Republic of the Philippines SUPREME COURT Manila
EFREN MORILLO, MARTINO MORILLO, VICTORIA MORILLO, MA. BELEN DAA, MARLA DAA, MARIBETH BARTOLAY, LYDIA GABO, JENNIFER NICOLAS AND MARILYN MALIMBAN, Petitioners,
-versus-
G.R. No. _______________ __________ _____ For: Issuance of the Writ of Amparo
THE PHILIPPINE NATIONAL POLICE, represented by PDG RONALD DELA ROSA, Chief, Philippine National Police , PSSUPT. GUILLERMO LORENZO T. ELEAZAR, QCPD Director , P/SUPT. LITO PATAY, QCPD PS 6 Station Commander , P/SI EMIL S. GARCIA, PO3 ALLAN FORMILLEZA, PO1 JAMES AGGARAO AND PO1 MELCHOR NAVISAGA and/or any of their agents, Respondents. x---------------------------------------x JOINT PETITION FOR THE ISSUANCE OF THE W RIT RIT OF AMPARO
PETITIONERS, through counsel, and unto this Honorable Court, respectfully state:
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PREFATORY STATEMENT
There are two chief kinds of carnage taking place here, these wet Manila nights. There is the “buy-bust” operation, in which the targeted criminal attempts to buy some drugs, only to find that he is dealing with undercover police. He panics and reaches for a weapon, a pistol perhaps or a kind of homemade shotgun. Before he can use it (so the familiar script reads) the police shoot him dead. There have been around two thousand of these buy-bust killings since the war on drugs under President Rodrigo Duterte began at the start of July. The dead are both pushers and users. If you’re a user, Duterte’s wisdom has it, then you’re also a pusher. And even if you aren’t a pusher, the users of the drug in question, “shabu” or crystal meth, very soon forfeit their claims to humanity. They lose their souls. The only thing to do with them is kill them. … An EJK, the second form of carnage, is an extrajudicial killing, and it was outnumbering the buy-bust incident, this December, by roughly two to one. A buy-bust is of its nature attributable. A particular group of policemen takes responsibility for a particular killing on grounds of selfdefense, and though doubt may be cast on their story (which repeats and repeats the same formula) there is no mystery about the people involved. The people the police shoot “in self-defense” are classed as nanlaban, which means “fought” as in “he fought back…” … In a survey by Social Weather Stations, 69 percent of those polled thought the incidence of EJKs was either very or somewhat serious. Only 3 percent thought it not serious at all. As to whether they believed that police were telling the truth that the suspects they killed in buy-bust operations had really resisted arrest, doubters and believers were evenly split, with 28 percent saying the police were definitely or probably telling the truth, and 29 percent saying they were definitely or probably not doing so. Overwhelmingly, however, 88 percent agreed, strongly or somewhat, that since Duterte became president, there has been a decrease in drug problems in their area. And that is the perception that 2
appears to have trumped all others. There’s less of a drug problem. You can walk the streets at night, one is told. And yet the price paid is most striking. Asked how worried they were that they or someone they knew would become the victim of an EJK, 45 percent replied that they were very worried, and a further 33 percent that they were somewhat worried. That is to say, four out of five respondents were worried to a significant degree that they, or a friend of theirs, might end up bound and gagged in the gutter, or shot by a masked man on a passing bike, or woken in the small hours to receive a bullet in the head. Are they right to worry? Statistically, the answer would seem to be no. If you are young, male, and poor, then, yes, you should worry. For Duterte’s war seems very much to be a war against the poor. But the further you move up the social ladder, the less you are likely to be affected. That kind of reasoning, however, rather ignores the pervasive effect of terrorism. The targeted killings have their message for the world of the drug users and dealers. The crazy and seemingly haphazard extrajudicial killings, the corpses suffocated with packing tape and dumped at the side of the road with sadistic jokes on cardboard signs (and one that, when turned over, revealed a smiley face) have a message for everyone: nobody is safe. - James Fenton, Murderous Manila: On the Night Shift Shift (first of two parts), New York Review of Books, February 9, 2017 issue [emphasis supplied] 1
What runs counter to common sense is not the nihilistic principle that “everything is permitted,” which was already contained in the nineteenth century utilitarian conception of common sense. What common sense and “normal people” refuse to believe is that everything is possible. We attempt to understand elements in present or recollected experience that 1Available
at http://www.nybooks.com/articles/2017/02/09/murderous-manila-on-the-nightshift/
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simply surpass our powers of understanding. We attempt to classify as criminal a thing which, as we all feel, no such category was ever intended to cover. What meaning has the concept of murder when we are confronted with the production of corpses? corpses ? - Hannah Arendt, The Origins of Totalitarianism , 441 (1962 ed) [emphasis supplied].
Here, people would not be able to imagine such phantasmagorias, even in their dreams. A surrealism from slapdash absurdities and poverty’s impure colors, the incongruities between people and things, things and people – here they have absolutely no idea what this means. - Kazimierz Brandys, A Brandys, A Warsaw Diary, Diary , 1978-1981
The official version of the inhuman horrors assailed in this Petition reads like the writers have seen too many old Tagalog action Tagalog action movies shown on television on sleepy Sunday afternoons that they unconsciously wove into their script a familiar but all-too wooden if not improbable dialogue from bygone days of Filipino cinema. “HINDI KAMI PAPAHULI NG BUHAY!,” the victims allegedly shouted upon seeing the approaching lawmen, before they unleashed a hail of bullets on the police officers. From thereon, the official narrative could not move beyond sheer incongruity. The official police reports claim it was a chance encounter during a tokhang operation, tokhang operation, but in interviews with media, they said they caught the victims holding a drug session; in thus making conflicting accounts of their deadly action, they effectively rendered irrelevant the two categories of carnage the prize-winning American journalist James Fenton came up with in his recent reportage of several episodes of the on-going drug war in the country.2 2 Had
he known about it, Fenton would have been better served by the categories established by the UN Minnesota Protocol, otherwise known as UN Manual on the Effective Prevention and Investigation of Extra-Legal, Arbitrary and Summary Executions (U.N. Doc. E/ST/CSDHA/.12 [1991] ).The Minnesota Protocol deals with the effective investigation and prosecution of extra-
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To begin with, the assailants – Police Senior Inspector EMIL GARCIA Police Officer 3 Allan Formilleza, Police Officer 1 James Aggarao and Police Officer 1 Melchor Navisaga – are members of a police community precinct that has no operational jurisdiction in the area where the killings happened. And in a comical attempt to hide this fact, the police officers fabricated death certificates and police reports for the young men they mercilessly gunned down, to show that the carnage happened in another barangay that properly belonged to their police station’s area of operation. Indeed, it was such a bloody Sunday afternoon – like the killers were running after an approaching deadline – that when the smoke cleared, four young men lay lifeless in gory pools of human blood and bits and pieces of human flesh and bones amid the pained and frightened cries of their loved ones. The dead: Marcelo Daa, Jr., Raffy Gabo, Anthony Comendo , and Jessie Cule. They fit the profile of the usual victims of extralegal killings in the war against drugs – male, young and poor. They were men on the cusp of life, ages ranging from 22 to 36 years old at the time of their brutal demise. They lived with their families in squalor in Payatas, the dumpsite for the whole Metro Manila area. They were garbage collectors and scavengers, barely eking out a living. The houses in this community of scavengers very near the La Mesa Dam are no more than clumps of haphazardly built structures made from an assortment of plastic, wood, and pieces of scrap metal – all salvaged from the trash thrown out of the houses of other people. 3 legal, arbitrary and summary executions. These executions include: (a) political assassinations; (b) deaths resulting from torture or ill-treatment in prison or detention; (c) death resulting from enforced "disappearances"; (d) deaths resulting from the excessive use of force by lawenforcement personnel; (e) executions without due process; and (f) acts of genocide. These categories of killings carried out by the State and persons acting at its behest or acquiescence may be subsumed under the shorthand “extralegal killings” (ELKs). 3 As the well-known Filipino folk singer Gary Granada sang in his iconic composition of the same title: Isang araw ako'y nadalaw sa bahay tambakan Labinglimang mag-anak ang duo'y nagsiksikan Nagtitiis sa munting barung-barong na sira-sira Habang doon sa isang mansyon halos walang nakatira Sa init ng tabla't karton sila doo'y nakakulong Sa lilim ng yerong kalawang at mga sirang gulong Pinagtagpi-tagping basurang pinatungan ng bato Hindi ko maintindihan bakit ang tawag sa ganito
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Humble the home may be, but it is sacred. As an American scholar would put it: “The maxim that a ‘man's house is his castle’ is one of the oldest and most deeply rooted principles in Anglo-American jurisprudence.'It reflects an egalitarian spirit that embraces all levels of society down to the ‘poorest man’ living ‘in his cottage.’ The maxim also forms part of the fabric of the Fourth Amendment to the Constitution, which protects people, their homes, and their property against unreasonable searches and seizures by the government.” 4 This sacrosanct space was shockingly violated by the policemen-murderers. The victims were in the premises of the home, spending a quiet Sunday afternoon on games and leisure, when the policemen descended upon them without warning, rounded them up while laughing and joking among themselves and pretending to look for pokemon pokemon monsters in the house. Then the policemen shot the victims one by one, execution-style. And when it was all over, as if nothing happened, the lawmen sat near the broken bodies of the salvaged salvaged victims and helped themselves with food and drinks from a sari-sari store sari-sari store owned by the Ay bahay Sinulat ko ang nakita ng aking mga mata Ang kanilang kalagayan ginawan ko ng kanta Iginuhit at isinalarawan ang naramdaman At sinangguni ko sa mga taong marami ang alam Isang bantog na senador ang unang nilapitan ko At dalubhasang propesor ng malaking kolehiyo Ang pinagpala sa mundo, ang dyaryo at ang pulpito Lahat sila'y nagkasundo na ang tawag sa ganito Ay bahay Maghapo't magdamag silang kakayod, kakahig Pagdaka'y tutukang nakaupo lang sa sahig Sa papag na gutay-gutay, pipiliting hihimlay Di hamak na mainam pa ang pahingahan ng mga patay Baka naman isang araw kayo doon ay maligaw Mahipo n'yo at marinig at maamoy at matanaw Hindi ako nangungutya, kayo na rin ang magpasya Sa palagay ninyo kaya, ito sa mata ng Maylikha Ay bahay 4 Jonathan L. Hafetz, A Man’s H ome is His H is Castle?: Castle ?: Reflections Reflect ions on the t he Home, Home , the Family, Fam ily, and P rivacy the Nineteenth and Early Tw entieth Centuries, 8 Wm. & Mary J. Women & L. 175 (2002), available at http://scholarship.law.wm.edu/wmjowl/vol8/iss2/2 .
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family of one of the victims – another surreal, if phantasmagoric thread to this horrendous tale of police brutality. The murderers-in-uniform say the five young men are illegal drug suspects who deserved the death they died, a claim belied by members of the community who witnessed what happened. The perpetrators cite OPLAN TOKHANG, the government’s campaign against drugs, as justification for the killing and maiming of illegal drug suspects. This policy of murder is furthered by members of the SWAT and SOCO who tampered with the crime scene and attempted to erase evidence implicating the principals of the crime. And perhaps, that this Petition is being filed at all before this Honorable Court is only because a fifth victim, a 28-year old vegetable vendor named Efren Morillo, put up such a fight against death that he somehow improbably escaped its cold fangs, and mustered the courage to speak about what happened to him and his friends on August 21, 2016 at Group 9, Area B, Payatas, Quezon City. But the perpetrators of the gruesome crimes want to silence Morillo and his family, the families of his slain friends, and the entire community where the killings took place, by carrying out a continuing campaign of harassment and intimidation against them. Five months after the killings, the policemen involved continue to sow terror at Group 9, Area B, Payatas, Quezon City, to intimidate and harass into a paralyzed silence an entire community that had witnessed their crime. Composed mainly of informal workers, garbage collectors and scavengers, the powerless and povertystricken community is vulnerable to fear and pressure coming from men armed with guns and given the mantle of protection by no less than the government in their rampage in the name of the war on drugs. And this carnage is just one incident of a continuing drug war that – barely seven months after it was launched – has already claimed the lives of more than 7,000 persons. 5 Alas, the Jewish philosopher Hannah Arendt may yet be proven right once again, that as the dehumanized bodies slaughtered in the drug war pile up, everything is now possible. possible. 5
Phelim Kine, Deadly Milestone in Philippines’ Abusive ‘Drug War’: 7,000 Filipinos Killed Since July Shows Rule of Law Collapse, Human Rights Watch D ispatch, July 24, 2017, available at https://www.hrw.org/news/2017/01/24/deadly-mil https://www.hrw.org/ne ws/2017/01/24/deadly-milestone-philippinesestone-philippines-abusive-drug-war abusive-drug-war .
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This Petition for the issuance of the Writ of Amparo is the Petitioners and aggrieved parties’ cry for help and protection against further violation of their constitutional and human rights to life, liberty and security.
I.
PARTIES
A. PETITIONERS 1) Petitioner EFREN C. MORILLO is Filipino, 28 years old, and a resident of San Isidro, Montalban, Rizal. 2) Petitioner MARTINO MORILLO is Filipino, of legal age, a resident of San Isidro, Montalban, Rizal, and the father of Petitioner Efren Morillo. 3) Petitioner VICTORIA MORILLO is Filipino, of legal age, a resident of San Isidro, Montalban, Rizal, and the mother of Petitioner Efren Morillo. 4) Petitioner MA. BELEN DAA is Filipino, of legal age, a resident of Area B, Group 9, Bgy. Payatas, Quezon City, and the mother of deceased victim Marcelo Daa, Jr. 5) Petitioner MARLA DAA is Filipino, 20 years old, a resident of Area B, Group 9, Bgy. Payatas, Quezon City, and the younger sister of deceased victim Marcelo Daa, Jr. 6) Petitioner MARIBETH BARTOLAY is Filipino, 34 years old, a resident of Area B, Group 9, Bgy. Payatas, Quezon City, and the live-in partner of deceased victim Marcelo Daa, Jr. 7) Petitioner LYDIA GABO is Filipino, of legal age, a resident of Area B, Group 7, Sto. Nino, Bgy. Payatas, Quezon City, and the mother of deceased victim Raffy Gabo. 8) Petitioner JENNIFER NICOLAS is Filipino, years old, and a resident of Area B. Group 7, Sto. Nino, Bgy. Payatas, Quezon City, and the sister-in-law of deceased victim Raffy Gabo. 8
9) Petitioner MARILYN MALIMBAN is Filipino, of legal age, a resident of Area B, Group 7, Sto. Nino, Bgy. Payatas, Quezon City, and the live-in partner of deceased victim Jessie Cule. 10) All the Petitioners may be served with court processes and 10)All pleadings through the undersigned counsel, Roque & Butuyan Law Offices, Offices, at Unit 1904 Antel 2000 Corporate Center, 121 Valero St., Salcedo Village, Makati City 1277 Metro Manila.
B. RESPONDENTS
11) Respondent PHILIPPINE NATIONAL POLICE (PNP) is a 11)Respondent government entity, with offices at Camp Crame, Quezon City represented by its head , PDG. RONALD DELA ROSA the Philippine National Police (PNP) Director-General. 12) Respondent PSSUPT. GUILLERMO LORENZO T. 12)Respondent ELEAZAR is of legal age, Filipino, and the District Director of the Quezon City Police District (QCPD), with office address at Camp Karingal, Quezon City. 13) Respondent P/SUPT. LITO PATAY is of legal age, Filipino, 13)Respondent Station Commander of QCPD Police Station 6, and with his office address at QCPD S6, Bgy. Batasan, Quezon City. 14) Respondent P/SI EMIL S. GARCIA is of legal age, Filipino, 14)Respondent a police officer assigned at QCPD Police Station 6, and with office address at QCPD S6, Bgy. Batasan, Quezon City. 15) Respondent PO3 ALLAN FORMILLEZA is of legal age, 15)Respondent Filipino, a police officer assigned at QCPD Police Station 6, and with office address at QCPD S6, Bgy. Batasan, Quezon City. 16) Respondent PO1 JAMES AGGARAO is of legal age, 16)Respondent Filipino, a police officer assigned at QCPD Police Station 6, and with office address at QCPD S6, Bgy. Batasan, Quezon City. 17) Respondent PO1 MELCHOR NAVISAGA is of legal age, 17)Respondent Filipino, a police officer assigned at QCPD Police Station 6, and with office address at QCPD S6, Bgy. Batasan, Quezon City.
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18) Respondents PNP and above-named police officers may be 18)Respondents served with summons, court processes, and pleadings at their addresses as specified above. 19) Respondents PNP and police officers are also served 19)Respondents summons, court processes, and pleadings through the Office of the Solicitor General, with address at Amorsolo Street, Legaspi Village, Makati City, Metro Manila.
II. A. SOURCES FACTS.
OF
STATEMENT OF MATERIAL FACTS MATERIAL
20) The material facts of this case are culled from the sworn affidavits of the following Petitioners which are attached to this Petition as annexes:
a. Efren Morillo (Annex A); b. Maribeth Bartolay (Annex B); c. Rowena Cordero (Annex C); d. Marla Daa (Annex D); e. Maria Belen Daa (Annex E); f. Lydia Gabo (Annex F); g. Marilyn Malimban (Annex G); h. Jennifer Nicolas (ANNEX H);
B. IDENTITY OF THE DECEASED VICTIMS.
21) Almost all the Petitioners are related to deceased-victims of the extralegal kilings perpetuated by Respondent-policemen as named in this Petition. This is with the exception of the lone survivor of the killings, Efren Morillo, and his parents, Petitioners Martino and Victoria Morillo.
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22) The names of the deceased victims of extralegal killings perpetrated by police officers named below are as follows: a. MARCELO DAA, JR. who was Filipino citizen, 31 years old, and a resident of Area B, Group 9, Bgy. Payatas, Quezon City. b. JESSIE CULE who was a Filipino citizen, 20-25 years old, and a resident of Area B, Group 7, Bgy. Payatas, Quezon City. c. RAFFY GABO who was a Filipino citizen, citizen, 23 years old, and a resident of Area B, Group 7, Bgy. Payatas, Quezon City. d. ANTHONY COMENDO who was a Filipino, 36 years old, and a resident of Area B, Group 13, Bgy. Payatas, Quezon City.
C. RELATIONSHIP TO PETITIONERS DECEASED VICTIMS.
OF THE
23) Petitioner EFREN C. MORILLO is the victim of a frustrated murder, and the only survivor of violence committed by Respondent-police officers named in this Petition. 24) Petitioner MARTINO MORILLO is the father of Petitioner Efren Morillo. 25) Petitioner VICTORIA MORILLO is the mother of Petitioner Efren Morillo. 26) Petitioner MA. BELEN DAA is the mother of deceasedvictim Marcelo Daa, Jr. 27) Petitioner MARLA DAA is the younger sister of deceased-victim Marcelo Daa, Jr. 28) Petitioner MARIBETH BARTOLAY was the live-in partner of deceased-victim Marcelo Daa, Jr.
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29) Petitioner LYDIA GABO is the mother of deceasedvictim Raffy Gabo. 30) Petitioner JENNIFER NICOLAS is the sister-in-law of deceased-victim Party Raffy Gabo. 31) Petitioner MARILYN MALIMBAN was the live-in partner of deceased-victim Jessie Cule. D. CHRONOLOGY MATERIAL FACTS.
OF
32) In the afternoon of 21 August 2016, Marcelo Daa, Jr., Raffy Gabo, Anthony Comendo, Jessie Cule and Efren Morillo were in the house of their friend Marcelo Daa, Jr. at the foot of a hill in Bgy. Payatas, Quezon City.6 Morillo was there to collect a debt from Daa, while Daa, Gabo, Comendo and Cule were passing time until their six o’ clock work shift in the evening as garbage collectors. 7 33) A little after one o’ clock in the afternoon, five men and two women in civilian clothes suddenly arrived. They entered the wooden gate and rushed inside the yard, startling Daa, Cule and Morillo, who were playing pool at a pool table in a hut on one side. The men pulled out short firearms and aimed them at the latter. Gripped by fear, Daa, Cule and Morillo put up their hands in surrender. 34) The armed men handcuffed Daa and Morillo. They pulled electric wire from the ceiling of the hut which they used to tie Cule’s hands. They fetched Gabo and Comendo who were at the hammock at the back of the house and also tied their hands with electric wire. Then, they made Daa, Morillo, Cule, Gabo and Comendo sit side by side on a bench. The whole time, the armed men kept accusing the five captives of being involved in illegal drugs. Realizing that the armed men are policemen, Daa, Morillo, Cule, Gabo and Comendo piteously protested their innocence of any crime. 8 35) The armed men entered the house. Cowering inside were Marcelo Daa, Jr.’s live-in partner, Maribeth Bartolay, and also his Aunt Ising. The armed men proceeded to ransack the house, 6 Efren
Morillo, Maribeth Bartolay and Marla Daa corroborate each other on this point in their sworn affidavits attached as ANNEX A, ANNEX B and ANNEX D respectively. 7 Efren Morillo attests to the foregoing in his sworn affidavit attached as ANNEX A. 8 Efren Morillo and Marla Daa attest to Paragraphs 27 and 28 and corroborate each other in their sworn affidavits attached as ANNEX A and ANNEX D respectively.
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rummaging through personal effects and furniture. They took a cellphone and tablet device they found therein. They forced Maribeth to take off her silver necklace and rings and hand these over to them. They also took Marcelo’s collection of metals which the latter painstakingly acquired by scavenging. All the while, the armed men were laughing and mocking Maribeth and Ising: “Ilabas ‘nyo na ‘yung Pokemon! Saan mo ba nilagay ‘yung Pokemon?” 9 36) Outside, Marcelo Daa, Jr. was having an emotional exchange with his younger sister, Marla Daa. Marla was originally inside the house with Maribeth and Ising, but she ran out when the armed men entered. She dashed to her brother who was seated on the bench with the four other captives. She wailed: “Kuya, paano ka na?” na?” Although handcuffed, Marcelo exerted effort to remove the bracelet and ring he was wearing. He handed the bracelet and ring to Marla and said dolefully: “Pumunta ka na sa taas. Kaya ko na ‘to.” Clutching the bracelet and ring and crying, Marla left. 10 37) The armed men emerged from the house carrying a silver foil and a lighter in the shape of a gun. They crowed to Daa, Morillo, Cule, Gabo and Comendo that the items prove the latter’s involvement in illegal drugs. The five captives fervently denied owning the said items. 38) The armed men hustled Daa, Morillo, Cule, Gabo and Comendo to the back of the house. One of the armed men took Daa and Morillo to a makeshift room at the back connected to the house, but whose two walls are missing. One opening leads to a ravine about three meters away. The armed man made Daa sit on a wooden chair and Morillo on the armrest thereof. Then, without warning, he pointed his firearm at Morillo and shot him on the chest. Morillo fell to the ground bleeding, but he did not lose consciousness. Next, the armed man shot Daa, who fell to the ground beside Morillo. Daa was shot a second time on the head as he lay on the ground. He died. 39) Lying beside Daa, Morillo played dead. When the armed man left the room, Morillo crawled out of the opening and onto the edge of the ravine. Pressing one hand over his bleeding chest, he slid down the ravine and landed on the bank of a stream at the bottom thereof. Morillo crossed the stream, trudged up the hill on the other side and walked until he reached the highway. There, providentially, he encountered an acquaintance who was the barker of a jeepney. 9 Maribeth
Bartolay attests to the foregoing in her sworn affidavit attached as ANNEX B. Morillo and Marla Daa attest to Paragraphs 27 and 28 in their sworn affidavits attached as ANNEX A and ANNEX D respectively.
10 Efren
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The latter and the jeepney driver took pity on him and acceded to his request to be brought to a hospital near his home in Montalban, Rizal. 40) Morillo was brought to the Montalban Infirmary in Kasiglahan Village, Rodriguez, Rizal. Unfortunately, there was no doctor on duty at the infirmary so that only first aid could be applied to his chest wound. Moreover, personnel at the infirmary reported his condition of being shot to policemen at the Community Police Action Center (COMPAC) near thereat. 41) Policemen from the COMPAC went to the infirmary to see Morillo. At the latter’s behest, the policemen went to Morillo’s house in San Isidro, Montalban, Rizal to inform his mother, Victoria Morillo about what happened and take her back with them to the infirmary. 42) Morillo recounted to the Montalban policemen the attack against him and his friends earlier that afternoon by policemen in Quezon City. But much to his alarm the Montalban policemen insisted that they turn him over to Quezon City Police Station 6, whose area of responsibility includes Bgy. Payatas, the place of the incident. 43) Morillo pleaded not to be handed over to Station 6, insisting that he did not commit any crime and that in fact he is a victim himself. He was terrified when he realized the likelihood that the policemen who shot him and killed Daa, Cule, Gabo and Comendo are assigned at the said station. Despite his pleas, the Montalban policemen loaded Morillo in an ambulance and brought him to Quezon City Police Station 6 in Bgy. Batasan Hills, Quezon City. The only concession given him was the company of his mother Victoria in the ambulance. 44) Efren Morillo arrived by ambulance at Quezon City Police Station 6 at nine o’ clock in the evening. There he was made to wait indefinitely, the policemen unmindful of his serious wound. Morillo slipped in and out of consciousness as he lay on the ambulance stretcher. At one point, he heard a voice say: “Matibay ang bata na ‘yan. Alas tres pa may tama na, hanggang ngayon buhay pa.” Finally, after many pleas by his mother Victoria, the policemen transported Morillo to East Avenue Medical Center. Morillo was shot at three o’ clock in the afternoon but because the Montalban police
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footdragged in taking him to the hospital, he only received proper medical attention at around midnight, or nine hours later. 11 45) The armed men who turned out to be policemen executed Gabo, Comendo and Cule one by one in cold blood. They made the three kneel on the ground at the back of the house and shot them to death. Jessie Cule was the last of the three to be killed. He begged to be spared, hugging the legs of one of the armed men and sobbing. As he would not let go of his hold, the man shot him on the nape. 12 46) Concerned relatives and neighbors gathered at the top of the hill near the highway as soon as news spread about the presence of armed men in the house of Marcelo Daa, Jr. Hearing gunshots coming from the latter direction, they ran down the hill towards the Daa residence. They were stopped from fully entering the inside of the yard, but not before catching a glimpse of a shocking sight at the back of the house. A relative of the Daas, Rowena Cordero, saw Raffy Gabo and Anthony Comendo sprawled and lifeless on the ground. She also saw Jessie Cule on his knees but his torso bent forward to the ground. Cule was still alive, his chest and shoulders heaving up and down. At this point, one of the armed men stopped Cordero from going in farther. 47) Angrily, Cordero confronted the armed men: ““Bakit ““ Bakit Sir, may warrant ba kayo? Asan ang barangay? Bakit ‘nyo binaril agad, hindi naman sila nanlaban. Paano sila manlalaban wala naman silang baril." The man ignored Cordero’s admonition. One of the women with the armed group, Lea Barcelona, also known as Neneng, whom Cordero was able to identify because she used to live in the neighborhood, told the man blocking Cordero: “Sir, tiyahin 'yan ng isa sa pinatay 'nyo." The man did not deny or object to the statement. Based on these exchanges, Cordero surmised that the armed men are policemen; 48) The armed men pushed Cordero and the other relatives and neighbors out of the compound and closed the wooden gate. However, the latter remained outside the gate and kept vigil there. From outside the gate, they can see the inside of the compound through the wooden slats of the gate and fence. At one point, one of the armed men said: “Sir, may humihinga pa.” The pa.” The man accompanied his statement with a motion of breathing in and out. The armed men then walked toward the back of the house. A few moments later, two 11 Efren
Morillo attests to Paragraphs 31, 32, 33, 34, 35, 36 and 37 in his sworn affidavit attached as ANNEX A. 12 Marilyn Malimban attests to the foregoing in her sworn affidavit attached as ANNEX G, as spontaneously recounted to her by fourteen-year old eyewitness Nonoy.
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gunshots rang out. Sometime later, one of the armed men also exclaimed: “Putang ina! Natakasan pa tayo. Hanapin ‘nyo! Sabagay, hindi na makakaligtas ‘yun, puso ang tama.” 13 49) The armed men stayed several more hours inside the Daa residence. They ate at the pool table area using the family plates and utensils.14 They even had the insolence to solicit from Maribeth Bartolay food and drinks from her sari-sari store. sari-sari store.15 50) Before four o’ clock in the afternoon, about ten (10) men and women in full police and/or SWAT uniform arrived and entered the house. At around five o’ clock, another round of gunshots was fired, the sound coming from the back of the house. At seven o’ clock in the evening, scene of the crime operatives (SOCO) and members of the media arrived. 51) One of the armed men gave a media interview and confirmed that they are in fact policemen assigned to QCPD Police Station 6 in Bgy. Batasan Hills, Quezon City. He introduced himself as Police Senior Inspector EMIL GARCIA and announced that he and PO3 Allan Formilleza, PO1 James Aggarao and PO1 Melchor Navisaga had killed Marcelo Daa, Jr., Raffy Gabo, Anthony Comendo and Jessie Cule in a police operation implementing OPLAN TOKHANG. He claimed that the victims were notorious drug suspects and were also known robbers. Curiously, the police also told the media that they caught the victims during a drug session, even if this fact directly contradicts the narrative of the police report they later filed. Copies of the Police Report, Joint Affidavit of Arrest and the Police Blotter Excerpt of Entry are attached hereto as ANNEXES I and series. Copies of the videos of the news reports are attached hereto in a compact disc as ANNEX N and series. 52) At eight o’ clock in the evening, the dead bodies of Marcelo Daa, Jr., Raffy Gabo, Anthony Comendo and Jessie Cule
13 Rowena
Cordero attests to Paragraphs 39, 40 and 41 in her sworn affidavit attached as ANNEX
C. 14 Maribeth Bartolay and Rowena Cordero corroborate each other on this point in their sworn affidavits attached as ANNEX B and ANNEX C respectively. 15 Maribeth Bartolay attests to the foregoing in her sworn affidavit attached as ANNEX B.
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were carried out of the house and brought to Light Funeral Services in Kamuning, Quezon City.16 Copies of the Death Certificates of the victims are attached hereto as ANNEXES J and series. 53) Efren Morillo survived his gunshot wound and recuperated at the East Avenue Medical Center. However, his fear for his life did not ebb because during the whole ten (10) days that he was confined at the hospital, as policemen from QCPD Police Station 6 kept him captive in his hospital room. Thankfully, officials from the Commission on Human Rights (CHR) later on arrived and rescued him from the said policemen. A copy of Efren Morillo’s medical certificate is attached hereto as ANNEX K. 54) Morillo is now in the custody and under the protection of the CHR. But as a way to reach him, his assailants filed a false charge of Direct Assault Upon Agents of Persons in Authority against him with the Quezon City Metropolitan Trial Court. 17
55) Marilyn Malimban, the live-in partner of one of the victims Jessie Cule, also fears that the policemen who killed Jessie and his friends would come back and harm her. Her fears are grounded on facts because during the wake of Jessie in their residence at Area B, Group 7, Sto. Nino, Bgy. Payatas, some unidentified men arrived. From inside the house, Marilyn heard them ask her landlady: “Sino “ Sino rito ang asawa ng namatay?” namatay?” She went inside her room and stayed there until the men left. 18 56) A few days after the killings, a television reporter of GMA 7, Jay Taruc, and his crew visited the place of the incident in Area B, Group 9, Bgy. Payatas and sought to interview witnesses. However, No one agreed to speak with him or even come near him because unbeknownst to him, the police escort he took with him to the area is PO3 Allan Formilleza, one of the policemen involved in
16 Rowena
Cordero, Marla Daa and Marilyn Malimban attest to Paragraphs 43, 44 and 45 and corroborate each other in their sworn affidavits attached as ANNEX C, ANNEX D and ANNEX G respectively. 17 Efren Morillo attests to the foregoing in his sworn affidavit attached as ANNEX A. 18 Marilyn Malimban attests to the foregoing in her sworn affidavit attached as ANNEX G.
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the killings. All the members of the community were terror-stricken at the sudden appearance of Formilleza that day. 19 57) In the afternoon of 27 October 2016, three policemen involved in the killings – PO3 Allan Formilleza, PO1 James Aggarao and PO1 Melchor Navisaga – again went to the Daa residence in Area B, Group 9, Bgy. Payatas. Marla Daa, the younger sister of one of the victims Marcelo Daa, Jr., was home alone at that time. Brazenly and without asking for permission, Formilleza, Aggarao and Navisaga entered the gate and started taking videos of the whole compound and house. One of them was even carrying an M-16 Armalite rifle. Despite her profound fear, Marla mustered the courage to ask: “Bakit kayo nagvi-video?” The nagvi-video?” The three ignored her. After several minutes, they left.20 58) Again in the afternoon of 22 November 2016, one of the policemen involved in the killing was spotted in the area. The said policeman got out of a vehicle and went to the store near the road. He asked the owner of the store, Nica: “Saan dito may bentahan ng droga?” Recognizing the man as one of the killers, Nica replied: “Wala na nga e, pinagpapatay ‘nyo na.” na.” The policeman did not answer and simply walked away.21 59) After the incident, Petitioners obtained copies of he reports from the police concerning the operation. It is readily apparent that the police fabricated the police reports. In the report filed by the QCPD S6 Station Illegal Drugs Special Operation Task Group to the Quezon City Prosecutors’ Office (for the purpose of filing criminal charges against Efren Morillo) 22 and their Joint Affidavit of Arrest, they claim that the Aggrieved Parties fired at them first. They even allege that the Aggrieved Parties shouted “HINDI KAMI PAPAHULI NG BUHAY!” They also alleged that they found guns and drug paraphernalia in their possession. These are nothing but lies. 60) Another grave anomaly is the reported place of the incident. In all the documents from the Respondents – the Police Report, the Joint Affidavit of Arrest and the Police Blotter Excerpt of
19 Rowena
Cordero attests to the foregoing in her sworn affidavit attached as ANNEX C. Daa attests to the foregoing in her sworn affidavit attached as ANNEX D. 21 Marla Daa and Maria Belen Daa attest to the foregoing in their sworn affidavits attached as ANNEX D and ANNEX E. 22 The police filed a criminal case against Efren Morillo for Direct Assault Against an Agent of a Person in Authority. The case is pending before MeTC Branch 42 of Quezon City. Curiously, they did not file a case for a violation of R.A. No. 9165 9165 even if they alleged that they found drug paraphernalia in the place of the incident. 20 Marla
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Entry, and even in the Death Certificates of the deceased -- the place of incident is Group 9, Brgy. Bagong Silangan, Quezon City. 61) This is false, as the place of incident is the house of Marcelo 61)This Daa, Jr. at Group 9, Area B, Bgy. Payatas, Quezon City. This is not a simple oversight and is actually evidence that the Respondents are fabricating and manipulating evidence. 62) First, Respondents know that the place of incident is in Bgy. 62)First, Payatas and not Bgy. Bagong Silangan. This was not an inadvertence. In their Joint Affidavit of Arrest, they categorically said the following: “THAT, at about 2:00 PM, on the same date, we were dispatched to conduct Oplan Tokhang, house to house visitation to a known drug personalities (sic), particular in the house of certain Marcelo Daa Jr., at Group 9 Area B, Brgy Bagong Silangan, Quezon City.” 63) However, they knew that the house of Marcelo Daa, Jr. is in 63)However, Group 9 Area B, Bgy. Payatas, Quezon City. This is evident from the Police Report, where it was indicated as such. This is the true address, as provided in the Barangay ID of Marcelo Daa, Jr. As policemen detailed in QCPD S6, they should know that these are two different areas altogether. They are not expected to make such a patent error as this. A copy of the Barangay ID of Marcelo Daa, Jr. is attached hereto as ANNEX L. 64) Second,, the motive for the fabrication is obvious. As admitted 64)Second by Respondents Garcia, Formilleza, Aggarao and Navisaga in their Joint Affidavit of Arrest, they are detailed at Bagong Silangan Police Community Precinct 4 (PCP-4). However, Bgy. Payatas is covered by a different Police Community Precinct -- PCP 5. 65) Thus, Respondents had no authority to conduct OPLAN 65)Thus, TOKHANG operations in Bgy. Payatas, where the incident occurred. It is thus quite obvious that they fabricated evidence to make it appear that they had jurisdiction to conduct OPLAN TOKHANG operations where the incident occurred. Otherwise, if it were indeed a legitimate operation, there is no need to lie about the place of the incident. 66) Third,, Respondents merely substituted “Bgy. Payatas” with 66)Third “Bgy. Bagong Silangan” while retaining all other pieces of information about the place of the incident. 19
67) This shows that intercalation was a mere afterthought, and a 67)This poor one at that. There is no place called “Group 9 Area B, Bgy. Bagong Silangan, Quezon City.” Bgy. Bagong Silangan is divided into sitios sitios and puroks, puroks, unlike Bgy. Payatas which is separated into groups and groups and areas. areas. This is due to the huge size discrepancy between the two barangays. 68) The foregoing show how the incident on 21 August 2016 was 68)The not a legitimate police operation that resulted in a shoot-out between suspects and policemen. It was a summary execution that was enabled by OPLAN TOKHANG, and which follows the worn-out narrative that the deceased victims were notorious drug suspects who fought back against the policemen. Nanlaban. Nanlaban. The attempt to cover up the crime and glorify it as a police achievement is achieved through a systematic conspiracy among different units of the same police district, part of which is to silence and frighten possible witnesses and aggrieved parties from speaking up in the name of justice.
III. GROUNDS FOR THE ISSUANCE OF THE W RIT RIT OF AMPARO A. RESPONDENTS P/SI GARCIA, PO3 FORMILLEZA , PO1 AGGARAO AND PO1 NAVISAGA CONTINUE TO THREATEN THE PETITIONERS EVEN AFTER THE INCIDENT .
69) The chilling and gruesome murders of victims Marcelo Daa, Jr., Raffy Gabo, Anthony Comendo and Jessie Cule and the near-fatal wounding of Petitioner Efren Morillo are gross violations of their basic human right to life. 70) Members of the police - namely, Respondents P/SI GARCIA, PO3 Formilleza, PO1 Aggarao and PO1 Navisaga, brazenly admit to the killings of Daa, Gabo Comendo and Cule, and the maiming of Morillo. The swiftness of their attack, their desecration of 20
the home, their ignominy and cruelty to the victims, their callousness and derision toward family, kin, neighbors and community of the latter, and their disrespect for the dead show utmost disregard for human rights. 71) Worse, after the killings, the Respondent police officers involved in the killings repeatedly went back to the scene of the crime, went into the residential houses of some of the petitioners in an obvious attempt to manipulate evidence and to antagonize witnesses. 72) Petitioner Efren Morillo continues to fear for his life. Because he survived the attack of the perpetrators and identified each and every one of them, his life is in grave danger. Moreover, the trumped up charge of Direct Assault Upon Agents of Persons in Authority filed against him is clearly persecution on the part of the perpetrators. In addition, the incident has dealt a serious blow on the financial stability of his family. To pay for his medical bills, Morillo’s parents Martino and Victoria Morillo were forced to sell their house. They have no more income, since Morillo, who was the sole breadwinner of the family, could not resume work because of the danger to his life. Thus, there is a clear and grave threat to his right to life, liberty and security. 73) The other Petitioners suffer the same violation of their right to life, liberty and security. They are terrified for their own lives and the lives of their family members, relatives and loved ones because the perpetrators keep returning to intimidate and harass them into silence. They are violated in their own homes because the perpetrators freely barge in. They could not go to work because they are afraid to leave their children alone in their houses. Their lives are at a standstill. Even the neighbors and members of the larger community are victimized because of the paralyzing fear wrought by the blatant threats of the policemen involved in the killings from the time of the incident to date. 74) With respect to the Daas who reside at Group 9, Area B, Bgy. Payatas, where the incident occurred, the same Respondents Formilleza, Aggarao and Navisaga returned at least twice. 75) As detailed in the affidavits of Marla Daa 23 and Maria Belen Daa,24 the three policemen returned on 27 October 2016. This was two days after the first hearing for the criminal case filed by the 23 ANNEX 24 ANNEX
D. E.
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policemen against Efren Morillo. In the affidavit of Marla Daa, she recalls: “We buried Kuya Nonoy and tried to recover from the violence and trauma of his murder. However, in the afternoon of 27 October 2016, barely two months after the incident, the three policemen who killed my brother and his three friends and shot Efren MorilloAllan Formilleza, James Aggarao and Melchor Navisaga- again appeared at my parents’ house. I felt suffocating fear as I was home alone at that time. Brazenly and without asking for permission, they entered the gate and started taking videos of the whole compound and house. One of them was carrying an armalite. Mustering courage, I asked: “Bakit kayo nagvi-video?” they ignored me. After several minutes, they left.” 25
76) A month later, on 22 November 2016, the same policemen attempted to return. She narrates: “Again in the afternoon of 22 November 2016, one of the policemen who killed my brother Nonoy and his three friends and shot Efren Morillo was spotted in our area. Said policeman got out of a vehicle and approached one of the sari-sari store near the road. He asked the owner of the store, Nica: “Saan dito may bentahan ng droga?” Recognizing the man as one of the killers, Nica dared reply: “Wala na nga e, pinagpapatay ‘nyo na.” The policeman did not answer and simply walked away. Later, Nica narrated to us the foregoing exchange.” 26 77) With respect to the relatives of Raffy Gabo, the funeral wake of the victim was disturbed by the presence of three individuals lurking around their house. Their presence was disturbing enough to rouse the curiosity and agitated reaction of their neighbors. 27
25 Paragraph
13 of ANNEX D. 14 of ANNEX D. 27 Lydia Gabo attests to the foregoing in her sworn affidavit attached as ANNEX F. 26 Paragraph
22
B. QCPD
STATION 6, REPRESENTED BY RESPONDENT P/SUPT. PATAY, TAKE PART IN
THE
CONTINUED
THREAT
THROUGH A CONSPIRACY TO COVER UP THE CRIME .
78) Respondents have exhibited what lengths they can take in order to cover up for their crime and make it appear like a legitimate police operation. They have manipulated official documents and even filed these before the Courts. 28 They even instituted a criminal action against Efren Morillo in order to frighten the victims and their families from testifying or filing any charges against them. 79) Certainly, the attempt to cover up does not start and end with the perpetrators of the crime. The Scene of the Crime Operative (SOCO) Team Leader, PCI Nellson Sta. Maria, is detailed under the QCPD SOCO Division stationed at EDSA/Kamuning, Quezon City 29 The investigator of the case, PO2 Jerome Dollente is detailed at the QCPD CIDU Unit at Camp Karingal, Quezon City. 30 Moreover, the Police Report that was filed before the Quezon City Prosecutor’s Office was signed by Respondent P/SUPT LITO PATAY, QCPD S6 Commander. 31 80) Further, numerous witnesses recall having heard another volley of gunfire when SWAT Officers went to the scene of the crime. This was hours after the incident, and after the bystanders were forced to move away from the place of the incident. This only bolsters the fact that Respondents have conspired to manipulate the evidence in order to afford them impunity and even make it seem like an achievement for the police force. 81) Petitioners fear for their lives, as their knowledge of the facts of the incident belie the claims of Respondents. Their fear thus not only stems from Respondents Garcia, Formilleza, Aggarao and Navisaga, but extends to the entire QCPD. Their knowledge will show how the crime was covered up through a systematic coordination between different units of the QCPD. Thus, there is a 28 The
Police Report, Joint Affidavit of Arrest and Excerpt of Entry were filed as evidence before the MeTC Branch 42 in Criminal Case No. M-QZN-16-09092-CR. 29 ANNEX I-1. 30 ANNEX I-1. 31 ANNEX I-1.
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very reasonable basis to afford the Petitioners protection from the QCPD.
C. THE PHILIPPINE NATIONAL POLICE TAKE PART IN THE CONTINUED THREAT THROUGH ITS OPLAN TOKHANG.
82) The Philippine National Police (PNP), represented by Respondents PNP PDG RONALD DELA ROSA, QCPD District Director PSSUPT GUILLERMO LORENZO T. ELEAZAR and QCPD Police Station 6 Station Commander P/SUPT. LITO PATAY, is a most interested institution in this petition because the perpetrators are members of the PNP and the crimes were committed in the course of a police operation. The policemen involved in the killings are under the direct command of the PNP.
83) At the very least, indirectly, the PNP gives institutional imprimatur to the disregard of the rule of law and the murder of illegal drug suspects. In the incident here involved, members of the SWAT and SOCO are accessories to murder, having obviously staged the crime scene and erasing evidence implicating the principals of the crime. Moreover, the concept of operations of PROJECT TOKHANG as discussed in Command Memorandum Circular No. 16-2016 which “involves the conduct of house to house visitations to persuade suspected illegal drug personalities to stop their illegal drug activities” is a direct violation of the right to liberty and security, and under the constitutional framework, the rights of the accused and the right against unreasonable searches and seizures. In addition, the incredible pressure on police officials to perform above par in the implementation of PROJECT TOKHANG on pain of being relieved as per Command Memorandum Circular No. 16-2016 drives them to ignore protocol and breeds in them contempt of the law. A copy of Command Memorandum Circular No. 16-2016 is attached hereto as ANNEX M. 84) Assuming arguendo that arguendo that the deceased victims were illegal drug personalities, the police authorities should have followed the rule of law by charging them and causing the issuance of arrest and search warrants against them. Instead, they were summarily 24
executed and were lumped together with other victims who allegedly fought back, or “nanlaban.” “nanlaban.” 85) There is thus a very serious threat to the life, liberty, and security of the Petitioners, as well as the entire community of Area B, Bgy. Payatas, Quezon City. Their rights to life, liberty, and security are violated or threatened with violation by an unlawful act or omission of public officials or private individuals who are herein Respondents.
PRAYER W HEREFORE HEREFORE , PREMISES considered, Petitioners respectfully pray that the Honorable Court:
(a) Issue a Temporary Protection Order under Section 14(a) of the Rule on the Writ of Amparo of Amparo against against herein Respondents and any of their agents, directing them to refrain from issuing or carrying out any threat to the life, liberty and security of the Petitioners, including but not limited to: i)
A prohibition against entering within a radius of five kilometers of the residence and work addresses of the Petitioners;
ii)
A Temporary Restraining Order on the implementation of OPLAN TOKHANG in Area B, Bgy. Payatas, as well as all areas under the jurisdiction of QCPD S6;
(b) In the interim, cause the issuance of a Production Order under Section 14(c) of the Rule on the Writ of of Amparo against herein Respondents, directing them to produce and permit the inspection and copying or photographing of intelligence and surveillance reports, police blotters, coordination, video and all other official and unofficial documents and material pertaining to the police operations conducted on 21 August 2016 against the Aggrieved Parties in relation to their being suspected drug personalities under OPLAN TOKHANG, and to other operations or activities subsequent to such incident in relation to herein Petitioners Parties.
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(c) After due hearing, to issue the privilege of the Writ of Amparo to protect the Petitioners/Aggrieved Parties from any further violation of their rights;
Petitioners pray for other just and equitable relief. Respectfully submitted, Makati City for Manila. January 26, 2017.
By the counsel for Petitioners: ROQUE & BUTUYAN LAW OFFICES LAW OFFICES UNIT 1904 ANTEL CORPORATE CENTER 121 Valero Street, Salcedo Village Makati City 1227 Email: [email protected] Tel. Nos. 887-4445/887-3894 Fax No: 887-3893 26
By:
JOEL RUIZ BUTUYAN Roll No. 36911 PTR No. 5916291 | Jan. 9, 2017 | Makati IBP No. 01742 | Lifetime MCLE Compliance No. V-0013082 | Jan. 12, 2016
ROGER R. RAYEL Roll No. 44106 PTR No. 3804125/ Jan. 4, 2017– Quezon City IBP No. 02159 / Lifetime MCLE Compliance No. V-0013140 | Jan. 12, 2016
ROMEL REGALADO BAGARES PTR No. 5916298| Jan. 9, 2017 | Makati IBP No. 1060904| Jan. 10, 2017| So. Cotabato MCLE Compliance No. V-0022679 | June 29, 2016
GILBERT TERUEL ANDRES Roll No. 56911 PTR No. 3176091/ ?/ Makati City IBP No. 877499/Jan. 3, 2012/ Negros Occidental MCLE Compliance No.III-0013698, April 22, 2010
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GEEPEE A. GONZALES Roll No. 59686 PTR No. 5916299| Jan. 9, 2017 | Makati IBP No. 1060903| Jan. 10, 2017| Oriental Mindoro. MCLE Compliance No. V-0013167| Jan. 12, 2016
ETHEL C. AVISADO Roll No. 56254 PTR No. 5916293 | Jan. 9, 2017 | Makati IBP No. 1060902| Jan. 10, 2017| Davao City MCLE Compliance No. V-0022681| June 29, 2016
ZHARMAI C. GARCIA Roll No. 62891 PTR No. 5916297 | Jan. 9, 2017| Makati IBP No. 013345 | Lifetime | RSM MCLE Compliance No. V-0013105| Jan. 12, 2016
CRISTINA I. ANTONIO Roll No. 64154 PTR No. 7115606 / Jan. 6, 2017 / Cagayan IBP No. 1008162 / Lifetime / Cagayan MCLE Compliance: N/A (Admitted to the Philippine Bar in 2015)
GIL ANTHONY E. AQUINO Roll No. 65698 PTR No. 5916294 / Jan. 9, 2017 / Makati IBP No. 014871 / Lifetime/ Makati MCLE Compliance: N/A (Admitted to the Philippine Bar in 2016)
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COPY FURNISHED:
RESPONDENT PDG RONALD DELA ROSA, Camp Crame, Quezon City RESPONDENT PSSUPT GUILLERMO LORENZO T. ELEAZAR , Camp Karingal, Quezon City RESPONDENT P/SUPT. LITO PATAY , QCPD S6, Bgy. Batasan, Quezon City RESPONDENT P/SI EMIL S. GARCIA , QCPD S6, Bgy. Batasan, Quezon City RESPONDENT PO3 ALLAN FORMILLEZA, QCPD S6, Bgy. Batasan, Quezon City RESPONDENT PO1 JAMES AGGARAO , QCPD S6, Bgy. Batasan, Quezon City RESPONDENT, PO1 MELCHOR NAVISAGA, QCPD S6, Bgy. Batasan, Quezon City OFFICE OF THE SOLICITOR GENERAL 134 Amorsolo Street, Legaspi Village, Makati City, 1229
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Explanation
This Petition is being served to the parties by registered mail because of time, personnel and distance constraints, pursuant to the Revised Rules of Procedure.
GIL ANTHONY E. AQUINO
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