Law Reform Continued and Drafting of Laws

Serrano v. Gallant Maritime the law is a legitimate exercise of police power of the State to regulate the recruitment and deployment of
Services, Inc. and Marlow OFWs, to ensure respect for the dignity and well-being of OFWs wherever they may be employed
Navigation Co., Inc. G.R.
167614, March 24, 2009, The enactment of the subject clause in R.A. No. 8042 introduced a differentiated rule of computation of the
601 Phil. 245 (2009) money claims of illegally dismissed OFWs based on their employment periods
• It singles out those whose contracts have an unexpired portion of one year or more and subjecting
them to the peculiar disadvantage of having their monetary awards limited to their salaries for 3
months or for the unexpired portion thereof, whichever is less
• However, it spares the others who have less than a year from such prejudice, simply because the
latter's unexpired contracts fall short of one year

This court ruled that the clause “or for 3 months for every year of the unexpired term, whichever is less” is
unconstitutional for violating the equal protection clause and substantive due process.

Sameer Overseas A statute or provision which was declared unconstitutional is not a law. It “confers no rights; it imposes no
Placement Agency, Inc. V. duties; it affords no protection; it creates no office; it is inoperative as if it has not been passed at all.”
Cabiles, G.R. No. 170139,
August 5, 2014 When a law or a provision of law is null because it is inconsistent with the Constitution, the nullity cannot be
cured by reincorporation or reenactment of the same or a similar law or provision.
A law or provision of law
that was already declared unconstitutional remains as such unless circumstances have so changed as to
warrant a reverse conclusion.

Powerhouse Staffbuilders The award of the three-month equivalent of respondent employees' salaries should be increased to the
International, Inc v. amount equivalent to the unexpired term of the employment contract in accordance with our rulings in
Romelia Rey, GR 190203, Serrano v. Gallant Maritime Services, Inc. and Sameer Overseas Placement Agency, Inc. v. Cabiles.

Nov. 7, 2016
In Serrano, we declared unconstitutional the clause in Section 10 of R.A. No. 8042 limiting the wages that
could be recovered by an illegally dismissed overseas worker to three months. We held that the clause "or
for three (3) months for every year of the unexpired term, whichever is less" (subject clause) is both a
violation of the due process and equal protection clauses of the Constitution.


In 2010, upon promulgation of Republic Act No. 10022, the subject clause was reinstated. Presented with
the unique situation that the law passed incorporated the exact clause already declared unconstitutional,
 without any perceived substantial change in the circumstances, in Sameer, we, once again, declared the
reinstated clause unconstitutional, this time as provided in Section 7 of R.A. No. 10022.

Chavez v. JBC, G.R. No. Language used in the Constitution shall be taken to have been deliberately chosen for a definite purpose.
202242, April 16, 2013 The Words employed must be interpreted to exude its deliberate intent. It must be maintained inviolate
(Resolution on the MR) against disobedience and defiance


Constitution is clear in providing that Congress is entitled to only 1 seat in the JBC. Had the intention be
different, then the wording would have been different. The framers made adjustments in the Constitution in
consideration of the shift to a bicameral system. It is not based on the constituency of the House of
Representatives or the Senate. Just as the Judiciary and the Executive only have 1 representative in the
JBC.

People v. Maceren, G.R. The lawmaking body cannot delegate to an executive official the power to declare what acts should
No. L-32166 October 18, constitute a criminal offense. It can authorize the issuance of regulations and the imposition of the penalty
1977 provided for in the law itself.

Administrative agencies are clothed with rule-making powers because the lawmaking body finds it
impracticable, if not impossible, to anticipate and provide for the multifarious and complex situations that
may be encountered in enforcing the law. All that is required is that the regulation should be germane to the
objects and purposes of the law and that it should conform to the standards that the law prescribes.


The rule-making power must be confined to details for regulating the mode or proceeding to carry into effect
the law as it has been enacted. The power cannot be extended to amending or expanding the statutory
requirements or to embrace matters not covered by the statute.

Metropolitan Bank and The power of administrative agencies is confined to implementing the law or putting it into effect. Corollary
Trust Company, Inc. v. to this guideline is that administrative regulation cannot extend the law and amend a legislative enactment.

National Wages and
Productivity Commission The rules of administrative officers and boards, which have the effect of extending, or which conflict with
(GR 144322) February 6, the authority-granting statute, do not represent a valid exercise of the rule-making power but constitute an
2007 attempt by an administrative body to legislate


When the application of an administrative issuance modifies existing laws or exceeds the intended scope,
as in this case, the issuance becomes void, not only for being ultra vires, but also for being unreasonable.
Lokin v. Comelec (GR Requisites of a VALID IRR:
179431-32), June 22, 2010 1. Its promulgation must be authorized by the Legislature;
2. It must be within the scope of the authority given by the Legislature;
3. It must be promulgated in accordance with the prescribed procedure;
4. It must be reasonable.

The authority to make IRRs in order to carry out an express legislative purpose, or to effect the operation
and enforcement of a law is not a power exclusively legislative in character, but is rather administrative in
nature. The resulting IRRs must not be ultra vires.

CIR v. Bicolandia Drug In cases of conflict between the law and the rules and regulations implementing the law, the law shall always
Corporation, G.R. 148083, prevail. Should Revenue Regulations deviate from the law they seek to implement, they will be struck down.
July 21, 2006

International Human Rights Law: Domestic Recourse

Tañada v. Angara, G.R. By the doctrine of incorporation, the country is bound by generally accepted principles of international law,
118295, May 2, 1997 which are considered to be automatically part of our own laws. 


One of the oldest and most fundamental rules in international law is pacta sunt servanda — international
agreements must be performed in good faith. 


By their inherent nature, treaties really limit or restrict the absoluteness of sovereignty. By their voluntary
act, nations may surrender some aspects of their state power in exchange for greater benefits granted by
or derived from a convention or pact. After all, states, like individuals, live with coequals, and in pursuit of
mutually covenanted objectives and benefits, they also commonly agree to limit the exercise of their
otherwise absolute rights.

The sovereignty of a state therefore cannot in fact and in reality be considered absolute. Certain restrictions
enter into the picture:
(1) limitations imposed by the very nature of membership in the family of nations and
(2) limitations imposed by treaty stipulations.

Simon v. CHR, G.R. 100150, The SC held that decisions have consistently refused to regard the CHR as a quasi-judicial body.
The
January 5, 1994 Commission on Human Rights was not meant by the fundamental law to be another court or quasi-judicial
agency in this country or duplicate much less take over the functions of the latter. The most that the
 Commission can do is that it may investigate, i.e., receive evidence and make findings of fact as regards
claimed human rights violations involving civil and political rights.

CHR has the authority to “adopt its operational guidelines and rules of procedure and cite for contempt for
violations thereof in accordance with the Rules of Court.” However, this authority is limited to violations of
its rules and guidelines in line with its investigatorial powers.

Cariño v. CHR, G.R. 9668I, The most that may be conceded to the Commission in the way of adjudicative power is that it may
December 2, 1991 investigate, i.e., receive evidence and make findings of fact as regards claimed human rights violations
involving civil and political rights.

The legal meaning of "investigate" is "to follow up step by step by patient inquiry or observation. To trace
or track; to search into; to examine and inquire into with care and accuracy; to find out by careful inquisition;
examination; the taking of evidence; a legal inquiry;" "to inquire; to make an investigation," "investigation"
being in turn described as "(a)n administrative function, the exercise of which ordinarily does not require a
hearing. “an inquiry, judicial or otherwise, for the discovery and collection of facts concerning a certain
matter or matters."

In the legal sense, "adjudicate" means: "To settle in the exercise of judicial authority. To determine finally.
Synonymous with adjudge in its strictest sense;" and "adjudge" means: "To pass on judicially, to decide,
settle or decree, or to sentence or condemn.

Secretary of National The petition for a writ of amparo is a remedy available to any person whose right to life, liberty and security
Defense v. Manalo, G.R. is violated or threatened with violation by an unlawful act or omission of a public official or employee, or of
180906, October 26, 2008 a private individual or entity. The writ shall cover extralegal killings and enforced disappearances or threats
thereof. The parties shall establish their claims by substantial evidence.

Vivares v. STC, G.R. Writ of Habeas Data a remedy available to any person whose right to privacy in life, liberty or security is
202666, September 29, violated or threatened by an unlawful act or omission of a public official or employee, or of a private individual
2014 or entity engaged in the gathering, collecting or storing of data or information regarding the person, family,
home and correspondence of the aggrieved party.

Nothing in the Rule would suggest that the habeas data protection shall be available only against abuses
of a person or entity engaged in the business of gathering, storing, and collecting of data. What matters is
that the person or entity must be gathering, collecting or storing said data or information about the aggrieved
 party or his or her family. Having an expectation of informational privacy is not necessarily incompatible with
engaging in cyberspace activities, including those that occur in Online Social Networks. However, before
one can have an expectation of privacy in his or her OSN activity, it is first necessary that said user, manifest
the intention to keep certain posts private, through the employment of measures to prevent access thereto
or to limit its visibility


Had it been proved that the access to the pictures posted were limited to the original uploader, through the
"Me Only" privacy setting, or that the user's contact list has been screened to limit access to a select few,
through the "Custom" setting, the result may have been different

In the Matter of the Petition Despite the lack of certain contents, which the Rules on the Writs of Amparo and Habeas Data generally
for the Writ of Amparo and require, for as long as their absence under exceptional circumstances can be reasonably justified, a petition
the Writ of Habeas Data in should not be susceptible to outright dismissal
favor of Francis Saez v.
GMA, G.R. 183533,
September 25, 2012
Abogado, et al. v. Issued a writ of kalikasan to protect, preserve, rehabilitate, and to restore the marine environment in
Department of Scarborough Shoal (also known as Panatag Shoal), Ayungin Shoal, and Panganiban Reef (also known as
Environment and Natural Mischief Reef).
Resources, et al., G.R. No.
246209, May 3, 2019
International Human Rights Law: International Recourse, Navigating thru the System and Procedure
Inmates of the New Bilibid Administrative IRRs adopted by a particular department of the Government under legislative authority must
Prison, et al. vs. Sec. Leila be in harmony with the provisions of the law, and should be for the sole purpose of carrying the law's general
M. De Lima, provisions into effect. The law itself cannot be expanded by such IRRs, because an administrative agency
cannot amend an act of Congress. 


Every new law has a prospective effect. Under Article 22 of the RPC, however, a penal law that is favorable
or advantageous to the accused shall be given retroactive effect if he is not a habitual criminal. These are
the rules, the exception, and the exception to the exception on the effectivity of laws.

Karen Vertido v. The Committee notes the undisputed fact that the case remained at the trial court level from 1997 to 2005.
Philippines It considers that for a remedy to be effective, adjudication of a case involving rape and sexual offenses
claims should be dealt with in a fair, impartial, timely and expeditious manner.

 The Committee stresses that stereotyping affects women’s right to a fair and just trial and that the judiciary
must take caution not to create inflexible standards of what women or girls should be or what they should
have done when confronted with a situation of rape based merely on preconceived notions of what defines
a rape victim or a victim of gender-based violence, in general.

Litigation: Forms Commonly Attached to a Common Pleading

Prince Transport, Inc. v. General prayer is broad enough "to justify extension of a remedy different from or together with the specific
Garcia, G.R. No. 167291, remedy sought." Even without the prayer for a specific remedy, proper relief may be granted by the court if
January 12, 2001 the facts alleged in the complaint and the evidence introduced so warrant.

The court shall grant relief warranted by the allegations and the proof even if no such relief is prayed for.
The prayer in the complaint for other reliefs equitable and just in the premises justifies the grant of a relief
not otherwise specifically prayed for.

Manchester Development The Court cannot close this case without making the observation that it frowns at the practice of counsel
Corporation v. CA, No. L- who filed the original complaint in this case of omitting any specification of the amount of damages in the
75919, May 7, 1987, 149 prayer although the amount of over P78 million is alleged in the body of the complaint.
SCRA 562
This is clearly intended for no other purpose than to evade the payment of the correct filing fees if not to
mislead the docket clerk in the assessment of the filing fee. This fraudulent practice was compounded when,
even as this Court had taken cognizance of the anomaly and ordered an investigation, petitioner through
another counsel filed an amended complaint, deleting all mention of the amount of damages being asked
for in the body of the complaint.

Cosco Philippines The certification against forum shopping must be signed by the principal parties. If, for any reason, the
Shopping Inc. v. Kemper principal party cannot sign the petition, the one signing on his behalf must have been duly authorized. With
Insurance Co., G.R. 179488, respect to a corporation, the certification against forum shopping may be signed for and on its behalf, by a
April 23, 2012 specifically authorized lawyer who has personal knowledge of the facts required to be disclosed in such
document.

Only individuals vested with authority by a valid board resolution may sign the certificate of non-forum
shopping on behalf of a corporation. (PAL vs. FASAP) 


The petition is subject to dismissal if a certification was submitted unaccompanied by proof of the signatory’s
authority.
Vda De Formosa v. PNB, The certification against forum shopping in CA-G.R. SP No. 72284 is fatally defective, not having been duly
G.R. No. 154704, June 1, signed by both petitioners and thus warrants the dismissal of the petition for certiorari. We have consistently
2011 held that the certification against forum shopping must be signed by the principal parties.

Spouses Ello v. CA, G.R. Whenever personal service or filing is practicable, in light of the circumstances of time, place and person,
No. 141255, June 21, 2005 personal service or filing is mandatory.

Manasan's affidavit of service is a substantial compliance with the requirement. The procedural lapse did
not in any way thwart the laudable objective of Sec. 11.


Intestate Estate of Jose Uy The inclusion of a counsel’s Roll of Attorneys number, professional tax receipt number, and Integrated Bar
v. Atty. Maghari III, A.C. No. of the Philippines (IBP) receipt (or lifetime membership) number is intended to preserve and protect the
10525, Sept. 1, 2015 integrity of legal practice. In failing to accurately state his professional details, Maghari already committed
punishable violations. An isolated inaccuracy, regardless of the concerned lawyer’s lack of bad faith, already
merits a penalty of relative severity.

Maghari also acted with dishonest, deceitful, and even larcenous intent. He is not only accountable for
inaccuracies. In using false information in his pleadings, Maghari unnecessarily put his own client at risk.
Deficiencies in how pleadings are signed can be fatal to a party’s cause as unsigned pleadings produce no
legal effect.

Spouses Munsalud v. NHA, A pleading is sufficient in form when it contains the following:
G.R. 167181, Dec 23, 2008 • A Caption, setting forth the name of the court, the title of the action indicating the names of the
parties, and the docket number which is usually left in blank, as the Clerk of Court has to assign yet
a docket number;
• The Body, reflecting the designation, the allegations of the party's claims or defenses, the relief
prayed for, and the date of the pleading;
• The Signature and Address of the party or counsel;
• Verification. This is required to secure an assurance that the allegations have been made in good
faith, or are true and correct and not merely speculative;
• A Certificate of Non-forum Shopping, which although not jurisdictional, the same is obligatory;
• An Explanation in case the pleading is not filed personally to the Court. Likewise, for pleading
subsequent to the complaint, if the same is not served personally to the parties affected, there must
also be an explanation why service was not done personally.
 Civil Litigation and Common Forms; Family Law Practice
Cooperative Inc. v. Aquino, A written motion which fails to comply with the 3-day rule regarding the hearing of the motion will be treated
G.R. No. 167691, as a mere scrap of paper.
September 23, 2008
Criminal Litigation and Common Forms
Zamoranos v. People, G.R. The Shari'a Circuit Court is not vested with jurisdiction over offenses penalized under the RPC. Certainly,
193902, June 1, 2011 the Regional Trial Courts are vested the exclusive and original jurisdiction in all criminal cases not within
the exclusive original jurisdiction of any court, tribunal, or body. 


The Code of Muslim Personal Laws (PD 1083) created the Sharia District Courts and Sharia Circuit Courts
with limited jurisdiction. Neither court was vested jurisdiction over criminal prosecution of violations of the
Revised Penal Code.

Nonetheless, it must be pointed out that even in criminal cases, the trial court must have jurisdiction over
the subject matter of the offense.

Trying Zamoranos for Bigamy simply because the regular criminal courts have jurisdiction over the offense
defeats the purpose for the enactment of the Code of Muslim Personal Laws and the equal recognition
bestowed by the State on Muslim Filipinos. *determine first in sharia courts the validity of the marriage

Inmates of the New Bilibid A penal provision or statute has been consistently defined by jurisprudence as follows: 

Prison, et al. vs. Sec. Leila • A penal provision defines a crime or provides a punishment for one

M. De Lima, • Penal law and laws which, while not penal in nature, have provisions defining offenses and
prescribing penalties for their violation. 

• Properly speaking, a statute is penal when it imposes punishment for an offense committed against
the state which, under the Constitution, the Executive has the power to pardon. In common use,
however, this sense has been enlarged to include within the term "penal statutes" all statutes which
command or prohibit certain acts, and establish penalties for their violation, and even those which,
without expressly prohibiting certain acts, impose a penalty upon their commission. 

• Penal laws are those acts of the Legislature which prohibit certain acts and establish penalties for
their violations; or those that define crimes, treat of their nature, and provide for their punishment.

The United States v. The allegations of an information should, if possible, be sufficiently explicit and certain as to time to inform
Dichao, G.R. No. L-8781, the defendant of the date on which the criminal act is alleged to have been committed. Unless the accused
March 30, 1914
 is informed of the day, or about the day, he may be, to an extent, deprived of the opportunity to defend
himself.

Where the exact date cannot fixed, or where the prosecuting officer is not thoroughly satisfied that he can
prove a precise date, he should allege in the information that the crime was committed on or about a date
named. Under such allegation he is not required to prove any precise date but may prove any date which
is not so remote as to surprise and prejudice the defendant.

Forms Common to Civil and Criminal Litigation

Ong Ching v. Ramolete, The settled rule is that in order that there may be a valid substitution of attorneys in a given case, there
G.R. L-35356, May 18, 1973 must be:
(a) written application for substitution;
(b) a written consent the client; and
(c) a written consent of the attorney to be substituted.

Cabador v. People of the To determine whether the pleading filed is a demurrer to evidence or a motion to dismiss, the Court must
Philippines, G.R. 186001, consider
October 2, 2009 (1) the allegations in it made in good faith;
(2) the stage of the proceeding at which it is filed; and
(3) the primary objective of the party filing it.

Since Cabador filed his motion to dismiss before he could object to the prosecution's formal offer, before
the trial court could act on the offer, and before the prosecution could rest its case, it could not be said that
he had intended his motion to dismiss to serve as a demurrer to evidence.

Rivera v. People of the If the court denies the demurrer to evidence filed with leave of court, the accused may adduce evidence in
Philippines, G.R. 163996, his defense. When the demurrer to evidence is filed without leave of court, the accused waives the right to
June 9, 2006 present evidence and submits the case for judgment on the basis of the evidence for the prosecution

Lejano v. Philippines, G.R. A judgment of acquittal cannot be reconsidered because it places the accused under double jeopardy in
No. 176389, January 18, accordance with Art. III Sec. 21 of the 1987 Constitution which provides that no person shall be twice put in
2011 Resolution jeopardy of punishment for the same offense.
 On occasions, a motion for reconsideration after an acquittal is possible. But the grounds are exceptional
and narrow as when the court that absolved the accused gravely abused its discretion, resulting in loss of
jurisdiction, or when a mistrial has occurred.

Notarial Practice: Notarial Law and Rules

Cruz v. Centron, A.M. No. As a clerk of court, respondent is also an ex-officio notary public. However, clerks of court may only notarize
P-02-1644. November 11, documents or administer oaths only when the matter is related to the exercise of their official functions.
2004;; 442 SCRA 53 (2004)

Tigno v. Spouses Aquino,
G.R. No. 129416. November
25, 2004;; 444 SCRA 61
(2004) [please also cover
the topic under the last part
of the syllabus]
MTC and MCTC judges are empowered to perform the functions of notaries public ex officio. The Court
explicitly declared that municipal court judges such as Cariño may notarize only documents connected with
the exercise of their official duties.
There are possible grounds for leniency in connection with this matter, the SC permits notaries public ex
officio to perform any act within the competency of a regular notary public provided that certification be
made in the notarized documents attesting to the lack of any lawyer or notary public in such municipality or
circuit. Indeed, it is only when there are no lawyers or notaries public that the exception applies

Fuentes v. Buno, A.M. No.
MTJ-99-1204 (Formerly
OCA IPI No. 97-355-MTJ),
July 28, 2008;; 560 SCRA
22 (2008)
SC Circular No. 1-90 prohibits judges from undertaking the preparation and acknowledgment of private
documents, contracts and other deeds of conveyances which have no direct relation to the discharge of
their official functions.
While it may be true that no notary public was available or residing within Judge Buno’s territorial jurisdiction,
as shown by the certifications issued by the RTC Clerk of Court and the Municipal Mayor of Talibon, Bohol,
SC Circular No. 1-90 specifically requires that a certification attesting to the lack of any lawyer or notary
public in the said municipality or circuit be made in the notarized document.

Vda. De Rosales v. Ramos, It is clear from the pleadings before us that respondent violated the Notarial Law in failing to register in his
A.C. No. 5645. July 2, 2002;; notarial book the deed of absolute sale he notarized, which fact respondent readily admitted.
The
383 SCRA 498 (2002)
Notarial Law is explicit on the obligations and duties of a notary public. It requires him to keep a notarial
register where he shall record all his official acts as notary,and specifies what information with regard to the
notarized document should be entered therein. Failure to perform this duty results in the revocation of his
commission as notary public

 Notarization converts a private document into a public document thus making that document admissible in
evidence without further proof of its authenticity. A notarial document is by law entitled to full faith and credit
upon its face. Courts, administrative agencies and the public at large must be able to rely upon the
acknowledgment executed by a notary public and appended to a private instrument.

Dela Cruz v. Zabala, A.C. Notarization is not an empty, meaningless routinary act. It is invested with substantive public interest. It
No. 6294. November 17, must be underscored that the notarization by a notary public converts a private document into a public
2004;; 442 SCRA 407 (2004) document, making that document admissible in evidence without further proof of authenticity thereof. 


A notary public should not notarize a document unless the persons who signed the same are the very same
persons who executed and personally appeared before him to attest to the contents and the truth of what
are stated therein. These acts of the affiants cannot be delegated because what are stated therein are facts
they have personal knowledge of and are personally sworn to.

Lee v. Tambago, A.C. No. The Civil Code requires that a will must be acknowledged before a notary public by the testator and the
5281, February 12, 2008;; witnesses. 

544 SCRA 393 (2008)
An acknowledgment is the act of one who has executed a deed in going before some competent officer
or court and declaring it to be his act or deed. It involves an extra step undertaken whereby the signatory
actually declares to the notary public that the same is his or her own free act and deed.

The acknowledgment in a notarial will has a two-fold purpose:

• to safeguard the testator's wishes long after his demise and
• to assure that his estate is administered in the manner that he intends it to be done.

Dela Cruz v. Dimaano, A.C. Notaries public should refrain from affixing their signature and notarial seal on a document unless the
No. 7781, September 12, persons who signed it are the same individuals who executed and personally appeared before the notaries
2008;; 565 SCRA 1 (2008) public to attest to the truth of what are stated therein.


Without the appearance of the person who actually executed the document in question, notaries public
would be unable to verify the genuineness of the signature of the acknowledging party and to ascertain that
the document is the party’s free act or deed.


Furthermore, notaries public are required by the Notarial Law to certify that the party to the instrument has
acknowledged and presented before the notaries public the proper residence certificate (or exemption from
 the residence certificate) and to enter its number, place, and date of issue as part of certification. The
Notarial Law requires a party to the instrument to present competent evidence of identity.

Heirs of Amparo Del the grant of the motion for summary judgment was proper because there were no factual issues and
Rosario v. Santos, G.R. No. because the respondent, in effect, admitted to the due execution of the document in question.
L-46892 September 30,
1981;; 108 SCRA 43 (1981) The admission of the due execution of the document meant that they also admit to the voluntary signing of
the same: That it was the respondent who signed it; or That it was signed by another for the respondent
with the latter’s authority.


Such admission meant that the party whose signature it bears admits that at the time it was signed, it was
in the words and figures exactly as set out in the pleading of the party relying upon it


In effect, any formal requisites required by law, such as swearing and acknowledgment, or revenue stamps
required – are waived

Permanent Savings and The pertinent rule on actionable documents is found in Rule 8, Section 7 of the Rules of Court which
Loan Bank v. Velarde, G.R. provides that when the cause of action is anchored on a document, the genuineness or due execution of
NO. 140608, September 23, the instrument shall be deemed impliedly admitted unless the defendant, under oath, specifically denies
2004;; 439 SCRA 1 (2004) them, and sets forth what he claims to be the facts.

“Be strong and courageous. Do not be afraid or terrified because of them, for the LORD your God goes

with you; he will never leave you nor forsake you.”

Deuteronomy 31:6