penalties. Nevertheless, the Law on the Compensation of Damages adopted on 22 August 2001 provides for tort liability, including vicarious liability on the part of principals for the actions of agents, employers for the actions of employees, parents or guardians for the actions of children, and owners for the actions of pets or other animals under their control. North Korean tort law also recognises capacity as an important factor in determining whether or not someone may be held liable for their own actions. Philippines The Philippines is a mixed law jurisdiction, shaped primarily by Spanish civil law and American common law as codified in the Philippine Civil Code. For the most part, the equivalent of tort law (insofar as it concerns negligence and product liability) in the Philippines is the law of quasi-delict. Article 2176 of the civil code provides that, in the absence of a contractual or quasi-contractual relationship, a person who "by act or omission causes damage to another" by way of fault or negligence is "obliged to pay for the damage done". Article 1174 (which is made applicable by article 2178) provides that an individual is generally exempt from liability if the events giving rise to the damage were unforeseeable or inevitable. The Philippine law of quasi-delict is largely a codification of common law principles and doctrines. For instance, the common law doctrine of comparative negligence is codified in article 2179, providing for compensation to be reduced in proportion with the plaintiff's own fault for the damage they incurred. Similarly, the duty of care established in Donoghue v Stevenson is codified by article 2187 with regard to "manufacturers and processors of foodstuffs, drinks, toilet articles and similar goods", and is extended by article 2189 to provincial and local governments responsible for defective public amenities. Similarly, article 2190 establishes liability for the owners of defective buildings or structures that cause damage. Additionally, case law in the Philippines recognises the common law doctrine of res ipsa loquitur. Outside the law of quasi-delicts, the civil code also codifies other provisions of tort law in Chapter 2 of the Preliminary Title under the heading "Human Relations". This chapter provides that "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" and that "every person who, contrary to law, wilfully or negligently causes