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Published by ACODECO, 2017-06-30 15:00:41

Bulletin No. 11 - Free Competition

Bulletin No. 11 - Free Competition

Keywords: acodeco,competition

Edición N° 11

JUNE, 2017

Seminar Workshop on Experiences of SUTEL on Issues
of Access to Essential Telecommunications Infrastructure

OF OUR CONTRIBUTORS PAG. 2 PAG.4 PRESENT
PAG. 17
-Seminar Workshop on Experiences -Airlines Merger
of SUTEL on Issues of Access to
Essential Telecommunications IN NUMBERS
Infrastructure -Promoting Competition,
Savings Routes
PROJECTS

-Leniency Program in Panama PAG. 3

DEFENDING YOUR FREEDOM TO COMPETE

Seminar Workshop on Experiences OF OUR CONTRIBUTORS
of SUTEL on Issues of Access to
Essential Telecommunications The types of problems of access to
Infrastructure condominiums detected in Costa Rica were
presented: business condominiums and
By: Jovany Morales residential condominiums.

Head of the Department of Analysis At the corporate level: Collection of tolls for
and Market Studies the use of internal infrastructure or internal
networks, exclusivity agreements, transfer of
With the objective of equipping the infrastructure necessary for the deployment
of a network to a specific operator,
Ecollaborators of the National Competition construction of networks inadequate for the
Authority (DNLC, acronym in Spanish) entry of more than one operator. At the
residential level: Negative access by the joint
with the necessary tools to carry out their owners, requirement of operators that in
order to have access to a condominium, the
functions in defense of competition in the infrastructure necessary for the deployment
of network, must be assigned to them by the
telecommunications sector, on Thursday, Condominium and a monetary charge by the
operators to enter condominiums.
25 and Friday, 26 May 2017, the workshop
The methodology of the study "Access to
seminars of the Superintendence of common telecommunications infrastructure
in horizontal and vertical condominiums,
Telecommunications (SUTEL) was held at apartment buildings, closed residential
buildings and all those residential buildings
ACODECO headquarters, regarding the with common facilities necessary for the
provision of telecommunications services
regulation and defense of competition, available to end users" was described.

with an emphasis on access to essential The exchange of experience and common
concerns of SUTEL and ACODECO
telecommunication infrastructure, translates into a greater understanding and
analytical capacity in the areas of
presented by Deryhan Muñoz Barquero, competence related to access to essential
telecommunications infrastructure.
economist of the General Direction of

Markets of SUTEL, (acronym in Spanish)

Costa Rica.

The workshop developed how SUTEL has
analyzed emblematic cases of restrictions
to the competition. We analyzed regulation
of access to internal telecommunications
networks, access to essential infrastructure
2 in condominiums from the approach of ex
ante regulation.

3

PROJECTS

Leniency Program in Panama

As part of our competition advocacy
functions and to further publicize our
leniency program, The National Directorate
of Free Competition develops a Flowchart
of Dispensing Benefits or Reduction of
Sanctions Program. This document will
contain a brief description of the program,
as well as a flow chart in which all the
requirements, benefits and other details that
the economic agent must know when
applying to it will be announced.

The purpose is to provide graphically,
through social networks, economic agents
interested in availing the benefits of the
program.

PRESENT Conceptually, the competitive analysis
of air agreements is similar to the one
Airlines Merger that is done to evaluate a merger
bearing in mind some differences,
Compañía Panameña de Aviación, mergers transform different economic
S.A. and United Airlines, Inc., agents into one, which makes the
notified and requested a formal decisions that are taken respond to a
prior verification formal to obtain common objective, instead,
the favorable concept of agreements between airlines, only
ACODECO for the agreement cover certain aspects of commercial
called "Second Alliance Agreement activity, which means that it is
Modified and Reformed by and assumed that only the activities of the
between United Airlines, Inc. and agreement will be taken
Compañía Panameña de Aviación, jointly and the rest of the decisions will
S.A. dated May 31, 2016". This continue to be taken individually.
operation highlights, among other
things, that COPA and UNITED The guide for the control of economic
wish to increase the flow of concentrations, in which the general
passenger air traffic in aircraft guidelines to analyze this type of
operated by both carriers and operations are established, establishes
increase the quantity and quality of that conceptually the competition
the air service available to the analysis of an alliance agreement is
public. similar in nature to that of a merger,
4 which gives the transaction subject to
verification is analyzed as a merger.

5

PRESENT

After the competition analysis of metasearchers, is not identified in a
according to the guide for the control of rational way, the possibility that such
concentrations, it is concluded that the concentration, will lead to the
Second Covenant Agreement between agreement being able to create
COPA and UNITED, does not affect substantial power in the relevant
competition in the relevant market. market, to lift barriers to entry or to
Only a significant change in the market create favorable conditions for the
structure on the route from Panama conduct of monopolistic practices in
City to New York City is identified, the market, which is why it is granted a
where the HHI and ID indexes increase favorable concept to the Second
in value, indicating an increase in Alliance Agreement Modified and
market concentration, however, the Reformulated by and between United
absence of barriers to entry (which are Airlines, Inc. and Compañía Panameña
insurmountable), Panama's different de Aviación, S.A.
bilateral and multilateral air transport
agreements, which allow airlines
interested in entering the market can do
so without major problems, the
existence of low cost airlines, the
possibility of using alternate routes
(flights with scale), the existence of

PRESENT

Backpack Case

Since January 25 of this year, ACODECO Culminating the phase of practice of
has attended the ordinary evidentiary evidence, the allegations of conclusion
proceedings, within the judicial process were presented as provided by Law 45 of
for possible absolute monopolistic October 31, 2007, currently awaiting
practices in the purchase and distribution judgment by the court.
of backpacks to various educational
centers of the country, public events
conducted by the National Assistance
Program (PAN, acronym in Spanish).

In the process, ACODECO presented
documentary evidence, and adduced the
practice of test reports and expert
evidence, proceedings that extended until
last May.

6

PRESENT 7

Regional Seminar In Session II, "Integration Mechanisms for
Latin America and the Caribbean and
ACODECO participated in the Regional Relations with Korea", it was indicated that
Seminar "Analysis of economic, trade and the Framework Agreement of the Pacific
cooperation relations of Latin America and Alliance promotes the defense of democracy
the Caribbean with the Republic of Korea" and free trade given the position of South
on May 9 and 10, 2007, in the city of Lima, Korea as 7th largest export economic power
Republic of Peru. Organized by the Latin in the world. The areas are oriented towards
American and Caribbean Economic science, technology, innovation, trade
System (SELA), the Ministry of Foreign facilitation, among others. Regarding the
Affairs of Peru and the University of the Andean Community, the trade balance with
Pacific, whose objective was to analyze South Korea is negative, however, there are
and promote the strengthening of possibilities of exporting non-traditional
economic and commercial relations, in products.
order to carry out diagnoses of the
commercial relationship (Export - import), In Session III, "Importance of Cooperation
build on public policy experiences and in Economic Relations between Latin
explore forms of mutual trade - oriented America and the Caribbean with Korea",
cooperation and investment. South Korea has understood that Latin
American countries need assistance in areas
In Session I, entitled "Analysis of such as Education, Technology, Health,
Economic, Trade and Cooperation among others. South Korea has cooperation
Relations of Latin America and the institutions, including the Korea
Caribbean with South Korea," emphasis International Cooperation Agency
was placed on South-South international (KOICA). The Office of the Embassy of
cooperation. Korea (KOTRA) based in Peru has
In Peru, with Korean technology, training Colombia, Bolivia, Peru and Paraguay in
airplanes are manufactured, nowadays areas such as transport, industrial
60% of the pieces are manufactured in development, health, government, rural
Peru. development, environment, energy, climate
. change and infrastructure, among others.

PRESENT The main objective is the processing of heavy
crude oil extracted from the Orinoco oil belt.
It was also highlighted that in Central Among the conclusions of the forum is that
America they have security programs. In the Latin American industry has differences
the educational area was the example of with South Korea in science, technology and
students from the University of the Pacific innovation. Information sources for the
(Peru) who have spent part of their career success of market penetration are important.
in educational centers in South Korea. Some of the lessons to learn are promoting
innovation, patent registration and long-term
In Session IV, "National and Business strategic planning stand out. Strategic areas
Perspectives of Trade, Investment and should be identified for insertion in the Asian
Cooperation between Latin America and market, especially in South Korea. It is
the Caribbean with Korea", a video of the estimated that in order to reach new markets,
construction of a Petrochemical Complex, it is not only necessary to have an FTA, it is
located in the Bolivarian Republic of necessary to educate, diversify exports,
Venezuela, was presented by the Company participate in aggregate value chains and
Hyundai. regionally obtain in the FTAs the so-called
accumulation of origin (which consists of the
raw material of A country in the region can be
considered and treated as being of national
origin).

8

PRACETSUEANLTIDAD 9

Merger After analyzing the product market
DEL MONTE - BONLAC (substitutability) and the geographic
market, it was possible to determine the
existence of two relevant markets: the
market for juices, nectars and
refreshments, and the market for tea
drinks, both within the geographical scope
of the Republic of Panama.

On December 20, 2016, forensic firm Regarding the structural conditions of the
relevant markets, we can mention that
MORGAN & MORGAN, acting on behalf according to the CR4 index, both markets
maintained a high level of concentration
of DMPTY, S.A., a company belonging to before the merger, which increased after
the operation, and in the case of the ID
the economic group that owns DEL index, it was found that both markets were
concentrated before and after the merger.
MONTE DE PANAMÁ, S.A. (DEL
The Guide for the Control of Economics
MONTE), filed a formal verification prior Mergers adopted by ACODECO indicates
that when the R & D has a value greater
to the merger from which it acquires from than 0.25 (regardless of whether it has
increased or decreased) the merger
EMPRESA PANAMEÑA DE assessment with respect to relevant

ALIMENTOS, SA (seller), 100% of the

common and outstanding shares of

SOCIEDAD DE ALIMENTOS DE

PRIMERA, S.A. (BONLAC), in the

Republic of Panama.

PRESENT In the same way, it was possible to verify
that the merger did not generate conditions
markets requires completing the following that could favor the accomplishment of
sections of the methodology, so that the collusive practices.
barriers of entry and conditions of rivalry
in these markets were evaluated.

By analyzing possible entry barriers, it was ACODECO issued a concept regarding the
possible to verify that both markets were merger, being decided to conditionally
open to potential competitors and that grant a favorable concept, subject to the
entry barriers were not raised as a result of economic agents involved in the merger to
the merger; whereas, in view of the modify the Non-Competition clause, in its
conditions of rivalry, it was possible to temporal scope, establishing it in a
verify the existence of an effective rivalry maximum term of three (3) years.
between the economic agent resulting from It should be noted that the economic agents
the merger and the other economic agents involved had signed a share purchase
participating in the relevant markets, so agreement on October 31, 2016, agreeing
that the probability of the individual to a Non-Competition clause set for a
exercise or collective bargaining power of 10-years term.
the two economic agents on both markets,
was unlikely.

10

11

PRESENT For the analysis of the consultation, in

Feasibility Consultation on addition to the criteria that ACODECO
"Non-binding Table" of Fees
has on the subject, the report on the Free
The Association of Certified Public
Accountants of Panama (ACONTAP, Practice of Professions presented in 1992
acronym in Spanish), presented a Feasibility
Consultation, whose consultation consisted by the Competition Tribunal of Spain was
in knowing if the establishment and
disclosure of a "non-binding" fee table used; The criterion issued by the United
constitutes or not a Monopolistic Practice
that violates the rules of free competition and Kingdom Office of Fair Trade, in a case
consumer protection.
involving tariffs issued by the Royal
In summary, the consultation details that
according to article 45 of the code of ethics Institute of British Architects; The criteria
(Decree 26 of May 17, 1984), public
accountants must take into account the value set out by the OECD (Organization for
of the service offered to the client, the charges
for that service that are usually made by his Economic Co-operation and
professional colleagues and other related
considerations. " Development) in 2008 through the

Therefore, ACONTAP considers that it’s Competition Committee on
necessary to prepare and disclose a
"non-binding table" of fees for accountants Pro-Competitive and Anti-Competitive
associated with ACONTAP, which will be
made taking into account the fees made by its Aspects; The explanatory memorandum
associates in the last 3 years in a set of
services. of Law 7/1997, of April 14, on

liberalizing measures in matters of land

and professional associations (Spain);

The Omnibus Law in 2009 (amending

various laws to adapt to the Law on free

access to service activities and its

exercise) and case CCS / 400/001/09

(Singapore Medical Association - Tariff

Guidelines), were also used.

PRESENT Consequently, ACODECO denied the
favorable concept to the consultation
ACODECO explained that when presented by the Association of Certified
competitive economic agents in a market are Public Accountants of Panama.
able to predict the prices of their rivals with Subsequently, ACONTAP, filed a
a reasonable degree of certainty, a focal reconsideration brief on May 30th, in
point is created for market prices to accordance with the provisions of article
converge, regardless of the individual costs 10 of executive decree 8-A of January
of competitors and Therefore, the creation of 22, 2009, in which the criteria adopted in
a "non-binding table" of fees for accountants the appealed decision was maintained.
associated, ACODECO explained that when
competitive economic agents in a market are
able to predict the prices of their rivals with
a reasonable degree of certainty, a focal
point is created for market prices to
converge, regardless of the individual costs
of competitors and that therefore the
development of a "non-binding table" of
fees for accountants associated and not
associated with ACONTAP, constitutes a
high risk that its function is not merely
orientative and ends up limiting the
competition between members and
non-members, which can be considered an
absolute monopolistic practice, and sued by
ACODECO before the specialized courts of
commerce.

12

PRESENT 13

Digital Markets Market shares should be complemented with
other indicators such as: investigating in
On May 18 and 19, ACODECO participated search engines like Google for example,
in the workshop on issues of competition how many clicks are made on the site. One
and consumer protection in digital markets, thing would be the time that a webpage is
organized by Uruguay’s Commission for open, and another thing would be the
Promotion and Defense of Competition interaction with it, the time variable may not
(COMPAL, Acronym in Spanish). be the best indicator of use, since the user
may have left the page open and not
One of the topics addressed in the workshop necessarily be interacting with the same.
was to whether the traditional models for the
analysis of markets are still valid in digital Another aspect developed in the workshop
markets, and the conclusion is that the was related to competition issues in digital
analysis is a little more complex and is markets, where it is concluded that in the
required deepening. current times, the importance of data is
growing every day, generating new
To define the relevant market, it is necessary opportunities, as well as challenges for
to know the vision of the economic agents, consumers, economic agents and
as they expect the market to behave in the competition authorities.
short and medium term, also bear in mind
that the consumer of a platform can use
several platforms at the same time
(multi-holding).

PRESENT Another aspect discussed in the workshop
was collaborative economies, where it was
In the case of mergers in digital markets, for raised, among other things, that this is a
example, when evaluating in the light of transverse phenomenon of global scope with
competition law, data aspects must be taken a digital and innovative character that
into account; First if these data have come increases competition and encourages more
into play as a competitive advantage and efficient sector regulation as horizontal. The
second in the context of their privacy. experience is indicating that the society is
demanding a service and this by some
Regarding network analysis, it is not possi- regulation is eliminated, the society itself
ble to ignore elements which makes consu- looks for the mechanisms, mainly for the
mers go to networks of few users, keeping in support of the social networks (digital
mind that there are markets where consu- markets) to supply it, reason why, the
mers deal directly with money, like eBay for subject today should not be to eliminate the
example, and markets where it is not directly collaborative services, but to look for the
traded in money, such as Google or Face- mechanisms to regulate them in order to
book, where payment for use is given in coexist in harmony with the traditional
information data, which is used to generate systems.
income and the sustainability of the
platform.

14

15

PRESENT

Participation in the Annual

Conference of the International

Competition Network restraints, cartel research tools, challenges of

collaborative economies and unilateral

conduct, corruption and public tenders,

Advocacy of competition to state entities,

market studies, guides and notification

thresholds of mergers, aspects relevant to the

effectiveness of agencies in the application

In the City of Porto, Republic of Portugal, of competition laws, among others.

from May 10 to 12, 2017, Mr. Oscar García Experiences were also exchanged and
Cardoze and Mr. Harmodio A. Cedeño cooperation ties were tightened with
Espinosa representing ACODECO, different competition agencies.
participated in the annual meeting of ICN

which is the network of the most

representative competition agencies in the

world, which also brings together experts

and non-governmental organizations, where

a range of topics on antitrust issues such as:

proactive diffusion strategies for the

deterrence of anticompetitive behavior,

leniency programs and their challenges to

the future, incentives and strategies in their

application, fine and penalties for cartel

members, excessive prices, vertical

PRESENT

Technical Teleconference, about
Panama’s Leniency Program,
with the RECAC

The National Directorate of Free the fine that may be up to one million dollars
Competition, on May 11, participated in a (B/. 1,000,000.00), to the economic agent
technical conference call with homologous who participates in an absolute monopolistic
authorities belonging to the Central practice and be the first to provide
American Network of Competence information to the Competition Authority.
Authorities (RECAC, acronym in Spanish), The teleconference was held with the
exposing the Leniency Program, which purpose of promoting the theme in the
offers to exempt or reduce the payment of region and sharing experiences of this
fundamental tool for the detection of cartels.

16

17

IN NUMBERS

Promoting Competition,
Savings Routes

Since September 2008, in Panama, the To mitigate the situation, the publication of
so-called “cap prices” for liquid fuels for use the "Savings Routes" was established, which
in motor vehicles have been applied. These consists of presenting tables with the
are maximum selling prices established by information of the stations that offer the
the State, for different areas of the national prices below the maximum selling prices
territory, by means of a Resolution issued by and highlighting the minimum price per
the National Energy Secretariat, attached to route. We monitor 9 routes of the capital city
the Presidency of the Republic, valid for 14 and today we have a system of Business
calendar days. Objects that makes an automated
calculation, once we introduce the desired
ACODECO provided some analysis when at variables for the three types of fuels used in
that time the barrel of oil was around USD the domestic market (91 octane gasoline,
150.00 and in the monitoring of 109 service Gasoline of 95 octanes and from the 10 of
stations in Panama City, a behavior was April of this year, ultra-low sulfur diesel (15
observed in which only between 17% and ppm), which contributes to the reduction of
30% of the Stations, depending on the type environmental pollution, since the previous
of fuel, made a full transfer to the selling ones were imported with 5000 ppm and
price when the import parity price fell. In 500ppm. With this application we can place
other words, most stations did not transfer in a timely manner the information on our
the rebates to the national final consumer website for any query from your computer
(when they were given) in the international or mobile device and make the best decision
price. to purchase hydrocarbons.

IN NUMBERS

Regarding the behavior of the local market, RUTA DEL AHORRO - GASOLINA 95 OCTANOS
we can point out that the Terpel chain offers
the lowest prices in the different routes, in PRECIO TOPE = 0.763 FECHA: 29 DE MAYO DE 2017
the modality of self-service; we also find
some white or independent point stations SECTOR PRECIO SECTOR PRECIO
with lower prices; Delta stations offer full TRANSISTMICA
service, but sell the different fuels at the VIA ESPAÑA Y JOSE A. ARANGO 0.76
maximum selling price. DELTA A LADO DE DOIT CENTER 0.76
In relation to the prices to the public, DELTA CHILIBRE 0.76 VDELTA CALLE 95, LAS SABANAS 0.76
comparing them with those of the region, DELTA ENTRADA A LA CABIMA 0.76 IDELTA FRENTE A LA KELVIN DE RIO ABAJO 0.76
Panama presents the lowest prices; This is 0.76
attributable mainly to the established DELTA ENTRADA DE CHIVO-CHIVO 0.76 DELTA FRENTE AL ANTIGUO IJA DEL CASINO
maximum selling price and to the DELTA ENTRADA DE VILLA GRECIA DELTA FRENTE AL CUARTEL DE BOMBERO 0.76
consumption taxes lower than those charged DELTA ENTRADA HOGARES CREA 0.76
by the countries of the area, as the main DELTA ENTRADA MIRAFLORES 0.76 DELTA JUNTO A MATERIALES YUNG CHONG Y XTRA J.D. 0.76
factors that influence this result. The 0.74
regional average was USD 3.36, USD 3.14 DELTA FRENTE A CONCRETOS S.A 0.76 DELTA LATERAL AL TABERNÁCULO DE LA FE 0.76
and USD 2.62 per gallon for premium DELTA FRENTE A LOS ANDES No.2
gasoline, regular gasoline and diesel, DELTA LATERAL AL COLEGIO LA SALLE 0.76 DELTA SAN CRISTOBAL JUAN DIAZ 0.76
respectively; and in Panama they were USD DELTA LATERAL A PLAZA ÁGORA 0.76 INDEPENDIENTE FRENTE A PLAZA CAROLINA 0.76
2.77, USD 2.65 and USD 2.25, DELTA LATERAL ESTADIO JUAN D. AROSEMENA 0.76
correspondingly, according to the survey of INDEPENDIENTE LATERAL A CIUDAD DEPORTIVA, JUAN DÍAZ 0.76
the last week of May 2017. DELTA SAN MIGUELITO 0.76 PUMA FRENTE A LA PISCINA PATRIA 0.75
INDEPENDIENTE AVENIDA NACIONAL ANTES DE CABO VERDE 0.76
We urge you to consult detailed information PUMA AVE. LOS MARTIRES, FRENTE A MI PUEBLITO 0.76 PUMA LATERAL PLAZA CAROLINA
on our website www.acodeco.gob.pa in PUMA ENTRADA DE BETHANIA 0.76
Statistics - Reports and Price Statistics - 0.76 PUMA URBANIZACIÓN SANTA. INÉS/VILLA VENUS 0.76
Fuel. PUMA FRENTE CEMENTERIO PUEBLO NUEVO 0.76 SHELL FRENTE AL HOSPITAL PEDIATRICO 0.76
PUMA LAS CUMBRES 0.76 SHELL LA CRESTA 0.76
PUMA MILLA 8
PUMA PAN DE AZÚCAR TERPEL ENTRADA DE CIUDAD RADIAL 0.76
TERPEL A LADO DE HOGARES CREA 0.76 TEXACO ENTRADA DEL INSTITUTO DE SALUD MENTAL 0.76
0.76
TERPEL ENTRADA DE LA CABIMA 0.76 TEXACO FRENTE A SAN PEDRO NO. 1 0.76
TERPEL FRENTE AL HOSPITAL SANTA FÉ 0.76 TEXACO RIO ABAJO CALLE 18 0.76
TERPEL FRENTE A LOS ANDES No.1 0.76 TEXACO VIA ESPAÑA Y ERNESTO T. LEFEVRE 0.76
TERPEL LATERAL C. COMERCIAL LOS ANDES
TEXACO VIA ESPAÑA Y FERNANDEZ DE CORDOBA 0.76
TERPEL MILLA 8 0.76 DOMINGO DIAZ Y VIA TOCUMEN 0.76
TERPEL QUEBRADA ANCHA 0.75
TEXACO ALCALDE DIAZ 0.76 DDELTA ENTRADA DE VILLA LUCRE 0.75
TEXACO AVE. FRANGIPANI 0.76 ODELTA ENTRADA PARAISO 0.75
TEXACO DIAGONAL AL REST. LUNG FUNG 0.76 DELTA FRENTE AL CENTRO COMERCIAL EL FARO
0.75 DELTA FRENTE A SAN ANTONIO 0.75
TEXACO FRENTE AL HOSPITAL SANTA FÉ 0.76
TEXACO LAS CUMBRECITAS DELTA FRENTE A VILLA LUCRE
TEXACO LATERAL AL MACHETAZO SAN MIGUELITO 0.74 DELTA FRENTE PLAZA CONQUISTADOR 0.76
0.76
VIA CINCUENTENARIO 0.75 DELTA LATERAL A PLAZA TOCUMEN 0.76
DELTA AVE.12 DE OCT.
0.75 PUMA VILLA LUCRE 0.76
DELTA URBANIZACIÓN CHANIS 0.75 TERPEL ENTRADA CERRO VIENT0 Y SAN ANTONIO 0.76
DELTA VIA ESPAÑA 0.76
DELTA VILLA GABRIELA TERPEL FRENTE A AUTODEPOT
PUMA PANAMA VIEJO 0.75 TERPEL FRENTE A LA ENTRADA AL CLUB DE GOLF 0.76
PUMA URBANIZACIÓN CHANIS 0.76
0.75 TERPEL VIA TOCUMEN
0.76
0.76 TEXACO LATERAL VARELA HERMANOS
0.76
0.76 JUSTO AROSEMENA Y CALLE 50 0.76

0.76 JDELTA CALLE 50
UDELTA CALLE 50 Y CALLE 75

0.76 DELTA CALLE 50 Y CALLE URUGUAY

0.76 PUMA FRENTE A MERCEDES BENZ

0.76 TERPEL CALLE 50
TEXACO AVE. JUSTO AROSEMENA FINAL

0.76 PAITILLA Y AVE.BALBOA
PDELTA DETRÁS DEL HOTEL INTERNACIONAL

0.76 DELTA FRENTE AL MERCADO DEL MARISCO

0.76 TEXACO FRENTE AL IJA

0.76 VIA BRASIL

0.76 VACCEL VIA BRASIL, FRENTE A PRICE SMART
0.76 ITEXACO VIA BRASIL

TERPEL FRENTE AL JARDÍN DE PAZ 0.75
TEXACO PANAMA VIEJO 0.76

TUMBA MUERTO 0.76
DELTA FFRENTE A SANTA MARÍA 0.76
DELTA FRENTE A LA CERVECERIA NACIONAL 0.76
DELTA LATERAL A LA UNIVERSIDAD DE PANAMA 0.76
DELTA URBANIZACION DOS MARES 0.76
DELTA VILLA CÁCERES 0.76
INDEPENDIENTE FRENTE A CERVECERÍA 0.76
PUMA A LADO DE LA PARRILLADA BIG TOP 0.76
PUMA FRENTE A PLAZA EDISON 0.76
PUMA FRENTE MC.DONALD DORADO 0.76
PUMA URBANIZACION EL BOSQUE 0.76
PUMA VIA ARGENTINA FINAL 0.75
TERPEL VILLA DE LAS FUENTES 0.76
TEXACO VILLA DE LAS FUENTES
0.76
PUEBLO NUEVO 0.76
DELTA AVE 12 DE OCTUBRE 0.76
DELTA AVE. LA PULIDA 0.75
DELTA VIA FERNANDEZ DE CORDOBA
TERPEL AVE. LA PULIDA

18


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