, the power of the minority to act is, in general, considered to cease. (1 Dillon, Mun. Corp. 4th ed., sec. 283.)3

Therefore, without prejudice to writing a more extensive opinion, if necessary, I believe that respondent Mariano J. Cuenco has not been legally elected as acting President of the Senate. It is true that respondent Cuenco, in fact, must be the Senate President because he represent the majority of the members now present in Manila, and, at any new session with a quorum, upon the present senatorial alignment, he will be elected to said office. But precisely he is now the master of the situation, he must win his victory in accordance with the Constitution. It is absolutely essential in the adolescent life of our Republic to insist, strictly and uncompromisingly, on thedemocratic principles consecrated in our Constitution. By such efforts alone can we insure the future of our political life as a republican form of government under the sovereignty of a Constitution from being a mockery.

𝐓𝐡𝐞 𝐬𝐢𝐭𝐮𝐚𝐭𝐢𝐨𝐧 𝐧𝐨𝐰 𝐢𝐧 𝐭𝐡𝐢𝐬 𝐂𝐨𝐮𝐫𝐭 𝐢𝐬 𝐭𝐡𝐢𝐬 — 𝐭𝐡𝐞𝐫𝐞 𝐚𝐫𝐞 𝐟𝐨𝐮𝐫 𝐦𝐞𝐦𝐛𝐞𝐫𝐬 𝐰𝐡𝐨 𝐛𝐞𝐥𝐢𝐞𝐯𝐞 𝐭𝐡𝐚𝐭 𝐭𝐡𝐞𝐫𝐞 𝐰𝐚𝐬 𝐧𝐨 𝐪𝐮𝐨𝐫𝐮𝐦 𝐢𝐧 𝐫𝐞𝐬𝐩𝐨𝐧𝐝𝐞𝐧𝐭'𝐬 𝐞𝐥𝐞𝐜𝐭𝐢𝐨𝐧 𝐚𝐬 𝐚𝐠𝐚𝐢𝐧𝐬𝐭 𝐟𝐨𝐮𝐫 𝐨𝐭𝐡𝐞𝐫 𝐦𝐞𝐦𝐛𝐞𝐫 𝐰𝐡𝐨 𝐛𝐞𝐥𝐢𝐞𝐯𝐞 𝐭𝐡𝐚𝐭 𝐭𝐡𝐞𝐫𝐞 𝐰𝐚𝐬 𝐬𝐮𝐜𝐡 𝐪𝐮𝐨𝐫𝐮𝐦. 𝐓𝐰𝐨 𝐦𝐞𝐦𝐛𝐞𝐫𝐬 𝐝𝐞𝐜𝐥𝐢𝐧𝐞𝐝 𝐭𝐨 𝐫𝐞𝐧𝐝𝐞𝐫 𝐭𝐡𝐞𝐢𝐫 𝐨𝐩𝐢𝐧𝐢𝐨𝐧 𝐨𝐧 𝐭𝐡𝐞 𝐦𝐚𝐭𝐭𝐞𝐫 𝐛𝐞𝐜𝐚𝐮𝐬𝐞 𝐨𝐟 𝐭𝐡𝐞𝐢𝐫 𝐫𝐞𝐟𝐮𝐬𝐚𝐥 𝐭𝐨 𝐚𝐬𝐬𝐮𝐦𝐞 𝐣𝐮𝐫𝐢𝐬𝐝𝐢𝐜𝐭𝐢𝐨𝐧. 𝐀𝐧𝐝, 𝐨𝐧𝐞 𝐦𝐞𝐦𝐛𝐞𝐫 𝐢𝐬 𝐚𝐛𝐬𝐞𝐧𝐭 𝐟𝐫𝐨𝐦 𝐭𝐡𝐞 𝐏𝐡𝐢𝐥𝐢𝐩𝐩𝐢𝐧𝐞𝐬. 𝐓𝐡𝐮𝐬, 𝐭𝐡𝐞 𝐪𝐮𝐞𝐬𝐭𝐢𝐨𝐧 𝐨𝐟 𝐰𝐡𝐞𝐭𝐡𝐞𝐫 𝐨𝐫 𝐧𝐨𝐭 𝐫𝐞𝐬𝐩𝐨𝐧𝐝𝐞𝐧𝐭 𝐡𝐚𝐬 𝐛𝐞𝐞𝐧 𝐥𝐞𝐠𝐚𝐥𝐥𝐲 𝐞𝐥𝐞𝐜𝐭𝐞𝐝 𝐢𝐬, 𝐭𝐨 𝐬𝐚𝐲 𝐭𝐡𝐞 𝐥𝐞𝐚𝐬𝐭, 𝐝𝐨𝐮𝐛𝐭𝐟𝐮𝐥 𝐢𝐧 𝐭𝐡𝐢𝐬 𝐂𝐨𝐮𝐫𝐭 𝐮𝐧𝐝𝐞𝐫 𝐭𝐡𝐞 𝐩𝐫𝐞𝐬𝐞𝐧𝐭 𝐜𝐨𝐧𝐝𝐢𝐭𝐢𝐨𝐧𝐬. 𝐓𝐡𝐢𝐬 𝐝𝐨𝐮𝐛𝐭, 𝐰𝐡𝐢𝐜𝐡 𝐭𝐚𝐢𝐧𝐭 𝐭𝐡𝐞 𝐯𝐚𝐥𝐢𝐝𝐢𝐭𝐲 𝐨𝐟 𝐚𝐥𝐥 𝐭𝐡𝐞 𝐥𝐚𝐰𝐬, 𝐫𝐞𝐬𝐨𝐥𝐮𝐭𝐢𝐨𝐧𝐬 𝐚𝐧𝐝 𝐨𝐭𝐡𝐞𝐫 𝐦𝐞𝐚𝐬𝐮𝐫𝐞𝐬 𝐭𝐡𝐚𝐭 𝐭𝐡𝐞 𝐂𝐮𝐞𝐧𝐜𝐨 𝐠𝐫𝐨𝐮𝐩 𝐡𝐚𝐬 𝐩𝐚𝐬𝐬𝐞𝐝 𝐚𝐧𝐝 𝐦𝐚𝐲 𝐩𝐚𝐬𝐬 𝐢𝐧 𝐭𝐡𝐞 𝐟𝐮𝐭𝐮𝐫𝐞, 𝐜𝐚𝐧 𝐞𝐚𝐬𝐢𝐥𝐲 𝐛𝐞 𝐝𝐢𝐬𝐩𝐞𝐥𝐥𝐞𝐝 𝐛𝐲 𝐭𝐡𝐞𝐦 𝐛𝐲 𝐜𝐨𝐧𝐯𝐞𝐧𝐢𝐧𝐠 𝐚 𝐬𝐞𝐬𝐬𝐢𝐨𝐧 𝐰𝐡𝐞𝐫𝐞𝐢𝐧 𝐭𝐡𝐢𝐫𝐭𝐞𝐞𝐧 𝐬𝐞𝐧𝐚𝐭𝐨𝐫𝐬 𝐚𝐫𝐞 𝐩𝐫𝐞𝐬𝐞𝐧𝐭 𝐚𝐧𝐝 𝐛𝐲 𝐫𝐞𝐢𝐭𝐞𝐫𝐚𝐭𝐢𝐧𝐠 𝐭𝐡𝐞𝐫𝐞𝐢𝐧 𝐚𝐥𝐥 𝐭𝐡𝐚𝐭 𝐡𝐚𝐬 𝐛𝐞𝐞𝐧 𝐩𝐫𝐞𝐯𝐢𝐨𝐮𝐬𝐥𝐲 𝐝𝐨𝐧𝐞 𝐛𝐲 𝐭𝐡𝐞𝐦. 𝐓𝐡𝐢𝐬 𝐢𝐬 𝐚 𝐬𝐮𝐠𝐠𝐞𝐬𝐭𝐢𝐨𝐧 𝐜𝐨𝐦𝐢𝐧𝐠 𝐟𝐫𝐨𝐦 𝐚 𝐡𝐮𝐦𝐛𝐥𝐞 𝐜𝐢𝐭𝐢𝐳𝐞𝐧 𝐰𝐡𝐨 𝐢𝐬 𝐰𝐚𝐭𝐜𝐡𝐢𝐧𝐠 𝐰𝐢𝐭𝐡 𝐚 𝐡𝐚𝐩𝐩𝐲 𝐡𝐞𝐚𝐫𝐭 𝐭𝐡𝐞 𝐦𝐨𝐯𝐞𝐦𝐞𝐧𝐭 𝐨𝐟 𝐭𝐡𝐢𝐬 𝐠𝐚𝐥𝐥𝐚𝐧𝐭 𝐠𝐫𝐨𝐮𝐩 𝐨𝐟 𝐩𝐫𝐨𝐦𝐢𝐧𝐞𝐧𝐭 𝐥𝐞𝐚𝐝𝐞𝐫𝐬 𝐜𝐚𝐦𝐩𝐚𝐢𝐠𝐧𝐢𝐧𝐠 𝐟𝐨𝐫 𝐚 𝐜𝐥𝐞𝐚𝐧 𝐚𝐧𝐝 𝐡𝐨𝐧𝐞𝐬𝐭 𝐠𝐨𝐯𝐞𝐫𝐧𝐦𝐞𝐧𝐭 𝐢𝐧 𝐭𝐡𝐢𝐬 𝐝𝐞𝐚𝐫 𝐜𝐨𝐮𝐧𝐭𝐫𝐲 𝐨𝐟 𝐨𝐮𝐫𝐬.”