Notes on Conflicts of Laws

CONFLICTS OF LAWS; Definition:

That part of the law of each state or nation which determines whether, in dealing with a legal
situation, the law or some other state or nation will be recognized, given effect, or applied (16
Am Jur, 2d, Conflict of Laws, §1).

That part of municipal law of a state which directs its courts and administrative agencies, when
confronted with a legal problem involving a foreign element, whether or not they should apply a
foreign law/s (Paras).

DISTINGUISHED FROM PUBLIC INTERNATIONAL LAW

BASIS CONFLICT OF LAW LAW OF NATIONS

1 Nature Municipal in character International in character

Dealt with by private

Sovereign states and other entities
individuals; governs
Persons possessing international personality, e.g.,
2 involved individuals in their private
UN; governs states in their relationships
transactions which involve a
amongst themselves
foreign element
Generally affected by public interest;
Transactions Private transactions between
3 involved those in general are of interest only to
private individuals
sovereign states
May be peaceful or forcible
Peaceful: includes diplomatic negotiation,
tender & exercise of good offices,
mediation, inquiry & conciliation,
Remedies arbitration, judicial settlement by ICJ,
4 and Resort to municipal tribunals reference to regional agencies
Sanctions Forcible: includes severance of
diplomatic relations, retorsions, reprisals,
embargo, boycott, non-intercourse, pacific
blockades, collective measures under the
UN Charter, and war.

SOURCES:
Direct:

1. Constitutions
2. Codifications
a. Special Laws
b. Treaties and Conventions
c. Judicial Decisions
d. International Customs
Indirect:

1. Natural moral law

a. Work of writers
TERMS:

Lex Domicilii – law of the domicile; in conflicts, the law of one’s domicile applied in the choice
of law questions

Lex Fori – law of the forum; that is, the positive law of the state, country or jurisdiction of whose
judicial system of the court where the suit is brought or remedy is sought is an integral part.
Substantive rights are determined by the law where the action arose (lex loci) while the
procedural rights are governed by the law of the place of the forum (lex fori)

Lex Loci – law of the place

Lex Loci Contractus – the law of the place where the contract was made or law of the place
where the contract is to be governed (place of performance) which may or may not be the same
as that of the place where it was made

Lex Loci Rei Sitae – law of the place where the thing or subject matter is situated; the title to
realty or question of real estate law can be affected only by the law of the place where it is
situated

Lex Situs – law of the place where property is situated; the general rule is that lands and other
immovables are governed by the law of the state where they are situated

Lex Loci Actus – law of the place where the act was done

Lex Loci Celebrationis – law of the place where the contract is made

Lex Loci Solutionis – law of the place of solution; the law of the place where payment or
performance of a contract is to be made

Lex Loci Delicti Commissi – law of the place where the crime took place

Lex Mereatoria – law merchant; commercial law; that system of laws which is adopted by all
commercial nations and constitute as part of the law of the land; part of common law

Lex Non Scripta – the unwritten common law, which includes general and particular customs
and particular local laws

Lex Patriae – national law

Nationality Theory – by virtue of which the status and capacity of an individual are generally
governed by the law of his nationality. This is principally adopted in the RP

Domiciliary Theory – in general, the status, condition, rights, obligations, & capacity of a
person should be governed by the law of his domicile.

Long Arm Statutes – Statutes allowing the courts to exercise jurisdiction when there are
minimum contacts between the non-resident defendant and the forum.

WAYS OF DEALING WITH A CONFLICTS PROBLEM:

1. Dismiss the case for lack of jurisdiction, or on the ground of forum non-
conveniens

DOCTRINE OF FORUM NON CONVENIENS – the forum is inconvenient; the ends of justice
would be best served by trial in another forum; the controversy may be more suitably tried
elsewhere
 1. Assume jurisdiction and apply either the law of the forum or of another state
a. A specific law of the forum decrees that internal law should apply

APPLY INTERNAL LAW – forum law should be applied whenever there is good reason to do
so; there is a good reason when any one of the following factors is present:
Examples:

 Article. 16 of the Civil Code – real and personal property subject to the law of the country
where they are situated and testamentary succession governed by lex nationalii

 Article 829 of the Civil Code – makes revocation done outside Philippines valid
according to law of the place where will was made or lex domicilii

 Article 819 of the Civil Code – prohibits Filipinos from making joint wills even if valid in
foreign country

b. The proper foreign law was not properly pleaded and proved

NOTICE AND PROOF OF FOREIGN LAW

As a general rule, courts do not take judicial notice of foreign laws; Foreign laws must be
pleaded and proved

Effect of failure to plead and prove foreign law (3 alternatives) of the forum court:

A. Dismiss the case for inability to establish cause of action

B. Assume that the foreign law of the same as the law of the forum
C. Apply the law of the forum

The case falls under any of the exceptions to the application of foreign law
Exceptions to application of foreign law:

a. The foreign law is contrary to the public policy of the forum

b. The foreign law is procedural in nature
c. The case involves issues related to property, real or personal (lex situs)
d. The issue involved in the enforcement of foreign claim is fiscal or administrative
e. The foreign law or judgment is contrary to good morals (contra bonos mores)
f. The foreign law is penal in character
g. When application of the foreign law may work undeniable injustice to the citizens of the
forum
h. When application of the foreign law might endanger the vital interest of the state

APPLY FOREIGN LAW – when properly pleaded and proved

THEORIES WHY FOREIGN LAW SHOULD BE GIVEN EFFECT

1. Theory of Comity – foreign law is applied because of its convenience & because we
want to give protection to our citizens, residents, & transients in our land

2. Theory of Vested Rights – we seek to enforce not foreign law itself but the rights that
have been vested under such foreign law; an act done in another state may give rise to
the existence of a right if the laws of that state crated such right.

3. Theory of Local Law– adherents of this school of thought believe that we apply foreign
law not because it is foreign, but because our laws, by applying similar rules, require us
to do so; hence, it is as if the foreign law has become part & parcel of our local law
 4. Theory of Harmony of Laws – theorists here insist that in many cases we have to
apply the foreign laws so that wherever a case is decided, that is, irrespective of the
forum, the solution should be approximately the same; thus, identical or similar solutions
anywhere & everywhere. When the goal is realized, there will be “harmony of laws”

5. Theory of Justice – the purpose of all laws, including Conflict of Laws, is the dispensing
of justice; if this can be attained in may cases applying the proper foreign law, we must
do so

CHARACTERIZATION – the process of determining under what category a certain set of facts
or rules fall.

FACTORS WHICH GIVE RISE RO THE PROBLEM OF CHARACTERIZATION:

1. Different legal systems attach to the same legal term with different meaning;

2. Different legal systems may contain ideas or conceptions completely unknown to one
another;

3. Different legal systems apply different principles for the solution of problems which, in
general terms, are of a common nature.

STATUS – the place of an individual in society, and consists of personal qualities and
relationships, more or less permanent, with which the state and the community are concerned.

CAPACITY – is merely a part of status, and may be defined as the sum total of his rights and
obligations.

THREE THEORIES ON PERSONAL LAW OR THE LAW THAT SHOULD GOVERN STATUS
AND CAPACITY IN GENERAL:

1. NATIONALITY THEORY – by virtue of which the status and capacity of an individual are
generally governed by the law of his nationality (also called PERSONAL THEORY)

2. DOMICILIARY THEORY – which regards the law of the domicile as the proper
determinative law on status and capacity (also called TERRITORIAL THEORY).

3. SITUS THEORY – which views the particular place or situs of an event or transaction as
generally the controlling law (also called ECLECTIC THEORY).

RENVOI – literally means a referring back; the problem arises when there is a doubt as to
whether a reference to a foreign law –

a. is a reference to the INTERNAL law of said foreign law; or

b. is a reference to the WHOLE of the foreign law, including its CONFLICTING RULES.

DOUBLE RENVOI – is that which occurs when the local court, in adopting the foreign court
theory, discovers that the foreign court accepts the renvoi.

TRANSMISSION – is the process of applying the law of a foreign state thru the law of a second
foreign state.

DOUBLE RENVOI DISTINGUISHED FROM TRANSMISSION

1. DOUBLE RENVOI deals with TWO countries while TRANSMISSION deals with THREE
or MORE countries;
 2. DOUBLE RENVOI deals with a “referring back” while TRANSMISSION deals with a
“transmitting.”

Rules on Status in General (BEANTAP)

Factual Situation Point of Contact

Beginning of personality of natural person National law of the child (Article 15, CC)
1

Ways & effects of emancipation Same

2

Age of majority Same

3

Use of names and surnames Same

4

Use of titles of nobility Same

5

Absence Same
6

Presumptive death & survivorship Lex fori (Article 43, 390, 391, CC; Rule 131
7 §5 [jj], Rules of Court)

Rules on Marriage as a Contract

FACTUAL SITUATION POINT OF CONTACT

Between Filipinos Lex loci celebrationis is without prejudice
Celebrated to the exceptions under Articles 25, 35 (1,
4, 5 & 6), 36, 37 & 38 of the Family Code
Abroad
(bigamous & incestuous marriages) &
consular marriages
Between Foreigners Lex loci celebrationis EXCEPT if the
marriage is:
1. Highly immoral (like bigamous/
polygamous marriages)
2. Universally considered incestuous
(between brother-sister, and
ascendants-descendants)
Mixed Apply 1 (b) to uphold validity of marriage
Between Foreigners National law (Article 21, FC) PROVIDED
Celebrated the marriage is not highly immoral or
universally considered incestuous)
in RP
Mixed National law of Filipino (otherwise public
policy may be militated against)
Marriage by proxy (NOTE: a marriage Lex loci celebrationis (with prejudice to
 by proxy is considered celebrated the foregoing rules)
where the proxy appears

Rules on Marriage as a Status

FACTUAL SITUATION POINT OF CONTACT

Personal rights & obligations between
1 husband & wife
Property relations bet husband & wife
2 the CC provides concerning REAL property
National of husband(Note: Effect of subsequent
change of nationality:
1. If both will have a new nationality – the new
one
2. If only one will change – the last common
nationality
3. If no common nationality – nationality of
husband at the time of wedding)
National law of husband without prejudice to what
located in the RP (Article 80) (NOTE: Change of
nationality has NO EFFECT. This is
the DOCTRINE OF IMMUTABILITY IN THE
MATRIMONIAL PROPERTY REGIME)

Rules on Annulment of a Voidable Marriage and the Declaration of Nullity of a Void

Marriage

FACTUAL SITUATION POINT OF CONTACT

Grounds for annulment (if the marriage
1 is voidable merely) and grounds for
declaration of nullity (if the marriage is
void ab initio)
The law alleged to have been violated: in other
words, it is the law of the place of celebration (lex
loci celebrationis) subject to certain exceptions,
that furnishes the grounds.

Rules for Absolute Divorce

FACTUAL SITUATION POINT OF CONTACT

1. If sought in Lex fori (therefore, will not be granted)

the Phil.
Exception: Moslem divorces
(whether by
Filipinos or by
Foreigners)

(a) Between Filipinos (a) National law (therefore, not valid here
2. If obtained even if valid abroad; and this is true
regardless of the cause of divorce)
abroad
(b) Between foreigners (b) National law (if valid in the State
granting it, and valid according to the
national law of the parties, will also be valid
here? (See Art. 15, Civil Code).

(c) Mixed (c) Apply (a) and (b) respectively. See,

however Art. 26, second par. of the Family
Code.

Some Grounds for Legal Separation

FACTUAL SITUATION POINT OF CONTACT

(1) Grounds for (1) national law of the parties

legal
separation (a) Adultery (a) if of the same or common nationality –
the common national law governs

(b) Concubinage (b) if of different nationalities – the grounds

(c) Attempt by one spouse
against the life of the other
given by BOTH national laws should ALL
be considered proper grounds. (See
Hague Convention on Legal Separation,
Art. 8).
NOTE: Residence requirement if suit is
brought in the Philippines:

(a) if cause occurred in the Philippines –

NO residence requirement

(b) if cause occurred outside the Philippines

– one year residence is required in our
country. (Art. 99, Civil Code).

Rules on Paternity and Filiation, Adoption, Guardianship, and Funerals

FACTUAL SITUATION POINT OF CONTACT

Paternity and filiation If legitimate, NATIONAL LAW OF THE FATHER
- Including Parental Authority and
- Reciprocal support If illegitimate, NATIONAL LAW OF THE MOTHER.
- Legitimacy
- Legitimation If illegitimate but recognized by the father, the
- Recognition NATIONAL LAW OF THE FATHER.
- Presumptions of legitimacy
- Rights and obligations of parents Determination of whether legitimate or illegitimate,
and children NATIONAL LAW OF THE FATHER, in general.
- Including parental authority and
reciprocal support Doctrine of Immutability of Status- change of parents’
nationality does not affect the status of the child.
Adoption- creation of the status of In general, NATIONAL LAW OF THE ADOPTER.
adoption; rights and obligations of
adopter and adopted. In the Philippines, adoption by a Filipino does not
confer Filipino citizenship on an adopted alien child.
Guardianship
 a) Over the person
- appointing court - court of the domicile of the ward

- powers of guardian - coextensive with those of the appointing court

(law of the appointing state)

b) Over the property - court where the property if found (lex rei
- appointing court sitae)
- coextensive with those of the appointing court
- powers of guardian

c) over the person and over the - court where the property and the ward are
property (general guardian) found
- appointing court - coextensive with those of the appointing court

- powers of guardian

Funerals- incidents thereof Where the body is buried.

Rules on Property

FACTUAL SITUATION POINT OF CONTACT

Real property
Exceptions Successional rights
Capacity to succeed
Contracts involving real property
which do not deal with the title thereto
Contracts where the real property is
given as security
Lex rei sitae (Article 16, CC)
National law of decedent (Article 16 par.
2, CC)
National law of decedent (Article. 1039)
The law intended will be the proper law of
the contract (lex loci voluntantis orlex loci
intentionis)
The principal contract (usually loan) is
governed by the proper law oft the
contract – (lex loci voluntatis or lex loci
intentionis)NOTE: the mortgage itself is
governed by lex rei sitae. There is a
possibility that the principal contract is
valid but the mortgage is void; or it may be
the other way around. If the principal
contract is void, the mortgage will also be
void (for lack of proper cause or
consideration), although by itself, the
mortgage could have been valid.

Tangible personal property (choses in possession)

In General Lex rei sitae (Article. 16, CC)
1

Exceptions: same as those for real EXCEPTION: same as those for real
property property EXCEPT that in the example
concerning mortgage, the same must be
changed to pledge of personal property)
Means of Transportation
2 Vessels Law of the flag (or in some cases, place of

Other means
Things in transitu (these things have
3 a changing status because they
move)
Loss, destruction, deterioration
Validity & effect of the seizure of the
goods
Disposition or alienage of the goods
registry)
Law of the depot (storage place for
supplies or resting place)
Law of the destination (Article. 1753, CC)
Locus regit actum (where seized) –
because said place is their temporarysitus
Lex loci volutantis or lex loci intentionis–
because here there is a contract

FACTUAL SITUATION POINT OF CONTACT

Intangible Personal Property (choses in
action)
Recovery of debts or involuntary Where debtor may be effectively served with
1 assignment of debts (garnishment) summons (usually the domicile)

Voluntary assignment of debts Lex loci voluntatis or lex loci intentionis(proper law
2 of the contract)

Other Theories:
1. National law of the debtor or creditor
2. Domicile of the debtor or creditor
3. Lex loci celebrationis
4. Lex loci solutionis
Taxation of debts Domicile of creditor
3

Administration of debts Lex situs of assets of the debtor (for these assets
4 can be held liable for the debts)

Negotiability or non-negotiability of an The right embodied in the instrument (for

5 instrument
Validity of transfer, delivery or
6 negotiation of the instrument
example, in the case of a Swedish bill of
exchange, Swedish law determines its
negotiability)
In general, situs of the instrument at the time of
transfer, delivery or negotiation

Effect on a corporation of the sale of Law of the place incorporation

7 corporate shares

Effect between the parties of the sale Lex loci voluntatis or lex loci intentionis (proper
8 of corporate shares law of the contract) – for this is really a contract;
usually this is the place where the certificate is
delivered)
Taxation on the dividends of corporate Law of the place of incorporation
9 shares

Taxation on the income from the sale Law of the place where the sale was
10 of corporate shares consummated
 Franchises Law of the place that granted them
11

Goodwill of the business & taxation Law of the place where the business is carried on
12 thereto

Patents, copyrights, trademarks, trade
13 names
In the absence of a treaty, they are protected only
by the state that granted them
NOTE: foreigners may sue for infringement of
trademarks and trade names in the RP ONLY IF
Filipinos are granted reciprocal concessions in the
state of the foreigners

Wills, Succession & Administration of Conflict Rules

FACTUAL SITUATION POINT OF CONTACT

Extrinsic Validity of Wills
Made by an alien abroad Lex nationalii OR lex domicilii OR RP law (Article
1 816, CC), OR lex loci celebrationis(Article 17(1))

Made by a Filipino abroad Lex nationalii OR lex loci celebrationis(Article 815)

2

Made by an alien in the RP Lex nationalii OR lex loci celebrationis(Article 817)

3

Extrinsic Validity of Joint Wills (made in the same instrument)

Made by Filipinos abroad Lex nationalii (void, even if valid where made)
1 (Article 819)

Made by aliens abroad Valid if valid according to lex domicilii orlex loci
2 celebrationis (Article 819)

Made by aliens in the RP Lex loci celebrationis therefore void even if

3 apparently allowed by Article 817 because the
prohibition on joint wills is a clear expression of
public policy
Intrinsic Validity of Wills Lex nationalii of the deceased – regardless of the
LOCATION & NATURE of the property (Article 16
(2))
Capacity to Succeed Lex nationalii of the deceased – not of the heir
(Article 1039)
Revocation of Wills
If done in the RP Lex loci actus (of the revocation) (Article. 829)
1

If done OUTSIDE the RP

2 1. By a NON-DOMICILIARY Lex loci celebrationis (of the making of the will,
NOT revocation), OR lex domicilii(Article 829)
 1. By a DOMICILIARY of the RP Lex domicilii (RP law) OR lex loci actus (of the
revocation) (Article 17)
Probate of Wills Made Abroad
If not yet probated abroad Lex fori of the RP applies as to the procedural
1 aspects, i.e., the will must be fully probated here
& due execution must be shown
If already probated abroad Lex fori of the RP again applies as to the
2 procedural aspects; must also be probated here,
but instead of proving due execution, generally it
is enough to ask for the enforcement here of the
foreign judgment on the probate abroad
Executors and Administrators
Where appointed Place where domiciled at death or incase of non-
1 domiciliary, where assets are found

Powers Co-extensive with the qualifying of the appointing

2 court – powers may only be exercised within the
territorial jurisdiction of the court concernedNOTE:
these rules also apply to principal, domiciliary, or
ancillary administrators & receivers even in non-
successive cases

Rules on Obligation and Contracts

FACTUAL SITUATION POINT OF CONTACT

Formal or Extrinsic Validity Lex loci celebrationis (Article 17 {1})
Exceptions
1. Alienation & encumbrance of Lex situs (Article 16 [1])
property
1. Consular contracts Law of the RP (if made in RP consulates)
Capacity of Contracting Parties National law (Article 15) without prejudice to the
case of Insular Government v Frank 13 P 236,
where the SC adhered to the theory of lex loci
celebrationis
Exception
Alienation & encumbrance of property Lex situs (Article 16 {1})
Intrinsic validity (including Proper law of the contract – lex contractus(in the
interpretation of the instruments, and broad sense), meaning the lex voluntatis or lex
amt. of damages for breach) loci intentionis
Other Theories are:
1. Lex loci celebrationis (defect: this makes possible the evasion of the national law)
2. Lex nationalii (defect: this may impede commercial transactions)
3. Lex loci solutionis (law of the place of performance) (defect: there may be several places
of performance
4. Prof Minor’s solution:
5. Perfection – lex loci celebrationis
6. Cause or consideration – lex loci considerations
7. Performance – lex loci solutionis (defect: this theory combines the defect of the others)

Rules on Torts
 FACTUAL SITUATION POINT OF CONTACT

Liability & damages for torts in
generalNOTE: The locus delicti (place of
commission of torts) is faced by the problem of
characterization. In civil law countries,
the locus delicti is generally where the act
began; in common law countries, it is where
the act first became effective
Lex loci delicti (law of the place where the
delict was committed)NOTE: liability for
foreign torts may be enforced in the RP if:
1. The tort is not penal in character
2. If the enforcement of the tortious liability
won’t contravene our public policy
3. If our judicial machinery is adequate for
such enforcement

Rules on Crimes

FACTUAL SITUATION POINT OF CONTACT

Essential elements of a crime and Generally where committed (locus regit actum)
penalties
Theories as to what court has jurisdiction:
1. Territoriality theory – where the crime was committed
2. Nationality theory – country which the criminal is citizen or a subject
3. Real theory – any state whose penal code has been violated has jurisdiction, where the
crime was committed inside or outside its territory
4. Protective theory – any state whose national interests may be jeopardized has jurisdiction
so that it may protect itself
5. Cosmopolitan or universality theory – state where the criminal is found or which has his
custody has jurisdiction
6. Passive personality theory – the state of which the victim is a citizen or subject has
jurisdiction
NOTE: In the RP, we follow the territoriality theory in general; exception: Article 2, RPC,
stresses the protective theory
The locus delicti of certain crimes
Frustrated an consummated, Where the victim was injured (not where the
1 homicide, murder, infanticide & aggressor wielded his weapon)
parricide
Attempted homicide, etc. Where the intended victim was (not where the
2 aggressor was situated) – so long as the weapon
or the bullet either touched him or fell inside the
territory where he was
Bigamy Where the illegal marriage was performed
3

Theft & robbery Where the property was unlawfully taken from the
4 victim (not the place to which the criminal went
after the commission of the crime)
Estafa or swindling thru false Where the object of the crime was received (not
5 representation where the false representations were made)

Conspiracy to commit treason, Where the conspiracy was formed (not where the
6 rebellion, or seditionNOTE: Other overt act of treason, rebellion or sedition was
conspiracies are NOT penalized by committed)
our laws
 Libel Where published or circulated
7

Continuing crime Any place where the offense begins, exists or

8 continues

Complex crime Any place where any of the essential elements of

9 the crime took place

Rules on Juridical Persons

FACTUAL SITUATION POINT OF CONTACT

Corporations
Powers and liabilities
3. Formation of the corporation
(requisites); kind of stocks, transfer of
stocks to bind the corporation,
issuance, amount & legality &
dividends, powers & duties of
members, stockholders and officers
Validity of corporate acts & contracts
(including ultra vires acts)
Right to sue & amenability to court
processes & suits against it
Manner & effect of dissolution
Domicile
Receivers (appointment & powers)
NOTE: Theories on the personal and/or governing law of corporations:
1. Law of the place of incorporation (this is generally the RP rule)
2. Law of the place or center of management (center for administration or siege social)
(center office principle)
General rule: the law of the place of
incorporationEXCEPTIONS:
1. For constitutional purposes – even of the
corporation was incorporated in the RP, it is
nor deemed a Filipino corporation &
therefore can’t acquire land, exploit our
natural resources, 7 operate public utilities
unless 60% of capital if Filipino owned
2. For wartime purposes – we pierce the
corporation veil & go to the nationality of the
controlling stockholders to determine if the
corporation is an enemy (CONTROL TEST)
Law of the place of incorporation
Law of the place of incorporation & law of the
place of performance (the act or contract must be
authorized by BOTH laws)
Lex fori
Law of the place of incorporation provided that the
public policy of the forum is not militated against
If not fixed by the law creating or recognizing the
corporation or by any other provision – the
domicile is where it is legal representation is
established or where it exercises its principal
functions (Article. 15)
Principal receiver is appointed by the courts of the
state of incorporation; ancillary receivers, by the
courts of any state where the corporation has
assets (authority is CO-EXTENSIVE) w/ the
authority of the appointing court
 3. Law of the place of exploitation (exploitation centre or siege d’ exploitation)
Partnerships
The existence or non-existence of
legal personality of the firm; the
capacity to contract; liability of the firm
& the partners to 3rd persons
Creation of branches in the RP;
validity & effect of the branches’
commercial transaction; & the
jurisdiction of the court
Dissolution, winding up, & termination
of branches in the RP
Domicile
Receivers
Foundations (combination of capital
independent of individuals, usually not
for profit)
The personal law of the partnership, i.e., the law
of the place where it was created (Article 15 of the
Code of Commerce) (Subject to the exceptions
given above as in the case of corps.)
RP law (law of the place where branches were
created) (Article 15, Code of Commerce)
RP law (Article 15, Code of Commerce)
If not fixed by the law creating or recognizing the
partnership or by any other provision – the
domicile is where it is legal representation is
established or where it exercises its principal
functions (Article. 15)
RP law insofar as the assets in the RP are
concerned can be exercised as such only in the
RP
Personal law of the foundation (place of principal
center of administration)