REPUBLIC OF THE PHILIPPINES SUPREME COURT MANILA En Banc
Kilosbayan Foundation & Bantay Katarungan Foundation, Petitioners,
- versus -
G.R. No. 177721
Executive Secretary Eduardo R. Ermita & Sandiganbayan Justice Gregory S. Ong, Respondents. X---------------------------------------------------------------------------------------------------------X
Judge Florentino V. Floro, Jr., Petitioner-in-Intervention. X---------------------------------------------------------------------------------------------------------X
MANIFESTATION and MOTION TO RECONSIDER [The Denial Resolution dated 5 June, 2007]
With Urgent Motion For Leave To Admit This Appeal
The undersigned Intervenor, Judge FLORENTINO FLORENTINO V. FLORO, JR., respectfully moves to reconsider the denial Resolution dated 5 June, 2007, that he received the said resolution of June 8, 2007 (hence the manifests that timeliness of this appeal) and begs leave to admit the filed Motion to Intervene, the Petition, the Supplement and this pleading. Intervenor respectfully submits
the following GROUNDS to support this pleading and states, that:
JAVIER: SALONGA SUFFERS SUFFERS FROM SELECTIVE AMNESIA AMNESIA I. With all due respect , petitioners / SALONGA did not come to this Court Court of Last Last Resort Resort with clean clean hands. hands. His suit suit is a brazen brazen attack attack upon the persona of the President of the Philippines. He called Mrs. Arroyo / Esperon = Marcos / Ver: “KUNG SI SI MARCOS AY MAY VER, si GMA ay may Esperon”. The Palace REBUFFED Salonga. In the NICOLE case, “ A stab in the back by Arroyo”, Salonga “bran brande ded d Mrs. Mrs. Arro Arroyo yo’s ’s move move as a RA RAW W DEAL DEAL,, a midn midnig ight ht tran transa sact ctio ion n wh whic ich h vict victim imiz ized ed both both Nico Nicole le and and the the coun countr try’ y’ss ”. JUSTICE SYSTEM ”. 1
said “The Congress Congressmen men Exequiel Exequiel Javier Javier and Eduardo Eduardo Veloso Veloso said Senate president must be suffering from selective amnesia, former Senate which has impaired his judgment and ability to recall Philippine they said said in a join jointt stat statem emen ent. t. "Why zero in on the history,” they President, because he [Salonga] is now an opposition ?” Javier said. sympathizer ?” TO BEGIN WITH, this Honorable Court ruled that I am an honorable man. I came here to knock at the 14 doors of your august chambers. I am here as an ordinary taxpayer and more mor e importantly, as your brother in the legal and judicial profession. I write this appeal, not for myself and for the national interest, but for the transcendental transcendental purposes of: a) submitting the TRUTH behind the pleadings of petitioners, and b) enjoining successive, desperate and futile attempts to destroy the very PERSONA of the President of the Republic of the Philippines, by unconstitutional, illegal and baseless acts, forms, publications and actions, culminating in this citizenship case (which aimed not only to fulfill fulfill petitioners’ petitioners’ selfish agenda but truly, truly, their twin suits are the MOST UNKIND and persecutory to the PERSONA and family of an honest magistrate, a GOOD man). What is the TRUTH behind the instant suits of petitioner SALONGA? Every move of the President was / is being microscopically studied, meditated and scrutinized by him, from the time he decided PUBLICLY to OUST Mrs. Arroyo. Intervenor submits the evidence, as he quotes pertinent portions of news news repo report rtss on Salo Salong nga’ a’ss OPEN OPEN atta attack ckss on PRES PRESID IDEN ENTI TIAL AL acts acts,, actuations, reforms, etc.:
A.
Salonga sees Marcos in Arroyo, Ver in Esperon “Salon “Salonga ga said said Ms Arroyo Arroyo’s ’s order order for more more checkp checkpoin oints ts nation nationwid widee was “what [the dictator Ferdinand] Marcos also ordered in the 1969 elections, described by Newsweek (Nov. 24, 1969) and Time (Feb. 16, 1970) as the dirtiest, most violent and most corrupt in modern Filipino history.” “But even more more viol violen entt and and more more corr corrup uptt was was the the Feb. Feb. 7, 1986 1986,, elec electi tion on whic which h culminated in the EDSA I People Power Revolution. We hope that this kind of an election -- violent and fraudulent -- does not happen again, for your sake and for the sake of our suffering people,” he told the President. 2
Salonga said Ms Arroyo should also deal with the purported public distrust of AFP Chief of Staff Gen. Hermogenes Esperon who, he pointed out, had been “linked to the dishonest elections in southern Mindanao.” “We recall a similar figure during the last days of Marcos before EDSA I -Chief of Staff Gen. Fabian Ver . As commander in chief of the AFP, there is a lot you can do to avert a similar upheaval. We respectfully urge you to do so as soon as possible,” Salonga told Ms Arroyo.” [By Norman Norman Bordadora, Bordadora, N. Dizon- Inquirer - Posted date: May 02, 2007 ].
B. ESPERON, ANG BAGONG GENERAL VER - Salonga “Kung si Marcos ay may Ver, si GMA ay may Esperon”. Ito ang pahayag ni dating senador Jovito Salonga na labis na nababahala sa paggamit ng GMA ng military para tumulong diumano sa pulisya para sa eleksyon ito.
Ka Kasab sabay nit nito pinu inuna rin ni Salo Salon nga ang ang pagg paggam amit it ng mili milita tary ry sa pangkakampanya sa Metro amnila laban sa mga balwarte ng oposisyon.” [AJLPP-USA - Chicago Indymedia - Posted date: May 04, 2007 ]. C.
Palace rebuffs Salonga: Esperon, checkpoints to stay
“In effect, Ms Arroyo has rejected the concerns raised in a letter to her on Tuesday by former Senate President Jovito Salonga , who said her decision to call out the military to help stop election violence and killings would make the May 14 polls similar to the violence- and fraud-tainted elections during the Marcos regime. Napakalayo, yo, walang walang kabase-b kabase-baseh asehan an (It’s “ Napakala (It’s too far-fe far-fetch tched, ed, absolu absolutel telyy without without basis),” basis),” Ermita said said of the the comp compar aris ison on.. “The “The cond conduc uctt [of [of the the military] is very different then and now, so our people have nothing to fear because the AFP (Armed Forces of the Philippines) and the police are very conscious of how to play their role during this election period.”
As for Salonga’s comparing of Esperon to Gen. Fabian Ver, the dictator Ferdinand Marcos’ chief of staff, Ermita said: “I was already in [military] service at that time, and I can say that there is no basis to compare the conduct or demeanor of General Esperon … to what has been [said] against General Ver.” He said military commanders like Esperon had “a duty to do.” 3
‘Selective amnesia’ In a reaction to Salonga’s opinion comparing Ms Arroyo to the late dictator Ferdinand Marcos, her allies at the House of Representatives are claiming that the former senator might be suffering from “selective amnesia, which has impaired his judgment and ability to recall Philippine history.” Congressmen Exequiel Javier and Eduardo Veloso said a more accurate analogy should have been Marcos and jailed president Joseph Estrada since both of them were ousted by a military-backed popular revolt.
“The former Senate president must be suffering from selective amnesia, which has impaired his judgment and ability to recall Philippine history ,” they said in a joint statement. "Why zero in on the President, because he [Salonga] is now an opposition sympathizer ?” ?” Javier said. Javier said Salonga’s comparison of Ms Arroyo to Marcos and of Esperon to Gen. Fabian Ver, Marcos’ military chief, was not even like comparing apples to oranges. Veloso said the parallelism drawn by Salonga between Marcos and Ms Arroyo was “most unfair to the President who has become a victim of constant black propaganda and ouster efforts by her detractors .” If we indeed indeed live live under under anothe anotherr author authorita itaria rian n rule, rule, how come come the Presid President ent’s ’s detr detrac acto tors rs and and crit critic icss mana manage ged d to win win elec electi tive ve post postss and and can can free freely ly participate in the elections?” he said.
In a text text messag message, e, Bacarr Bacarro o said said Espero Esperon n respec respected ted Salong Salonga’ a’ss “perso “personal nal opinion” but noted that the latter had based that opinion on “perception brought about by surveys.”“Surveys will be different based on [their] reason and intent,” Bacarro said. [ With reports from Michael Lim Ubac, Christine O. Avendano and Nikko Dizon of the Philippine Daily Inquirer , and Maila Ager, INQUIRER.net]. D.
SMITH TRANSFER TO US CUSTODY
Nicole: ‘A stab in the back by Arroyo’
“Former Senate President Jovito Salonga branded the government move to hand hand Sm Smit ith h back back to the the Am Amer eric ican anss as “a raw raw deal deal and and a midn midnig igh ht transaction. ” Salonga said the victims of the government’s giving in to US pressure were Nicole and the country’s justice system. 4
“The raw deal was done against Nicole and the judicial process... against Judge Benjamin Pozon, also against the Court of Appeals ,” Salonga said. “It is largely against the Supreme Court , where there is a pending case filed. [By Tarra Quismundo, Norman Bordadora, Cynthia Balana, Inquirer- Posted date: December 31, 2006].
II.
Since the President legally / constitutionally issued the appointment to ONG, and and cons consid ider erin ing g that that forth forthwi with th,, ONG ONG abso absolu lute tely ly and and unconditionally the same same by pers person onal ally ly fili filing ng,, hand handin ing g and and deli delive veri ring ng the the accepted the PRESID PRESIDENT ENTIAL IAL APPOIN APPOINTME TMENT NT paper paper to the Supreme Supreme Court Court / Acting Acting Chief Justice Justice L. A. Quisumbing Quisumbing (before this suit), IPSO FACTO (and at the very moment the latter received it, the 15th Supreme Court Associate Justice post is deemed occupied / taken (by operation of the 1987 Constitution; IPSO JURE , the same was, at that precious moment deemed NO LONGER VACANT). The other irrelevant (to the validity of the appointment) / consequential / result resultant ant /direc /director tory y acts and ceremo ceremonie niess (like the directory JUDICIAL OATH, ceremonial oath / photo opportunity before / with the President, filing copies with the Clerk of Court – as ruled in In re Vallarta, to prevent forgeries, depositing copies with the Civil Service Commission, donning the Robes, being present in the sessions, signing of decisions, and receiving the salaries, all these) are just consequences or to-follow acts of SUPREME COURT ASSOCIATE JUSTICE GREGORY SANTOS ONG which have no bearing at all, on his already HAVING BEEN FULLY CLOTHED with FULL POWERS as the GOD OF FAURA (when he delivered the GMA duly signed PAPER to ACTING CHIEF JUSTICE L. A. QUISUMBING). Per JUDICIAL FIAT , ONG can only be ousted by another constitutional constitutional Court, the Senate Impeachment Tribunal, which (from the moment A. C.J. Quisumbing personally received the BODY of ONG and the GMA paper at his exclusive original original jurisdictio jurisdiction n over any and all suits / Chambers) acquired exclusive accusations to REMOVE, OUST and THROW AWAY the body of ONG from the GOD OF FAURA THRONE. This Court, with all due respect , has NO JURISDICTION over the subject matter, the issues, the petitioners’ filed cases and over the person of ONG. Jurisdiction over these cannot be waived by ONG and can be questioned at any stage of the instant proceedings.
In the celebrated Justice MINITA VIRAY CHICO-NAZARIO case, the GMA original paper was duly signed but ONLY THE FAXED copy was received by Justice Nazario. The Court may take JUDICIAL NOTICE that - the news reports published the CRITICAL CRITICAL FACT that Justice Nazario 5
went to the Office of C.J. Davide, Jr. forthwith, when her clerk received the same. Mr. Davide, Jr. asked her to produce the original, but she failed. She went to Baguio City to have suffered the snafu / trauma. Then, she testified nationwide on ANC cable Abs-Cbn where she stressed that – “It is the dream of all lawyers to become Supreme Court Justice”.
Her case was worst or rendered more painful, since she never possessed the original appointment. In fact, Sec. Bunye kept the nation in dire suspense, when he would not admit nor deny if the paper was recalled. But in this case, ONG had the a) original papers, while b) Malacanang and the c) Solicitor General confirmed verbally and officially (per media and in filed pleadings) that ONG had been duly appointed and the paper had not been recalled nor returned to the JBC. More importantly, d) Fr. Joaquin G. Bernas, S.J., eminent constitutionalist and regular amicus curiae of this Court declared /
published his AUTHORITY on the matter that ONG is NATURAL BORN citizen. And I repeat, that the UN CRC TREATY categorically mandates that,
in case case of doub doubt, t, the the natu natura rall born born issu issuee of citi citize zens nshi hip p MUST MUST perf perfor orce, ce, be resolved in favor of ONG, since such is MORE FAVORABLE to the child (as landmark precedent, this Court ruled in favor of legitimacy of FPJ / Ronald Allan Kelly Poe, since such ruling is more favorable to POE).
Worst for petitioners, the Filipino nation never contradicted the appo appoin intm tmen entt as UTTER UTTER RESPE RESPECT CT to the the PRES PRESID IDEN ENT T and and to the the 15 th Supreme Court Associate Justice. Now, amid news reports that there will be flo floods ods of suit suitss to oust oust ONG, ONG, the the fact fact rema remaiins that hat NO PETITI PETITION ON what whatso soev ever er had had be been en file filed d to OUST OUST ONG ONG, exce except pt peti petiti tion oner ers’ s’.. The The
FILIPINO FILIPINO people, people, for sure, comprehend comprehend that the 1987 Constitution Constitution provides provides only ONE WAY to litigate the citizenship issue, to oust ONG: accuse him of having committed a culpable violation of the constitution, by forgery of his citizenship papers, JBC personal data, and deception of the Filipino nation, IN CONGRESS towards the SENATE IMPEACHMENT TRIBUNAL. There is no other way that a suit may proper in the ordinary course of law. IT IS ABSOLUTELY ABSURD for petitioners, on the one hand, to insist that ONG is a Chinese citizen (for on the other, he could not be a naturalized 6
Filipino, at any legal angle), for what remains, r emains, if SALONGA’s weird stance is bel belie ieve ved, d, at the the very very leas least, t, ONG ONG woul would d be a STAT STATEL ELESS ESS alie alien n unde under r international law. This consequential judicial LOGIC follows, and I HATE very much, to lecture upon SALONGA on this CIVIL law subject. A final word.
God hath truly destined ONG to be the 15th Supreme Court Associate Justice. There can be no other spiritual proof , than, the CRITICAL data that he was at the PINK SISTERS convent, Tagaytay City, at the time pre-prophesied (per news reports) and it was barely a week before his MAY 25, 2007 natal day . It is / was a TOKEN as birthday GIFT by the SPIRIT that gives life from the AMEN , the Fait Faithf hful ul and and True True, the WORD ORD of GOD GOD. I myself self,, YOUR YOUR
HONORS, was asked by my ANGELS to have applied with the JBC on my natal day of November 5, 1997, and I was DONNED THE ROBES when ERAP appointed me on my birthday on November (4) 5, 1998, at the age of 45, the youngest RTC, NCJR Judge, ever ( Br. 73, RTC, Malabon). At the time of the appointment of ONG, I was also 53 years OLD. As PROPHET with TWIN GIFTS of SPIRITUAL HEALING and DISCERNMENT,
your HONORS, REST ASSURED, and I most respectfully MANIFEST that in 2010, after the curtains of the 22 nd PUNO Court should be deemed closed, and by virtue of the hereby by POWE POWERS RS vest vested ed in me by my 3 WORL WORLD-F D-FAM AMOU OUS S ANGE ANGELS LS,, I here CERTIFY that ONG will never ever be a candidate for CHIEF JUSTICE, for he will just be the smallest LIGHT as Benjamin of this Court of Last Resort. We beg all of you to co-sign his DESTINY, since it is the WILL of
GOD. GOD. Petiti Petitione oners’ rs’ CASE CASE must must perforce perforce FALL FALL becaus becausee of the SPIRIT SPIRITUAL UAL WEIGHT of ONG’s LIGHT, from GOD. AMEN.
For his greater glory.
There is no other more potent and destructive weapon against evil and petit petition ioners ers’’ basele baseless ss / persec persecuto utory ry suit suit upon upon ONG / his family family,, than than the
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WORD of GOD. We pray that petitioners be ENLIGHTENED to repent, and
to be KIND to ONG, for God is on our side. We SING this song: The Psalms 73 The Fate of the Wicked A Psalm of Asaph. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
21 22 23 24 25 26
Truly God is good to Israel, even to such as are of a clean heart. But as for me, my feet were almost gone; my steps had well-nigh slipped. For I was envious at the foolish, when I saw the prosperity of the wicked. For there are no bands in their death: but their strength is firm. They are not in trouble as other men; neither are they plagued like other men. Therefore pride compasseth them about as a chain; violence covereth them as a garment. Their eyes stand out with fatness: they have more than heart could wish. They are corrupt, and speak wickedly concerning oppression: they speak loftily. They set their mouth against the heavens, and their tongue walketh through the earth. Therefore his people return hither: and waters of a full cup are wrung out to them. And they say, How doth God know? And is there knowledge in the Most High? Behold, these are the ungodly, who prosper in the world;they increase in riches. Verily I have cleansed my heart in vain, and washed my hands in innocency. For all the day long have I been plagued, and chastened every morning. If I say, I will speak thus; behold, I should offend against the generation of thy children. When I thought to know this, it was too painful for me; until I went into the sanctuary of God; then understood I their end. Surely thou didst set them in slippery places: thou castedst them down into destruction. How are they brought into desolation, as in a moment! They are utterly consumed with terrors. As a dream when one awaketh; so, O Lord, when thou awakest, thou shalt despise their image. Thus my heart was grieved, and I was pricked in my reins. So foolish was I, and ignorant: I was as a beast before thee. Nevertheless I am continually with thee: thou hast holden me by my right hand. Thou shalt guide me with thy counsel, and afterward receive me to glory. Whom have I in heaven but thee? And there is none upon earth that I desire besides thee. My flesh and my heart faileth: but God is the strength of my heart, and my portion for ever.
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For, lo, they that are far from thee shall perish: thou hast destroyed all them that go a whoring from thee. But it is good for me to draw near to God: I have put my trust in the Lord GOD, that I may declare all thy works.
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RELIEF
WHEREFORE, WHEREFORE, premises premises considered considered,, the Intervenor, Intervenor, Judge FLORENTINO V. FLORO, JR., respectfully begs leave to intervene as petitioner-in-intervention in this case, and prays FOR LEAVE OF COURT Manifestatio ation n and MOTION MOTION TO RECONSI RECONSIDER DER , the that that the instan instantt Manifest Petition-in-intervention and SUPPLEMENT be duly noted, admitted, given due course, and GRANTED. Intervenor FLORO, JR. tenders payment of all docket / legal fees (if required) , upon admission of this motion / Petition . Further, Intervenor Judge Floro respectfully prays that ---
1.
Immediately
upon
the
filing
of
this
motion and and
pleading,
a
TEMPORA TEMPORARY RY RESTRA RESTRAINI INING NG ORDER ORDER be issued issued --- enjoining
respondent Justice ONG, from performing acts and assuming jurisdiction / conduc conductin ting g procee proceedin dings gs in the Sandig Sandiganb anbaya ayan, n, and enjoining the Judi Judici cial al and and Bar Bar Counc Council il from from furt furthe herr proc procee eedi ding ng in any any mann manner er
against the nomination of Justice Ong; commanding respondent Justice Ong, immediately or at some other time to be specified with certainty by DIRECTORY OATH of OFFICE, to this Honorable Court, to take his DIRECTORY Associate Justice Justice duly, assume jurisdiction as the 15th Supreme Court Associate
legally and constitutionally appointed, and to perform all his duties / obligations, thus fully possessing the sacred office, forthwith; and
2. Afte Afterr cons consid ider erin ing g the the meri merits ts of this this inter interve vent ntio ion n and and the the plea pleadi ding ngss of respon responden dentt Justic Justicee Ong, Ong, to render render judgme judgment: nt: a) declar declaring ing respon responden dentt Just Justic icee Ong Ong as the the vali validl dly, y, lega legall lly y and and cons consti titu tuti tion onal ally ly appo appoin inte ted d Suprem Supremee Court Court Associ Associate ate Justic Justicee - succes successor sor of Justic Justicee Callej Callejo, o, Sr., Sr., commanding him to take the directory Oath of Office and fully assume office and jurisdiction, forthwith.
Other reliefs and remedies are likewise prayed for. Malolos City, Bulacan, for Manila, June 22, 2007. Judge FLORENTINO V. FLORO, JR., Movant/Petitioner-in-intervention, 9
123 Dahlia, Alido, Malolos, 3000 BULACAN, Tel/#(044) 662-82-03; (Presiding Judge, Branch 73, RTC, MALABON, NCJR, M.M.) [I.D. Number: RTCJ-317 / EDP Number: 38676300; 386763 00; ROLL OF ATTORNEY’S NO. 32800, Pg. No. 60, Book No. XIV (Note: Motion For Leave to Admit 4 th Appeal to be reinstated is pending.] PTR No. 503411, dated 1-11-’07, Malolos, Bulacan.
NOTICE
TO:
Atty. Ma. Luisa D. Villarama, Clerk of Court, En Banc, SUPREME COURT, MANILA
Please DOCKET and AGENDUM the foregoing pleading for the deliberation and Resolution of the Honorable Honorable Court, Court, immediat immediately ely upon receipt receipt hereof, hereof, in view of the urgency urgency of the matter. THANKS. THANKS. UPON ADMISSION OF THIS PLEADING, PLEASE NOTIFY UNDERSIGNED, SO THAT HE WILL BE ABLE TO FORTHWITH PAY ALL THE REQUIRED DOCKET / LEGAL FEES. All RIGHTS reserved, none waived.
Judge FLORENTINO V. FLORO, JR., Petitioner-in-Intervention VERIFICATION & Affidavit of Service Republic of the Philippines) Malolos City, BULACAN ) S.S. I, JUDGE JUDGE FLOREN FLORENTIN TINO O V. FLORO, FLORO, JR., under under oath, oath, depose depose and say, that: that: I am the Intervenor/movant in the above-entitled case and I read, caused the preparation of, and signed the foregoing pleading. And all the allegations/contents thereof/therein thereof/therein are true and correct of my own personal knowledge or based on authentic records. I CERTIFY that on June 21, 2007, I served copies of this Manifestation and Motion Motion to Recons Reconside iderr in this this case case G.R. G.R. No. No. 177721 177721,, “ Kilosbay Kilosbayan an Foundation Foundation & Bantay Bantay Katarunga Katarungan n Foundation v. Executive Secretary Eduardo R. Ermita, Office of the President & Sandiganbayan Justice Gregory S. Ong ”, ”, upon all petitioners and respondents/ counsels via registered mail with return card at their offices / addresses as hereunder indicated, in accordance with Secs. 3, 5, 7, 13 and 12 of Rule 13, Rules of Court, by depositing said copies at the Malolos Post Office, as evidenced by reg. receipts hereto attached, and pasted after their names, and indicated after the names of the addressees, and with instructions to the postmaster to return the mails to the sender after 10 days if undelivered.
IN WITNESS WHEREOF, I signed this affidavit, this 22nd day June, 2007, at Malolos City, BULACAN.
JUDGE FLORENTINO V. FLORO, JR., affiant. SUBSCRIBED AND SWORN to before me, on this 22nd day of June, 2007, hereat Malolos City, Bulacan, affiant exhibited to me his CTC NO. CC12006 # 10333105, issued at Malolos, Bulacan, on 1-11, 2007. DOC. NO. ______, PAGE NO. ____, BOOK NO. ____, SERIES OF 2007.
BERNAR D. FAJARDO Notary Public, Until Jan.15, 2008, PTR NO. 2417109, 1- 3,’07, Atty.’s Roll No. 33633, IBP OR # 687744,n 1-5,’07 Malolos City, Bulacan.
COPY FURNISHED:
Atty. Jovito R. Salonga , Counsel (and President of) Petitioners, Kilosbayan Foundation, &
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Bantay Katarungan Foundation, Kilosbayan House, 7 First Street, Acacia Lane, Mandaluyong City, Tel. Nos. 534-5868 and 534-5889, Executive Secretary Eduardo R. Ermita Public respondent, Office of the President , Malacanang Palace, Manila, M.M. Public Respondent, Atty. RENE A. V. SAGUISAG, 4045 Bigasan St., Palanan, Makati City, M.M., Counsel of Record for Respondent, Sandiganbayan Justice Gregory S. Ong, SANDIGANBAYAN, Centennial Building, Commonwealth Ave., Batasan Road, Quezon City, M. M., Tel. # 951-4521 , and The Office of the Solicitor General, 124 Amorsolo st., Legaspi Village, Makati, Metro Manila, Counsel for Public Respondents. Explanation on Service by Registered Mail : Intervenor, in compliance with Secs. 7, 11, Rule 13, 1997 Rules of Civil Procedure, states that due to lack of time and messenger and impracticality, he served copies of these motion and attached petition and annexes to all petitioners and respondents by registered mail with return card with attached receipts, pasted after the names of respondents and petitioners.
JUDGE FLORENTINO V. FLORO, JR. 123 Dalia, Alido, Bulihan, Malolos City, 3000 Bulacan Republic of the Philippines) Malolos City, BULACAN ) S.S.
AFFIDAVIT OF SERVICE I, JUDGE FLORENTINO V. FLORO, JR., of 123 Dahlia, Alido, Malolos, 3000 Bulacan, under oath, depose and say, that: I CERTIFY that on June 21, 2007 , I served copies of this SUPPLEMENT, in this case G.R. No. 177721 , “Kilosbayan Foundation & Bantay Katarungan v. Exec. Sec. E. Ermita, et al... ” upon all petitioners / counsels and respondents / COUNSELS via registered mail with return card at their offices / addresses as hereunder indicated, in accordance with Secs. 3, 5, 7, 13 and 12 of Rule 13, Rules of Court, by depositing said copies at the Malolos Post Office, Bulacan, as evidenced by registry receipts hereto attached, hereunder, and indicated after the names of the addressees, and with instructions to the postmaster to return the mails to the sender after 10 days if undelivered: COPY FURNISHED: NAMES & ADDRESSES ADDRESS ES OF ADDRESSEES ADDRESS EES
Atty. Jovito R. Salonga , Counsel (and President of) Petitioners, Kilosbayan Foundation, &
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REGISTRY REGIST RY RECEIPT RECEIP T
Bantay Katarungan Foundation, Kilosbayan House, 7 First Street, Acacia Lane, Mandaluyong City, Tel. Nos. 534-5868 and 534-5889, Executive Secretary Eduardo R. Ermita Public respondent, Office of the President , Malacanang Palace, Manila, M.M. Public Respondent,
Atty. RENE A. V. SAGUISAG, 4045 Bigasan St., Palanan, Makati City, M.M., Counsel of Record for Respondent, Sandiganbayan Justice Gregory S. Ong, SANDIGANBAYAN, Centennial Building, Commonwealth Ave., Batasan Road, Quezon City, M. M., Tel. # 951-4521 , and The Office of the Solicitor General, 124 Amorsolo st., Legaspi Village, Makati, Metro Manila, Counsel for Public Respondents. Explanation on Service by Registered Mail : Intervenor, in compliance with Secs. 7, 11, Rule 13, 1997 Rules of Civil Procedure, states that due to lack of time and messenger and impracticality, he served copies of these motion and attached petition and annexes to all petitioners and respondents by registered mail with return card with attached receipts, pasted after the names of respondents and petitioners.
JUDGE FLORENTINO V. FLORO, JR. 123 Dalia, Alido, Bulihan, Malolos City, 3000 Bulacan IN WITNESS WHEREOF, I signed this affidavit, this 22nd day of June, 2007, at Malolos City, BULACAN.
JUDGE FLORENTINO V. FLORO, JR., affiant. SUBSCRIBED AND SWORN to before me, on this 22th day of June, 2007, hereat Malolos City, Bulacan, affiant exhibited to me his CTC NO. CC12006 # 10333105, issued at Malolos, Bulacan, on 1-11, 2007. DOC. NO. _____, PAGE NO. ____, BOOK NO. ____, SERIES OF 2007.
BERNAR D. FAJARDO Notary Public, Until Jan.15, 2008, PTR NO. 2417109, 1- 3,’07, Atty.’s Roll No. 33633, IBP OR # 687744,n 1-5,’07 Malolos, Bulacan.
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