REPUBLIC OF THE PHILIPPINESCourt of Appeals

Maria Orosa, ManilaJudge Florentino V. Floro, Jr.,                                             Petitioner,              - versus -                                               S.P. No. _________________                                                                              Petition for Writ of AmparoJudge Thelma Pinero-Cruz, andPresiding Judge , Br. 16, RTC, Malolos City , Bulacan,Mrs. Lerida Socorro-Joson,Legal Researcher / OIC, Br. 16, RTC, Malolos City , Bulacan,                                      Respondents.X-----------------------------------------------------------------------X  Verified Petition for Issuance of Writ of Amparo / Affidavit

[With Prayer To Issue Interim Reliefs of Temporary Protection Order, Inspection Orderand Production Order under Sec. 14, A.M. No. 07-9-12-SC as amended by A.M.

No. 07-9-12-SC, and Legal Reservation of the Right to File Supplemental Petition for Habeas Data(effective on February 2, 2008), and Separate

Administrative, Criminal and Civil Casesagainst Respondents and co-conspirators, under Sec. 21]

And – Urgent Prayer   for   Immediate Resolution  

 COMES NOW the undersigned petitioner, Judge Florentino V.

Floro, Jr., under oath, by HIMSELF and for HIMSELF, as litigant / petitioner in the instant extraordinary lawsuit, WITH LEAVE   OF THISHONORABLE   COURT , and INVOKING Sections 1, 2 and 5, inter alia, of the Writ of Amparo Rule (A.M. No. 07-9-12-SC as amended by A.M. No. 07-9-12-SC) most respectfully depose and say, that: 

Prefatory 

Chief Justice Artemio V. Panganiban opined (re: "Ces Orena-

Drillon / ABS-CBN employees vs. Ronaldo Puno" Amparo Petition dated 1-

21, 2008):    "I THINK THE SUPREME COURT ACTED prudently in requiring the government to comment on the petition of the 11 broadcast journalists, led by Ces Orena Drilon, who challenged their arrest and detention as an aftermath of the Peninsula Manila Hotel siege." 

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Overlook procedural lapses: 

C. J. Panganiban stressed that: 

"When great constitutional issues are raised, the high tribunal historically tends to overlook procedural technicalities and looks at the substance of the controversy.Dismissing the Drilon petition on procedural grounds would have merely delayed the case. Tackling the case on its merits augurs well for our democracy. Even the respondent officials, notably Interior Secretary Ronaldo Puno and PNP Director General Avelino Razon, have publicly welcomed judicial guidance on the paramount issues raised; namely, the legality of the arrest and detention of the petitioners; and, the validity of the media advisory issued by the Department of Justice, warning that journalists might incur criminal liability if they disobeyed orders from police authorities during “emergencies.” 

(With Due Respect, Concurring and dissenting, By C.J. Artemio V. Panganiban, Philippine Daily Inquirer, 01/26/2008) URL:http://opinion.inquirer.net/inquireropinion/columns/view/20080126-115016/Concurring-and-dissenting

 

         On September 25, 2007, Chief Justice Reynato Puno officially

announced the approval or promulgation of the Writ of Amparo: 

 "Today, the Supreme Court promulgated the rule that will place the constitutional right to life, liberty and security above violation and threats of violation. This rule will provide the victims of extralegal killings and enforced disappearances the protection they need and the promise of vindication for their rights. This rule empowers our courts to issue reliefs that may be granted through judicial orders of protection, production, inspection and other relief to safeguard one's life and liberty. The writ of amparo shall hold public authorities, those who took their oath to defend the constitution and enforce our laws, to a high standard of official conduct and hold them accountable to our people. The sovereign Filipino people should be assured that if their right to life and liberty is threatened or violated, they will find vindication in our courts of justice.

   

        On September 23, 2007, undersigned petitioner as WikiPedian editor /

User, created in the world’s largest and multi-awarded ON-LINE

encyclopedia, “Writ of Amparo and Habeas Data (Philippines),” the very

first article on AMPARO which had been created. Copies of the WikiPedia

Article and the Talk Page are attached as Annexes A-1 and A hereof.

 

SUPPORTING AFFIDAVIT (Sec. 5, A.M. No. 07-9-12-SC)  

REPUBLIC OF THE PHILIPPINES )

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Malolos City, BULACAN                   ) S.S.      I, Judge Florentino V. Floro, Jr., under oath, depose / say, that: Nature of the Petition / Parties / The names / personal circumstances of the petitioner / respondents responsible for the threat, act or omission The right to life, liberty and security of the petitioner violated or threatened with violation by an unlawful act or omission of the respondents; how such threat or violation is committed with the detailed attendant circumstancesThe investigation conducted, the names, personal circumstances, and addresses of the investigating authority or individuals, the manner and conduct of the investigation, together with any report / Court orders The actions and recourses taken by the petitioner to determine the Constitutional and legal violations by respondents, inter alia, and the identity of the person / s  responsible for the threat, act or omission 

  

         Petitioner Judge Florentino V. Floro, Jr. is a resident of 123 Dahlia,

Alido, Bulihan, Malolos City , 3000 Bulacan, where he may be served with

court summons, orders, processes and decisions.

 

         Respondent Judge Thelma Pinero-Cruz, is the Presiding Judge, Br. 16,

RTC, Malolos City, 3000 Bulacan; while respondent Mrs. Lerida Socorro-

Joson, is the legal researcher / OIC, Br. 16, RTC, Malolos City, 3000

Bulacan, where they may be served with court summons, orders, processes

and decisions.

 

  

         To begin with, Mandamus, Certiorari, Prohibition, mesne processes,

Motions, Disbarment and Administrative or even Criminal Cases against

respondents are useless remedies (in the ordinary course of law, due to clear

bribery, which under our criminal jurisprudence can only be proved by NBI

entrapment) For a clear violation of petitioner’s constitutional rights under

our present rule of law, Amparo is the sole remedy of petitioner under the

critical facts and applicable law/s, hereunder specified in detail.

 

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         The instant petition seeks Amparo protection from this Honorable

Court against respondents - to prevent them from harassing or threatening to

permanently delay - petitioner's consolidated case, particularly the

promulgation of the decision, long overdue on December, 2004 / September,

2005. Moves to delay, maneuvers to submit piece-meal resolutions to limit

justice and censor the pleadings are no longer just temptations for the

respondents. Here is a reality that petitioner has to expose and stop, by the

only efficacious remedy: Amparo.

The writ, copied from a measure used widely in Latin America against

abusive government officers and employees, was adopted by the high

tribunal last year amid an upsurge of human rights abuses and extrajudicial

executions in the country.

 

This landmark and judicial FIRST Amparo petition is sought to stop /

prevent respondent Mrs. Lerida Socorro-Joson (“Joson”, for brevity) from

"utang-utang", demanding moneys from court litigants, and, as bar flunker,

from drafting decisions, sowing judicial terrorism, doing illegal searching

instead of legal searching, and, as UNQUALIFIED legal researcher, from

making the trials - farce, or moro-moro so to speak, inter alia. Her acts of

charging and prosecuting petitioner and ignorant litigants, with her co-

conspirators, which include lawyer/s in connection with the non-release of

the judgment since December, 2004, tarnished the image of the judiciary.

 

The instant petition also calls on this 2nd Highest Tribunal to

preventthe respondents from “effecting, and making threats of, issuing unjust

interlocutory orders, resolutions and acts of harassment” of petitioner and other

litigants, in the course or in consequence of the hearing, trial and processes, due to

greed, lust for money, and thirst for vengeance. St. Paul wrote that "death comes

from sin, and sin comes from law" - the law of greed, envy, hatred, vengeance,

vendetta,HYPOCRISY, graft and corruption, anger and bitterness - which cause/d

cancer, stroke, nerve and spinal disorders, accidents, horrible deaths, lingering

illnesses, extrajudicial killings and desaparecidos, necessitating the

extraordinary remedy of AMPARO. The peremptory writ is the sole weapon

against judicial HYPOCRISY and violation of the Constitution, inter alia, by

Judge Thelma Pinero-Cruz (“Judge Thelma”, for brevity) by her unjust refusal

to release a decision due on December, 2004, because of the clear P 80,000

pay-off.

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     Parenthetically (in the world-famous Judgment in A.M. No. RTJ-

99-1460, March 31, 2006, entitled "OCA vs. Judge Florentino V. Floro,

Jr."), Justice Minita Viray Chico-Nazario ruled (in the ratio decidendi):

 

     "There is no indication that Judge Floro is anything but an honorable man.  And, in fact, in our disposition of the 13 charges against him, we have not found him guilty of gross misconduct or acts or corruption.      Moreover, Judge Floro himself admitted that he believes in “psychic visions,” of foreseeing the future because of his power in “psychic phenomenon.”  He believes in “duwendes” and of a covenant with his “dwarf friends Luis, Armand and Angel.”  He believes that he can write while on trance and that he had been seen by several people to have been in two places at the same time.   He has likened himself to the “angel of death” who can inflict pains on people, especially upon those he perceived as corrupt officials of the RTCs of Malabon.     He took to wearing blue robes during court sessions, switching only to black on Fridays.     His own witness testified that Judge Floro explained that he wore black from head to foot on Fridays to recharge his psychic powers. Finally, Judge Floro conducted healing sessions in his chambers during his break time.     Judge Floro’s separation from the service does not carry with it forfeiture of all or part of his accrued benefits nor disqualification from appointment to any other public office including government-owned or controlled corporations. Consequently, while Judge Floro may be dysfunctional as a judge because of the sensitive nature of said position, he may still be successful in other areas of endeavor.    As Judge Floro’s separation from the service cannot be considered a penalty, such separation does not carry with it the forfeiture of all or part of his accrued benefits nor disqualification from appointment to any other public office including government-owned or controlled corporations.     In fact, the psychological and psychiatric reports, considered as the bedrock of the finding of mental impairment against Judge Floro, cannot be used to disqualify him from re-entering government service for positions that do not require him to dispense justice.     The reports contain statements/findings in Judge Floro’s favor that the Court cannot overlook in all fairness as they deserve equal consideration.      Lest we be misconstrued, we do not denigrate such belief system.     However, such beliefs, especially since Judge Floro acted on them, are so at odds with the critical and impartial thinking required of a judge under our judicial system.

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      Psychic phenomena, even assuming such exist, have no place in a judiciary duty bound to apply only positive law and, in its absence, equitable rules and principles in resolving controversies.” 

http://www.supremecourt.gov.ph/jurisprudence/2006/mar2006/A.M.%20No.%20RTJ-99-

1460.htm

 

          Petitioner's “constitutional rights to due process of law, property,

liberty and security” were violated when respondents Judge Thelma

and Joson disobeyed the Constitutional provisions, Canons of Ethics for Court

personnel, Code of Judicial Conduct, Code of Professional Responsibility, Revised

Penal Code, R.A. 6713, R.A. 3019, Rule 139-B, 139 and 140, Rules of Court, inter

alia.

 

     But worse, there continue to be very real threats that such rights of

petitioner will again soon be disregarded and infringed upon.

Why?  The  P 80,000 pay-off between respondents and Alfred Trinidad,

son of litigants / LRC petitioners, through counsel  Atty. Nye

Orquillas,  permanently locked the hands of respondents to release any

decision on the 10 year case,  putting  petitioner  at  their mercy,  and

there is no longer any plain, speedy and fast remedy in the ordinary

course of law. No less than the Honorable Supreme Court's 3rd

Division’s final Resolution dated March 8, 2006 ruled: (against

respondent Joson, and in favor of undersigned, in A. M. OCA IPI No.

05-2157-P):

 

“To REMINDS respondent OIC Mrs. Lerida Socorro-Joson to BE MORE CIRCUMSPECT and PRUDENT in the discharge of her duties ….” 

Bribery: urgent and compelling - chilling effect on litigants' and lawyers' recourse to the Courts – first and foremost cause of extra-judicial killings

 

These developments have far-reaching consequences because every

litigant especially the pauper and less privileged have to worry that he or she

may be forced to pay huge sums or bribes to magistrates in the Bulacan

judiciary, specifically to the a) MAGICIANS b) CARDIOLOGISTS c)

Marilao, Bulacan LATIAN fixers and d) respondents - due to conspiracy

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between lawyers, judges, and court personnel, as fixers and brokers.

Petitioner believed in the Supreme Court’s long history of vigilance on this

matter of paramount import. How can a bar flunker legal researcher,

respondent Joson be qualified as OIC or legal researcher? How can the life,

liberty and property of litigants be entrusted to such legally, mentally and

physically disabled court personnel? Petitioner cites authority:

Judicial corruption

     “On January 25, 2005, and on December 10, 2006, Philippines Social Weather Stations released the results of its 2 surveys on corruption in the judiciary; it published that: a) like 1995, 1/4 of lawyers said many/very many judges are corrupt. But (49%) stated that a judges received bribes, just 8% of lawyers admitted they reported the bribery, because they could not prove it. [Tables 8-9]; judges, however, said, just 7% call many/very many judges as corrupt[Tables 10-11];b) "Judges see some corruption; proportions who said - many/very many corrupt judges or justices: 17% in reference to RTC judges, 14% to MTC judges, 12% to Court of Appeals justices, 4% i to Shari'a Court judges, 4% toSandiganbayan justices and 2% in reference to Supreme Court justices [Table 15].”

 

Petitioner runs to this Honorable Court of Appeals with urgent and

compelling reasons. If petitioner (as lawyer, judge, world-famous prophet,

psychic, healing magistrate, a Second Honors Ateneo alumni and 1983 Bar

Exams, 12th placer, 87.55%) could not obtain justice in his own town and

province, for he could no longer, by any legal means (including scholarly

written and filed court pleadings) obtain justice per the Bulacan RTC rule of

law, how can an ordinary mortal / litigant, unlike undersigned fight in the

lowest / local courts of law?

 

Petitioner's dilemma is: respondent Judge Thelma’s spouse died

ofcancer in 2004/5, when she failed to issue the decision; if petitioner would

file this case in RTC Bulacan (the co-equal court for sure would invoke

judicial courtesy); and/or if filed in the Supreme Court, respondent Judge, a

member of UP Class 62, who is about to retire on 2009, would of course

catch not only the attention, but the mercy and anguish of (the HUMAN

NATURE) of about 4 incumbent Supreme Associate Justices, her

classmates. My conscience is clear. The evil actuation of respondents is an

attack on the credibility of the judicial department.

 

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Burning issue – Judge Thelma’s Disobedience to the Constitutional

mandate – Sec. 15, (1), (2), (4), Art. VIII, 1987 Constitution

 

“Beneath the surface of a restored democracy, the Philippines still

suffers… from the collective trauma of martial law and an ingrained

institutional habit of human rights abuse.” Today’s increasing resort to the

writ of amparo is a consequence.(Cebu Daily News / Opinion Viewpoint, Memory holes, By Juan Mercado, Cebu Daily News, Philippine Daily Inquirer - 01/24/2008)

 

http://globalnation.inquirer.net/cebudailynews/opinion/view/20080124-114509/Memory-holes

 

Bakit po ba ang dami ng EJ killings and Desaparecidos?  It is because

of corruption in courts, per SWS surveys of 1995 / 2005: the UN Philip

Alston and FIDH Reports, the Eric G. John and G. Eugene Martin

Testimonies on March 14, 2007 at the USA Senate point to judicial

corruption as ROOT of all extrajudicial killings and enforced

disappearances:

 

Litigants lost hope in going to courts due to selling of decisions,

extortions by court personnel as fixers of judges, and finally the end result is

recourse to the NPA, CPP and to 'juez de cochillo". Petitioner, (as world-

famous GIFTED), was endowed (by God per St. Paul and the 3 holy angels,

world-famous LUIS, Armand and Angel), with the power to annihilate by

Lights and Fire. He accurately predicted the 2007 mystic fires which halved

the Supreme LOGO, on January 15, 2007, the Comelec’s seal, the entire 4th

floor of this Honorable Court, the Muntinlupa Metropolitan Trial Court,

Malabon RTC, except his sala on July 22, 2000 and RTC Malolos Courts,

circa 1987. On January 15, 2008, the 15th RTC Judge Navidad was shot on

the left eye, and mercilessly, after Fr. Rey Roda was gunned down on the

same days that the Supreme Court was burned, last year. God watches us

from a very near distance, and not so far.

 

        On September 23, 2007, undersigned petitioner as WikiPedian

editor / User, created in the world’s largest and multi-awarded ON-LINE

encyclopedia, “Philippine Extrajudicial Killings and Desaparecidos),”the

very first article on Philippine E-J Killings and Abduction, which had been

created (copies of the WikiPedia Article and the Talk Page are attached

asAnnexes B-1 and B hereof). Petitioner cites the pertinent parts:

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Philippine Extrajudicial Killings and Desaparecidos

International Reports - the root cause of killings

 Alston UN Report

Philip Alston  submitted his final report on the killings; he found that the Armed Forces of the Philippines killed left-wing activists to get rid off communist insurgents: "the executions had “eliminated civil society leaders, including human rights defenders, trade unionists and land reform advocates, intimidated a vast number of civil society actors, and narrowed the country’s political discourse.” Alston denied for lack of merit the government's claim that killings were perpetrated by communists to exterminate spies and to make negative propaganda versus government. Alston, on February, 2007 stated that the military made alibis or denials on its role about 800 deaths of activists and journalists since 2001. Alston blamed “impunity” which caused the executions of journalists and leftist activists: “the priorities of the criminal justice system had been “distorted,” and had “increasingly focused on prosecuting civil society leaders rather than their killers.” But Alston noted the government's creation of - special courts to try extra-judicial killings, the Melo Commission and the Philippine National Police’s Task Force Usig.[56][57] In the November U.N. Alston report - the killings in 2007 was only 68, huge drop from the 209 murdered in 2006. Karapatanpublished its report however, listing 830 victims of extra-judicial killings since 2001, under Gloria Macapagal-Arroyo.[58] On March 1, 2007, theSupreme Court of the Philippines issued Administrative Order No. 25-2007, which created by designation 99 regional trial courts to try cases of killings and desaparecidos.[59]

Failed Investigations and Prosecutions

The United Nations Special Rapporteur on Extrajudicial Execution found that just on paper trails, cases are filed; but Alston officially concluded that “there is a passivity, bordering on an abdication of responsibility, which affects the way in which key institutions and actors approach their responsibilities in relation to such human rights concerns; prosecutors refused to take a role in gathering evidence, and instead being purely passive, waiting for the police to present them with a file; the Ombudsman’s office did almost nothing in recent years in this regard, failing to act in any of the 44 complaints alleging extra-judicial executions attributed to State agents submitted from 2002 to 2006." (“Preliminary note on the visit of the Special Rapporteur on extra-judicial, summary or

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arbitrary executions, Philip Alston, to the Philippines (12-21 February 2007),” A/HRC/4/20/Add.3, March 22, 2007, p. 4., etc.)[60][61]

The Eric G. John and G. Eugene Martin Testimonies

On March 14, 2007, Eric G. John, Deputy Assistant Secretary for East Asian and Pacific Affairs testified before the USA Senate Subcommittee on Foreign Relations at Washington, DC . John submitted his written statement: a) the increase in extrajudicial killings, b) the “Huk Rebellion” in the 1940s and 50s causing thousands of murdered victims; c) the communist New People’s Army (NPA), which was listed in the U.S. State Department list of Foreign Terrorist Organizations campaigned to overthrow the government since 1968; d) Extrajudicial killings by the security forces, the NPA, etc. during the Marcos regime, were less; and e) noted the report of UN Special Rapporteur Alston which submitted the Philippine Government’s recognition of the gravity of the problem, expresses concern about the views of the Armed Forces of the Philippines (AFP) regarding the problem, but much had to be done.[62]

G. Eugene Martin, U.S. Institute of Peace Executive Director of the Philippine Facilitation Project, testified before the Senate Foreign Relations Subcommittee on East Asian and Pacific Affairs, and submitted to it the Asian Legal Resource Centre (ALRC) statement on the killings, a Joint Statement submitted by the World Council of Churches, the Asia Pacific Forum on Women, Law and Development and the Asian Legal Resource Center (ALRC) to the 6th Human Rights Council. Martin stated that the Philippine government said that it implemented measures to stop the killings, but he submitted that the reforms made did not and will not resolve the killings. Mr. Alston's March report stated that "the question of resources or technical expertise will partly resolve the killings but the strong risk is that these measures will treat only some of the symptoms of the crisis, and will fail to address meaningfully two of the most important underlying causes of a great many of the killings." (A/HRC/4/20/Add.3, March 22, 2007) Alston named 2 root causes of the killings a) 'vilification', 'labeling’, or guilt by association” - "characterization of most groups on the left of the political spectrum as ‘front organizations’ for armed groups whose aim is to destroy democracy" making the groups "considered to be legitimate targets; and b) the 2nd cause is the Government’s counter-insurgency strategy's extent of facilitating killings of activists and others.[63][64] G. Eugene Martin specifically expanded the 2 causes of the violence and killings: a) weak political and social institutions, corrupt and ineffective judicial system, resulting to failure to obtain justice from corrupt Philippine courts; and b) the legacy of the Ferdinand Marcos regime;Martial law caused the corrupt system where soldiers, police, judges and prosecutors became principals of offenses like extralegal arrest, detention, incarceration, disappearances

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and killings (salvaging), all permitted or allowed. He traced the spate of violence and killings to political instability of President Arroyo government; while she created the Independent Commission to Address Media and Activist Killings, Melo Commission, she had no capability to end the killings, due to her political lameness because of the 2004 election controversy.[65][66][67]

 FIDH Report

3 FIDH experts, Mr. Nabeel Rajab ( Bahrain ), Mr. Mouloud Boumghar ( France ) and Mr. Frédéric Ceuppens ( Belgium ), came to the Philippines on August 13 to 23, 2007. Their FIDH mission report stated that torture and ill-treatment was widespread versus suspected “terrorists”. The Filipino government is a signatory to the International Covenant on Civil and Political Rights (ICCPR), and the UN Convention against Torture (CAT). The FIDH dismissed the Philippines government's claim doubts that mechanisms were placed to stop the killings, as it questioned the efficiency of - the corrupt judiciary, the government “Witness Protection Programme” ; also, judges and lawyers were victims themselves of killings. It also found the Philippine anti-terrorism law ( “Human Security Act”) to result in more torture and extra-judicial killings as a fight against terrorism.[68]

Reason why Amparo is the only remedy left for petitioner

 

          To be very specific in law and in fact, bribery and the specific pay-

offof P 80,000 duly received by both respondents Judge Thelma and Joson

from Mr. Alfred Trinidad (as will be discussed hereunder, and resulting in

the locking of the hands of respondents to prevent any attempt to release the

decision, due since 2004), can only be tempered by C. J. Puno’s brain

children Amparo and Habeas Data. Petitioner citer his very own

CREATED WikiPedia article, the ONLY ARTICLE on Amparo, E-

Killings andDesaparecedos, in any world encyclopedia, to PROVE that the

CRITICAL facts of the instant suit are verily COVERED by Amparo,

thusly:

 

“Promulgation of Writs of Amparo and Habeas Data

Because of the inefficacy and insufficiency of the Philippines Writ of Habeas Corpus, on September 25, 2007, Chief Justice Reynato Punosigned and released the Writ of Amparo: "This rule will provide the victims of extralegal killings and enforced disappearances the protection they need and the promise of vindication for their rights.

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This rule empowers our courts to issue reliefs that may be granted through judicial orders of protection, production, inspection and other relief to safeguard one's life and liberty The writ of amparo shall hold public authorities, those who took their oath to defend the constitution and enforce our laws, to a high standard of official conduct and hold them accountable to our people. The sovereign Filipino people should be assured that if their right to life and liberty is threatened or violated, they will find vindication in our courts of justice'."[45][46][47]

[48] Puno explained the interim reliefs under amparo: temporary protection order (TPO), inspection order (IO), production order (PO), and witness protection order (WPO, RA 6981).[49] As supplement to Amparo, on August 30, 2007, Puno (atSilliman University in Dumaguete City, Negros Oriental) promised to release also the writ of habeas data (“you should have the idea” or “you should have the data”) another new legal remedy to solve the extrajudicial killings and enforced disappearances. Puno explained that the writ of amparo denies to authorities defense of simple denial, andhabeas data can find out what information is held by the officer, rectify or even the destroy erroneous data gathered. Brazil used the writ, followed by Colombia, Paraguay, Peru, Argentina and Ecuador.[50]

On December 3, 2007, Reynato S. Puno stated that the writ released only 3 victims (including Luisito Bustamante, Davao City), since amparo was enforced on October 24: "I would like to think that after the enactment and effectivity (of the writ), the number of extrajudicial killings and disappearances have gone down."[51]

On December 17, 2007, Iloilo regional trial court Judge Narciso Aguilar granted a writ of amparo against President Gloria Macapagal-Arroyo and 9 military and police officials to release Nilo Arado and Maria Luisa Posa-Dominado activists abducted on April 12.[52]

On December 19, 2007, Dra. Edita Burgos petitioned the Philippine Court of Appeals to issue a writ of amparo against Armed Forces chief Gen. Hermogenes Esperon Jr and Army chief Lt. Gen. Alexander Yano regarding her son Jonas's abduction on April 28.[53]

On December 27, 2007, the 2nd Division, Court of Appeals 30-page decision penned by Associate Justice Lucas Bersamin granted the writ of amparo filed by Reynaldo and Raymond Manalo, abducted activists.[54]

Recent Events

On February, 2007, The U.S. ambassador to the Philippines has broken her silence and called on Manila to end extrajudicial killings. On Feb. 27, U.S. ambassador Kristie Kenney U.S. ambassador to the Philippines alerted Mrs. Arroyo as she voiced her call to end these killings: "Let's beef up the human rights in the Armed Forces of the

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Philippines and make every effort to investigate, prosecute those responsible, [and] exonerate the innocent."[71]

On August, 2007, the International Day of the Disappeared, Asian Human Rights Commission (AHRC) ranked the Philippines among the top eight countries in Asia where forced disappearances of activists are not just rampant but are done with impunity. Sri Lanka heads the list (statement posted on its website (www.ahrchk.net). The activists took part in the recent Human Rights School Session of the AHRC for 2007. The AHRC listed the other countries where forced disappearances take place with impunity: Pakistan, Indonesia, Bangladesh, Nepal,Thailand, Philippines and parts of India.[72]

On September, 2007, Marie Hilao-Enriquez, Karapatan secretary-general, formally petitioned the United Nations Human Rights Council(UNHRC) to direct the Philippine government to stop the extrajudicial killings. She filed the report on 60 cases killings have been recorded by Karapatan from January to June, 2007, alone, with 17 cases of disappearances, 12 of torture and 113, of illegal arrests.[73][74]

On October 3, 2007 at Tarlac City, 69-year-old Bishop Alberto Ramento of the Iglesia Filipina Independiente (IFI), or Philippine Independent Church, and a vocal critic of killings under the Arroyo government, was stabbed 7 times and killed.[75]

The December 11 2006 Philippines National Police’s Task Force Usig submitted 115 cases of “slain party list /militant members” since 2001, and 26 cases of “mediamen.” The Philippine Daily Inquirer published 299 killings from October 2001 and April 2007 (See e.g. Alcuin Papa, “3 US solons to PNP: Respect human rights,” Philippine Daily Inquirer, April 18, 2007)[76]

The December, 2007 year end report of Karapatan ( Alliance for the Advance of People’s Rights) noted only 68 extrajudicial killings vis-a-vis year 2006 209 victims. Karapatan also reported 16,307 human rights violations just for 2007 (which include killings to forcible displacement of communities). Therefore, aside from the 887 killings since 2001 under Mrs. Arroyo, Karapatan, just for 2007, underscored 35 victims of political killings; 26, of enforced or involuntary disappearance; 8, of abduction; 29, of torture; 129, of illegal arrest; 116, of illegal detention; 330, of threat, harassment and intimidation; 7,542, of forcible evacuation or displacement, 3,600, of “hamletting”, interalia. As only solution, it petitioned the resignation of Mrs. Arroyo.[77] (with 356 left-wing activists murdered). The Philippines armed forces battled the Communists since 1969, with about 40,000 victims killed, and it had to ward off killings by Muslim radicals.[78]However, Justice Undersecretary Ricardo Blancaflor, head of Task Force on Political Violence contradicted Karapatan's

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submission only on the number of killings. PNP's Task Force Usig, according to Blancaflor noted only 141 cases, of which, only 114 are party list members or leftist activists.[79]

On December 13, 2007, Philippine Human Rights Commissioner Dominador Calamba III, at the Philippine Working Group for an Asean Human Rights Mechanism forum denounced the failure of the government in its treaty reporting to the United Nations, due to "13 reports overdue." (reports due on implementation of international covenants signed by the Philippines to solve discrimination, forced disappearances and extrajudicial killings). Calamba reported 383 killings filed with the CHR, of which 145 were extrajudicial or political in form.[80]

On January 1, 2008, the National Union of Journalists (NUJ) paid tribute to 171 journalists killed in 2007. Citing data published byInternational Federation of Journalists: Iraq was number one, with 65 deaths; in the Philippines, 6 journalists killed on 2007 were Hernani Pastolero (Sultan Kudarat), Carmelito Palacios (Nueva Ecija), Dodie Nunez (Cavite), Geruncio "Oscar" Mondejar (Mandaue), Vicente Sumalpong (Tawi-Tawi) and Fernando "Batman" Lintuan (Davao City); 54 journalists were murdered under the administration of President Gloria Macapagal-Arroyo. In 2006, INSI stated that the Philippines was the 2nd most dangerous country for journalists, next to Iraq , listing 15 work-related journalists murdered.[81] On January 4,2008, the International Federation of Journalists (IFJ) Asia-Pacific director Jacqueline Park denounced the murders of broadcasters Fernando Lintuan in Davao City and former journalist Romelito Oval, Jr. It petitioned the Philippine government to fully investigate 2007 journalists' killings: "5 journalists as well as Oval were killed in the Philippines in 2007, which is shocking and reveals the extreme dangers that journalists face every day in trying to carry out their work. There will be no press freedom in the Philippines until this (situation) changes."[82]

On January 4, 2008, Anakpawis Rep. Crispin Beltran filed House Resolution 299 with the House of Representatives of the Philippines to investigate the murders and harassment of trade union / labor leaders in the Philippines. He cited the 2007 annual Survey of Trade Union Rights Violations of the International Trade Union Confederation: "33 of the total 144 cases of trade union killings worldwide happened in the Philippines; and 800 cases of beatings and torture of trade unionists in the country."[83][84]

On January 9, 2008, PNP Task Force Usig announced that 3 policemen, 11 soldiers and 3 militiamen had been arrested or named suspects in killings of media men and militants since 2001. Director Jefferson P. Soriano submitted the report with the 17 names to PNP chief Avelino Razon. As ofDecember 10, TF Usig prosecuted 113 killings cases of party-list members, leftist activists and 27 journalists.[85]

- 14 -

Twin horrible deaths happened on / circa the same day last year, January 15, 2007, that the Supreme Court of the Philippines' (logo or seal) was mysteriously burned into halves by an almost one hour afternoon fire.[86][87] Despite different appeals by local and international groups, the spate of extrajudicial killings in the Philippines continued. On January 15, 2008, Reynato Puno condemned the murder of Judge Roberto Navidad, Regional Trial Court, Branch 32, Calbayog City, Samar, the 15th judge to be ambushed since July 20, 1999, the 14th under the Arroyo government. Just starting his engine, black Nissan Patrol SUV ( TPL-911), Natividad was shot in the face / left eye, at 7:10 p.m. Monday, by a lone gunman, 5’4" tall and medium-built, wearing black jacket, using a 45 caliber pistol.[88] On Tuesday, Catholic missionaryRey Roda, Oblates of Marry Immaculate (OMI), 54, was shot dead at 8:30 p.m., when he resisted abduction attempt by unidentified 10 armed men in a chapel at ikud Tabawan village, South Ubian, Tawi-Tawi, South Ubian . In February 1997, another OMI leader, Bishop Benjamin de Jesus was shot dead in front of the Jolo cathedral .[89] In 2006, the Asian Human Rights Commission stated that there had been 26 priests, pastors, and churchmen who were liquidate or were victims of violence under the Gloria Macapagal-Arroyo administration since 2001.[90] This includes 3 priests who were reported killed just in 2007: Basilio Bautista of the Iglesia Filipina Reform Group, in Surigao del Sur, Indonesian priest Fransiskus Madhu, in Kalinga province, and Catholic priest Florante Rigonan, in Ilocos Norte.[91] OnJanuary 19, 2008, the Catholic Bishops Conference of the Philippines (quoting from a letter of Vatican Secretary of State Cardinal Tarciso Bertone), announced that PopeBenedict XVI "praised the courage of, and was saddened over the brutal and tragic killing of Fr. Reynaldo Roda in his ministry as head of Notre Dame School." The Pope wrote Jolo Bishop Angelito Lampon: "calls upon the perpetrators to renounce the ways of violence and to play their part in building a just and peaceful society, where all can live together in harmony."[92]

On January 16, 2008, the New York-based international democracy watchdog Freedom House dropped or relegated the "freedom status" of the Philippines to partially free from a list of totally free countries. It based its Philippine status downgrade on the spate of political killings, "specifically targeting left-wing political activists in the country, freedom in the sloped downward."[93]

On January 18, 2008, the Kilusang Magbubukid ng Pilipinas (KMP), led by KMP chairman Rafael "Ka Paeng" Mariano (president of the Anakpawis), condemned the January 12kidnapping and January 16 extrajudicial killing and torture of their farmer and local leader Teldo Rebamonte, 45, Masbate People’s Organization (who was supposed to join the commemoration of the Mendiola Massacre) in Barangay Nabasagan, Concepcion in Claveria, Burias Island, Masbate.[94]

On January 23, Karapatan announced that the 2 latest victim of extra-judicial killings were: Tildo Rebamonte, 45, a Claveria,Masbate carpenter, who was gunned down on January 16, 4 days after he was allegedly kidnapped by the Philippine National Police’s Regional Mobile Group; and ex-political prisoner Ronald Sendrijas, 35, who was shot dead in Tagbilaran City, Bohol on January 17.[95]

On January 23, 2008, (or in just 9 days after the murder of a priest) Pastor Felicisimo Catambis, 60, of the United Church of Christ in

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the Philippines (UCCP) in Catugan, Barangay (village) Balucawe, Leytetown was shot dead by a still unknown assailant.[96]

Culpable  violation of - the Constitution, Canon of Judicial Ethics, the Rule of Law, R.A. 3019, Rules 140, 139-B, 138, Rules of Court, Canon of Professional Responsibility, Canon of Ethics for Court Personnel

         Respondent Judge Thelma, in conspiracy with broker and court fixer,

respondent Joson, allowed her hands to be locked and tied, due to the P

80,000 cash pay-off (by Mr. Alfred Trinidad, son of LRC petitioners

therein, the Spouses Alfredo and Florentina Trinidad, who were both very ill

with massive stroke, inter alia, which money was badly needed at the time

Judge Thelma’s husband suffered METASTASIS and died, circa 2004/5).

Shocking to the conscience of the courts, Judge Thelma culpably violated

the Constitution which she swore as lawyer and later as Judge, to obey,

defend and implement, in the end that she would not delay a man’s /

litigant’s cause for money, inter alia. Petitioner cites the fundamental law:

“Section 15. (1) All cases or matters filed after the effectivity of this Constitution must be decided or resolved within twenty-four months from date of submission for the Supreme Court, and, unless reduced by the Supreme Court, twelve months for all lower collegiate courts, and three months for all other lower courts.  (2)A case or matter shall be deemed submitted for decision or resolution upon the filing of the last pleading, brief, or memorandum   required by the Rules of Court or by the court itself.  (4) Despite the expiration of the applicable mandatory period, the court, without prejudice to such responsibility as may have been incurred in consequence thereof, shall decide or resolve the case or matter submitted thereto for determination, without further delay.”

 

Precedents

 

           On December 16, Celestino’s siblings, Nelson and Amelia, filed a

motion seeking a writ of amparo on behalf of their brother, who they said

was illegally arrested without a warrant at the NAIA when he arrived to take

his flight. The court issued a temporary protection order for Celestino, who

was arrested at the Ninoy Aquino International Airport on December 5 as he

was about to leave for Virginia , USA , where a job as a lifeguard awaited

him. They claimed he was also being pressured to replace his lawyer,

Reynaldo Robles, with another lawyer “who will readily cooperate with the

government.”

- 16 -

(Court takes up ex-Marine’s amparo plea, January 22, 2008, DJ Yap - Philippine Daily Inquirer)http://www.inquirer.net/specialfeatures/makatistandoff/view.php?db=1&article=20080122-113941

          On January 15, 2008, The Supreme Court has issued a writ of amparo

to activist priest Fr. Robert Reyes to stop alleged harassment by the

government and ordered Justice Secretary Raul Gonzalez and Immigration

Commissioner Marcelino Libanan to make a verified return, or an official

report in response to the writ, with the Court of Appeals by January 24. The

appellate court was also tasked to hear the petition on January 25 and decide

the case within 10 days after it is submitted for decision.

However, what the priest wanted was “blanket removal” of the hold

order which the justice secretary said was not possible as “there is still a case

against him.”

The writ of amparo provides remedies to a person whose rights to life,

liberty and security are violated and threatened. The writ requires

respondents—whether government officials or agencies, or private

individuals—to take action to resolve a grievance and not merely deny the

allegation against them. 

(Court heeds ‘running priest’s’ plea for amparo - By Jerome Aning - Philippine Daily Inquirer - 01/20/2008)

http://newsinfo.inquirer.net/inquirerheadlines/nation/view/20080120-113530/Court-heeds-running-priests-plea-for-amparo

 Critical Facts – Detailed narration of bribery, pay-off, and the consequential refusal by respondents Judge Thelma and Joson to release the Decision long overdue since 2004  / 2005

 1. Consolidated cases C.C. No. 938-M-98 and P-405-98 were filed on

September 28 / 29, 1998 by petitioner with Brs. 9 and 19, RTC, Malolos,

Bulacan; the parties submitted to the court – stipulations of admitted exhibits

and facts with comments and objections, plus the direct testimony of

undersigned in 1998;

 

2. These cases were raffled initially in 1998 to Brs. 9, 19, 80 and in 2004

to Br. 16, where they were tried, heard and submitted for decision on

September 22, 2004 and June 17, 2005; (certified copies of the Orders

dated September 22, 2004 and June 17, 2005, issued and signed by

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respondent Judge Thelma are attached as Annexes C and C -1, respectively

hereof);

3. On February 24, 2005, respondent Judge Thelma dismissed all these 2

consolidated cases upon motion by Atty. Nye Orquillas (counsel of the LRC

petitioners spouses Alfredo and Florentina Trinidad; this counsel

maliciously caused the loss of the case of his clients Trinidads; petitioner,

twice reserved his right to file disbarment case against said attorney), due to

alleged non-payment of docket fees by undersigned on amended complaint

filed on  1998 / 1999; but the respondent Judge Thelma found her glaring

error; ergo, she rectified the same, reversing herself, thereby granting

undersigned’s Motion for Reconsideration, giving undersigned reasonable

time to pay docket fees on the amended complaint - Interlocutory Order of

September 7, 2005; (certified copies of the Orders dated February 24,

2005 and  September 5, 2005, issued and signed by respondent Judge

Thelma are attached as Annexes D and D-1, respectively, hereof);

 

4. Undersigned filed an administrative case against Mrs. Lerida Socorro

Joson and the 3rd Division Supreme Court rendered a FINAL JUDGMENT

(dated March 8, 2006) against her, and in favor of undersigned in A. M.

OCA IPI No. 05-2157-P:

“To REMINDS respondent OIC Mrs. Lerida Socorro-Joson to BE MORE CIRCUMSPECT and PRUDENT in the discharge of her duties ….”

 

(Copy of page one of the pertinent A. M. OCA IPI No. 05-2157-

Ppleading filed by undersigned is attached as Annexes E hereof, for

reference; undersigned reserves the right to submit in due course, copy of

the 3rd Division’s above-cited resolution ); 

5. Respondent Judge Thelma, knowing the glaring mistake, and knowing

that she rendered the foregoing   UNJUST resolutions   in violation of the

Revised Penal Code / the Canons of Judicial Ethics, inter alia,   reversed

herself for the second time: undersigned submitted certified copies of

document - parts of the records, which proved payment of docket and all

legal fees on the subject amended complaint; in the Order dated 22 October,

2007, respondent Judge Thelma ruled that undersigned really paid the docket

fees and instead of deciding the cases, she set the same for hearing on

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November 22, 2007. Certified copy of the Order dated 22 October, 2007,

issued and signed by respondent Judge Thelma is attached as Annexes

F  hereof);

 

6. Meanwhile, undersigned, by accident discovered the graft and

corruption perpetrated at Br. 16, RTC, Malolos, Bulacan, to wit:

 

a)     When undersigned paid a picture frame at Maunlad Mall I

and II, Poblacion, Malolos, Bulacan, many stall holders

complained about the Pulumbaret case where they denounced

the corruption at Br. 16, RTC, Malolos – P 2.0 million pay-

off  and monthly cash pay-offs to respondents, regarding the

rentals in the controversial mall case; however, undersigned

failed to get any hard evidence (which can be  subject of an

NBI entrapment case, which under settled jurisprudence, is the

only mesne process to indict a Judge for bribery; Vide: case of

Valenzuela RTC, Judge Jaime Bautista; and it is so

rare);  however, undersigned was able to communicate with the

complainants / a Bank regarding the immense corruption

perpetrated on 2004 / 2005, regarding Br. 16, RTC, Malolos,

Bulacan, including alleged “loans” from litigants / lawyers,

brokered by respondent Joson for the terminally ill (metastasis)

husband of Judge Thelma’ medical bills, which ballooned …;

unfortunately, the Bank’s complaint was dismissed on technical

grounds. Copy of the Resolution dismissing the case against

respondent Judge Thelma is attached as Annex G hereof;

b)    After Judge Thelma dismissed undersigned’s case per Order

dated February 24, 2005, in OPEN COURT, she begged to

unload these cases   on the ground that her court was designated

as Family Court; but undersigned objected vehemently, since

she already heard, tried and finished the case, and was

mandated to issued the decision long overdue since December,

2004 and September, 2005, per her orders of submission for

decision (Annexes C and C -1, respectively hereof); respondent

Joson, due to the pay-off, refused to include these consolidated

civil / LRC cases as those submitted for decision in her monthly

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and other reports required by the OCAD, despite repeated

written demands by undersigned and despite the administrative

case’s above-cited Resolution which directed her to comply

with the rules and circulars, to the damage and prejudice of

undersigned;

 

c)     When Ms. Belen Gomez (Alido, Malolos, Bulacan) was

ordered by undersigned to clear the fighting cocks and dirt at

the road right-of-way of the subject land of those consolidated

cases (owned by undersigned at Calvario, Meycauayan,

Bulacan), Mr. Alfred Trinidad (son and representative of the

MASSIVE stroke patient therein LRC petitioner Alfredo

Trinidad and his spouse co-petitioner very ill Mrs. Florentina

Trinidad) demanded P 80,000 reduced to P 60,000 from

undersigned (per verbal request / imposition to Belen Gomez at

a merienda in Jolibee, Poblacion, Meycauayan, Bulacan, last

year) as causa / consideration, for removal of the interference /

nuisance; Mr. Alfred Trinidad stated that “Yan ang nagastos

namin sa kaso” – stating in no uncertain terms the pay-off to

respondents / co-conspirators, Br. 16, RTC, Malabon’s OIC,

Mrs. Lerida Socorro Joson as front, and counsel Atty. Nye

Orquillas (who merely filed a 10 pages Motion to Dismiss, at

that time);

 

d)    Because of the pay-off of P 80,000, undersigned’s 1998

submitted cases could not be decided despite repeated written

and verbal motions to promulgate / release the decision due

since 2004 / 2005;

 

7. In violation of the Code of Professional Responsibility and with

palpable conspiracy, Atty. Irineo E. Guardiano, (the new counsel for therein

defendants spouses Mariano and Ligaya Blancos) blocked the release of the

decision to cover-up and protect the clear falsification of the certificates of

services of respondent Judge Thelma: Atty. Guardiano filed 2 sham and

false motions a) which asked the court AGAIN to dismiss these cases on the

GROSS IGNORANCE of the law ground that undersigned did not indicate

his P.T.R. in the pleadings; undersigned called the attention of respondent

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Thelma that undersigned appeared as LITIGANT / petitioner and not as

lawyer, and he never practiced law since November 5, 1998 when he was

appointed Judge; asking for time to reply and given time by the court, Atty.

Guardiano did not reply but instead b) asked the Court to order undersigned

to file FORMAL OFFER OF EVIDENCE; however, undersigned called

again the attention of respondent Judge Thelma that i) she herself admitted

all the Exhibits A to I / sub-markings of petitioners / undersigned, which

were formally offered with purposes and she ordered these cases

submitted for decision on June 17, 2005 and September 22, 2004and

even ordered all defendants to have waived their rights to present

evidence (Annexes C and C -1); and ii) the P 80,000 pay-off through Mrs.

Lerida Socorro-Joson and iii) the 2 legal, written and filed reservations to

file administrative and disbarment cases against the two co-conspirators,

the Fiscal and the new lawyer – to cover-up the a) falsification of the

certificate of service and b) non-release of decision as of September 22,

2004 /June 17, 2005; Copies of the sham and false pleadings filed by Atty.

Ireneo E. Guardiano, co-conspirator of respondents, are attached as Annexes

H and H-1, hereof;

8. At the last hearing of the subject consolidated cases, respondent Judge

Thelma denied undersigned plea to issue an order directing the issuance of

the decision; instead she again and again and again, ordered ONLY the

incidents, that is, the Omnibus Motions and the Motion to Issue Decision

filed by undersigned, merely submitted for decision; respondent Judge

Thelma miserably failed also to resolve undersigned’s pending motions for

more than one year; Duplicate original of the last order dated January  , 2008

issued by respondent Judge Thelma is attached as Annex I hereof.

9. At the hearing dated 13 September, 2004, respondent Judge Thelma

issued an Order which ruled that petitioner’s Exhibits A to I / sub-markings

were duly admitted after Formal Offer of Evidence. Copy of said Order is

attached as Annex I-i hereof;

 

10.  Petitioner also submitted copy of his P.T.R. No. 0005034, dated

January 11, 2007, P 300, Malolos City , Bulacan, even if he never practiced

law, just to put to finish any technicality. Copy of this P.T.R. is attached

as Annex K hereof;

 

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11.  On December 17, 2007, petitioner filed with respondent Judge

Thelma’s court, a 16-pages Opposition to the sham and false dilatory

Motions filed by respondent Judge Thelma’s co-conspirator, defendant

spouses Blancos, per Atty. Irineo E. Guardiano. Copy of this pleading is

attached as Annex K-1 hereof;

 

12.  On January 17, 2008, petitioner filed with respondent Judge Thelma’s

court, a 16-pages Verified Rejoinder to the sham and false

dilatory Manifestation and Comment to Opposition, filed by respondent

Judge Thelma’s co-conspirator, defendant spouses Blancos, per Atty. Irineo

E. Guardiano. Copy of this pleading is attached as Annex L hereof;

A model for all

          The judiciary and the entire nation is watching. What becomes of this

case will become a model for other courts and other lawyers, litigants, jurists

and even law students, aspiring to be counsels, in the same situation.

          Ultimately, the decision that will be handed by our courts and this

Court in this landmark case of first impression to STOP a Judge and her

clerk of court from continued and unending THREATS / culpable violation

of the Constitution / mockery of justice / contempt of the Temples of Justice.

This case / its outcome will influence the future of democracy in our

country: Can a case be purchased by cash down payment and cash

installments?  I know that if we do nothing, we help destroy freedom, the

judicial institution, not only the property but the very life, liberty and destiny

of Malolos City , Bulacan litigants, the bench and the bar, in the Bulwagan

ng Katarungan. That is why I came to this Court today.

        This case is being watched all over the world, the nation, and perhaps,

tomorrow by the world, by Latin American Amapo countries.

         I state with certainty that this case is “compelling” because the

respondents had been “using the strong arm of the law to censor, oppress

and intimidate the petitioner, to permanently stop and delay the subject

civil / LRC cases, and respondents will continue to do so unless this Court

intervenes and stops them.

          These are uncertain times for the judiciary. Unless we do something

about it, the next crisis situation will see journalists, lawyers, judges, and

litigants being killed not only in the open field but in the courtroom itself,

like today:

- 22 -

“Man shoots three; takes hostages in Manila City Hal; Ex-mayor killed in Manila courtroom shooting; gunman escapes

           A man has reportedly shot a former mayor and two other people in Manila City Hall and took hostages while inside an elevator. An initial report from radio dzMM said a lone suspect seized a gun from one of the jailguards and shot Yap and his bodyguard, Peter

Villanueva. Another victim, Bella Santos, was also shot on the foot, in the fourth floor of the Manila City Hall Tuesday.  After the shooting, the unidentified assailant took hostages while inside an elevator. It was not yet clear how many hostages were inside the elevator. Reports said the former mayor was in Manila City Hall to attend a hearing in Manila Regional Trial Court Branch 19. Yap was found guilty of killing former mayor Victorio “Boy” Cebedo of Rizal, Zamboanga del Norte, before the 1992 local elections, and was sentenced to life imprisonment. Yap was reportedly a known political rival of the Cebedo family. In 2007, the Court of Appeals reversed the ruling and ordered Yap 's release, citing conflicting accounts of the shooting. Yap has other pending cases.

(Abs-Cbn Interactive, January 29, 2008)

http://www.abs-cbnnews.com/topofthehour.aspx?StoryId=107235

‘Barrage of threats’

         This Amparo petition is urgent “because the respondents Judge

Thelma and Joson have unleashed a barrage of threats and warnings against

petitioner’s - JUDICIAL LIBERTY, FREEDOM, and destiny of petitioner,

since the subject property is his own ancestral home / house and lot where he

was born on November 5, 1953, where he grew and was persecuted by

respondents since 2004 - although silent, and be viewed only from the

annexed pages, parts of the lower court’s expediente. Petitioner noted the

threats came right after respondents received the subject consolidated cases,

and specifically upon their receipts of the P 80,000 pay-off/s in 2004 / 2005,

the Alfred Trinidad “fighting cock” incident.

Public’s right to know

       Threats are easy to make. When the respondents received the cash pay-

offs, they make threats, and this is even more problematic because they

have the coercive power to back those threats, specifically, the records /

annexes hereof, carved from respondents’ records below, prove beyond

reasonable doubt, these THREATS, which are VIRTUAL REALITY in law

and in fact.

         More than judicial freedom, this case is about the right of the people,

the bench, the bar, and litigants, to information. The public / litigants suffer

- 23 -

when the information / DATA, about these pay-offs they need could not be

provided from respondent court, because of threats, censorship and prior

restraint, due to clear and present danger of FEAR of further piece-meal

VENDETTA in the subject cases.

          The supplemental Writ of Habeas Data (which can be availed of by

petitioner on its effectively on February 2, 2008) will truly reveal per

HAVING DATA from Mr. Alfred Trinidad, the specifics of the P 80,000

pay-off:that is – the breakdown – HOW MUCH DID RESPONDENTS

JUDGE THELMA AND JOSON RECEIVED AS GREASE MONEYS

AND HOW MUCH WAS THE PERCENTAGE / ATTORNEY’S FEES OF

ATTY. NYE ORQUILLAS ? The truth will be unveiled upon issuance of

the peremptory writ of Habeas Data, in due course.

Litigants’ / judicial rights disregarded

          Without this Honorable Court’s urgent intervention, petitioner, the

bench, the bar, litigants, journalists, will suffer grave injustice and

irreparable injury from acts that are plainly against the Constitution, since

there will be no more faith in Bulacan courts, due to magicians, brokers,

fixers, cardiologists, and more importantly, in respondents’ FAMILY court,

respondents’ threats of selling decisions / resolutions would convert the

lower court trials to farce, or moro-moro so to speak, forcing litigants to run

nowhere to, but to practice EXTRA-JUDICIAL KILLINGS and

DESAPARECIDOS.Judge Floro demands the resignation of Judge Thelma and ouster of broker, respondent Joson, to stop the E-J Killings and Abductions 

          The respondents’ blatant disregard of the rights of litigants / petitioner,

especially their treatment of petitioner as BEGGAR in the court, pleading,

filings motions, appearing in hearings, participating in trials since

September, 1998 until January, 2008, without even the single appearance of

any adverse parties / defendants therein, calls for the exercise by this

Honorable Court of its power of supervision to protect basic rights and

freedoms.

         Respondent Judge Thelma is no longer dispensing justice, but is

engaging in censorship and prior restraint of court pleadings, trials, orders

and NO JUDGMENTS orders, when there is pay-off -- areas that

respondents must respect, not invade, under our Constitution. Litigants are

tired of “paralyzing divisions, corruptions and moral bankruptcy” in the

judicial department, more importantly in RTC, Bulacan. Petitioner is utterly

confident that this Honorable Court would take a look into this and try to

- 24 -

bring about the closure of these consolidated cases because the general public

and all of us are still waiting for some genuine REPENTANCE on the part of

respondents, considering the dire pains of CANCER of her husband on 2004 /

2005, and the following DIRE PROPHECIES fulfilled on these consolidated

cases, to wit:

 Timeline – Dire Prophecies

Br. 9, RTC, Malolos, Bulacan +Judge Roy D.

Masadao (first Judge that handled the instant lower court case C.C.

No. 938-M-98, September, 1998)  fell on a horse and failed to finish

his gubernatorial campaign in Tabuk, Kalinga Apayao;

+Atty. Rafael Santos, first counsel of record of defendants

in subject consolidated cases before herein respondents - LRC P-405 /

C.C. No. 938-M-98 died during the pendency of these cases before

Br. 80, RTC, Malolos, Bulacan, before Judge Cesar Casanova;

Judge Cesar Casanova’s +mother died of lingering illness

due to METASTASIS when petitioner’s motion was denied;

Defendants’ spouses Mariano and Ligaya Blanco’s Eastern

Tanning Tannery at Bancal, Meycauayan, Bulacan, was burned and

uninsured, the spouses lost P 100 million; his brother Mayor Tinoy

Blanco was disqualified, while Mariano / Tinoy Blanco lost the

Meycauayan, Elections twice;

Respondent Thelma’s +husband died of CANCER, 2004 /

2005, long illness;

Br. 9, RTC, Malolos, Bulacan +Judge Roy D.

Masadao died of CANCER on 2005, when respondent Judge Thelma

received the pay-offs and delayed petitioner’s cases

       Petitioner begs this Court pursue relentlessly the truth behind the “P

80,000 pay-off to respondents Judge Thelma and Joson” scandal. The events

warned that the judiciary could ill afford another similar controversy.

Moral bankruptcy

      That the judicial order is accused too often of moral bankruptcy with

nary an exception is a sad sign of the general cynicism and frustration of our

nation. Most unfortunately, there does not seem to be any way of achieving

closure. For the process and results of standard democratic and

judicial inquiries, sometimes including those by higher Courts, are received

with skepticism and cynicism. We have to confess that corruption is in truth

our greatest shame as a people. Corruption was / is “at its worst,” leading

- 25 -

to extrajudicial executions of judges, the latest of which is the January 15,

2008 murder of Judge Navidad, and petitioner’s very own clerk of court,

Br. 73, RTC, Malabon, former PAO and incumbent Fiscal Julio Taloma, was

gunned down in Petitioner’s home town, Meycauayan, Bulacan, on 2005.

Same old problems

         They are the same old problems, or variations of them, which have

been plaguing our nation and Bulacan for years on end, through successive

political and judicial administrations.

         Nothing or very little seems to have been done about them. In them we

see the all too patent subordination of the common good to private good.

Putting oneself before the interests of the general public had been the “basic

fault” in the country’s political and judicial culture: when respondent Judge

Thelma’s husband was sick and needed huge sums for metastasis treatment,

respondent Joson acted as broker, ranging from loan activities to selling

court orders. Petitioner is just ONE of their victims.

           The persistence of that deep-seated fault pushes us to conclude in

sorrow that we as a people are still devoid of a real social conscience.

COUNT the cases of graft and corruption in the OCAD, OMBUDSMAND,

SANDIGANBAYAN, etc., etc., etc. Never mind the SWS surveys, just stick

to the SCRA reports on dismissals of government employees. And now, we

are shocked with Malaya ’s Jake Macasaet’s P 10 million bribery – contempt

case, to wit:

“P 10 million bribery controversy

          “On September 24, 2007, Ynares-Santiago denied charges that she received P10-million (US $ 224,000) bribe money (as published by The Daily Tribune, Malaya newspaper's Amado Macasaet and Newsbreak, the previous week). Santiago declared: “At the outset, let me underscore that these are blatant lies clearly aimed at smearing and maligning my character and person, and the integrity of the Judiciary, which I have been faithfully serving for 34 years now.”        Santiago asked Chief Justice Reynato Puno for an investigation. Macasaet’s column alleged that the P 10-million money was put in 1 of 5 gift boxes and left at the court's guardhouse. Santiago 's staff Daisy Cecilia Muñoz Delis (niece of the late Associate Justice Cecilia Munoz-Palma) personally got and opened the package and delivered it to Ynares-Santiago. Delis was dismissed (but she denied, stating she resigned on March 15), gave Justice Santiago her affidavit and Macasaet's letter.[1] [2] [3

        Newsbreak online published that the payoff dealt with 2 lawsuitswhich Santiago decided: "HENRY T. GO vs. 5th Div. Sandiganbayan", G.R. No. 172602, SPECIAL THIRD DIVISION , September 3, 2007, [4][5]and the

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Maysilo estate. Supreme Court of the Philippines Reynato Puno was forced to include this bribery matter for deliberation (in the September 25 en banc session) based on petition of 4 other incumbent lady justices.[6] [7][8]

[9] Senator Miriam Defensor-Santiago accused another Supreme Court of the Philippines justice of smear campaign against Consuelo Ynares-Santiago (to urge her to inhibit from a multi-billion peso 34-hectareMaysilo-Araneta University land case). Ynares-Santiago's decision awarded the land to Homer Barque, represented by counsel Felix Carao Jr. [10] The Court issued an indirect contempt indictment directing Macasaet to substantiate his published claims.[11]

A.M. No. 07-09-13-SC

             In the promulgated resolution dated September 26, 2007, the court ruled: "Upon evaluation of the column ‘Business Circuit,’ of Amado Macasaet in the September 18, 19, 20, and 21, 2007 issues of Malaya, it appears that certain statements and innuendoes therein tend, directly or indirectly, to impede, obstruct, or degrade the administration of justice within the purview of Section 3(d), Rule 71 of the 1997 Rules of Civil Procedure." Macasaet was ordered "to shed light on his claim against Santiago because the accusations have degraded the high court, and to explain where he obtained his information that Santiago was allegedly offered a P10-million bribe." [12] [13] [14] [15]

         On October 1, 2007, Macasaet filed a 28-page reply-explanation to the contempt charges. Macasaet stated that he wrote his column to call for an investigation and to preserve the integrity of the Court: "the investigation on his alleged liabilities is not only unsettling but signals a chilling effect on free speech; Yet, without that call (for an investigation), truth would be not exposed to the scalding light of public inquiry." [16]

         On November 13, 2007, the Court accepted both the resignation and inhibition / disqualification of retired Supreme Court Justices Vicente V. Mendoza and Romeo J. Callejo, Sr., as members of the Investigating Committee, leaving Justice Carolina Grino-Aquino as lone member / Chair (as the trial was set for November 8 and 29). The Aquino team asked Macasaet to name his source on the alleged payoff, but the publisher refused and invoked Republic Act 1477 or “the right not to reveal a journalist’s source unless national security is at stake,” and further alleged that the Santiago case pertains to bribery, a criminal issue. Consuelo Ynares-Santiago allegedly made “enemies” in the High Court, starting with retired Chief Justice Artemio Panganiban, as a result of Macasaet’s allegation.[17]

[18]”

http://en.wikipedia.org/wiki/Consuelo_Ynares-Santiago

13.  To repeat, petitioner JUDGE FLORO MUST BE GIVEN

PROTECTIVE ORDERS since the P 80,000 pay-off is a permanent barrier

to stop at all costs any attempt to release the decision since Br. 16 is

committed to the payors of the grease money;

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14.  Without any Order from this Court, the extra-judicial killings and

desaparecidos will not only multiply but will invite other dire pains to the

judiciary. Undersigned respectfully awaits JUST ORDERS from this Court

emanating as interim reliefs from the Writ of Amparo in due course

and Habeas Data to exorcise Br. 16, RTC, Malolos, and the notorious

“MAGICIANS, CARDIOLOGISTS, brokers of Latian, Marilao,

Bulacan”, inter alia, at RTC, Malolos, Bulacan.

15.  The pertinent rules, circulars and laws violated by respondents are

cited hereunder for reference purposes:

                

“A.M. NO. 01-8-10-SC- RE:   PROPOSED AMENDMENT TORULE 140 OF THE RULES OF COURT RE:  DISCIPLINE OF JUSTICES AND JUDGES - The Court resolved to APPROVE the amendment of Rule 140 of the Rules of Court regarding the discipline of Justices and Judges, so as to read as follows:

 

RULE 140 - DISCIPLINE OF JUDGES OF REGULAR AND SPECIAL COURTS AND JUSTICES OF THE COURT OF APPEALS AND THE SANDIGANBAYAN

 SEC. 8. Serious charges. – Serious charges include: 1. Bribery, direct or indirect; 2. Dishonesty and violations of the Anti-Graft and Corrupt Practices Law (R.A. No. 3019); 3. Gross misconduct constituting violations of the Code of Judicial Conduct; 4. Knowingly rendering an unjust judgment or order as determined by a competent court in an appropriate proceeding; 7. Borrowing money or property from lawyers and litigants in a case pending before the court; 9. Gross ignorance of the law or procedure;SEC. 9. Less Serious Charges. – Less serious charges include:

1.        Undue delay in rendering a decision or order, or in transmitting the records of a case; 4. Violation of Supreme Court rules, directives, and circulars; 6. Untruthful statements in the certificate of service;

SEC. 11. Sanctions. – A. If the respondent is guilty of a serious charge, any of the following sanctions may be imposed: 1. Dismissal from the service, forfeiture of all or part of the benefits as the Court may determine, and disqualification from reinstatement or appointment to any public office, including government-owned or controlled corporations. Provided, however, that the forfeiture of benefits shall in no case include accrued leave credits; 2. Suspension from office without salary

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and other benefits for more than three (3) but not exceeding six (6) months; or 3. A fine of more than P20,000.00 but not exceeding P40,000.00 B. If the respondent is guilty of a less serious charge, any of the following sanctions shall be imposed: 1. Suspension from office without salary and other benefits for not less than one (1) nor more than three (3) months; or 2. A fine of more than P10,000.00 but not exceeding P20,000.00.These amendments to Rule 140 shall take effect on October 1, 2001 following their publication in two newspapers of general circulation on or before September 15, 2001.CODE OF JUDICIAL CONDUCT - CANON 3A JUDGE SHOULD PERFORM OFFICIAL DUTIES HONESTLY, AND WITH IMPARTIALITY AND DILIGENCEADJUDICATIVE RESPONSIBILITIESRULE 3.01 - A judge shall be faithful to the law and maintain professional competence. RULE 3.02 - In every case, a judge shall endeavor diligently to ascertain the facts and the applicable law unswayed by partisan interests, public opinion or fear of criticism. RULE 3.05 - A judge shall dispose of the court's business promptly and decide cases within the required periods.

CANON 10 - A LAWYER OWES CANDOR, FAIRNESS AND GOOD FAITH TO THE

COURT. CODE OF PROFESSIONAL RESPONSIBILITY (June 21, 1988) Rule 10.01 - A lawyer shall not do any falsehood, nor consent to the doing of any in Court; nor shall he mislead, or allow the Court

to be misled by any artifice.  Rule 10.02 - A lawyer shall not knowingly misquote or misrepresent the contents of a paper, the language or the argument of opposing counsel, or the text of a decision or authority, or knowingly cite as law a provision already rendered inoperative by repeal or amendment, or assert

as a fact that which has not been proved.  Rule 10.03 - A lawyer shall observe the rules of procedure and shall not misuse them to defeat the ends of justice.

1997 Rules of Civil Procedure:RULE 7 - PARTS OF A PLEADINGSec. 3. Signature and address.Counsel who deliberately files an unsigned pleading, or signs a pleading in violation of this Rule, or alleges scandalous or indecent matter therein, or fails to promptly report to the court a change of his address, shall be subject to appropriate disciplinary action.”

  

RELIEF 

            IN THE LIGHT OF THE FOREGOING, it is

respectfully prayed that the instant -Verified Petition for Issuance of Writ of Amparo / Affidavit

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[With Prayer To Issue Interim Reliefs of Temporary Protection Order, Inspection Orderand Production Order under Sec. 14, A.M. No. 07-9-12-SC as amended by A.M.

No. 07-9-12-SC, and Legal Reservation of the Right to File Supplemental Petition for Habeas Data(effective on February 2, 2008), and Separate

Administrative, Criminal and Civil Casesagainst Respondents and co-conspirators, under Sec. 21]

And – Urgent Prayer   for   Immediate Resolution

 

be duly noted, DOCKETED, given due course   and   granted . It is finally

prayed that the matter be IMMEDIATELY RESOLVED in view of its

importance and merit. It is finally prayed that Judge Pinero-Cruz and Mrs.

Lerida Socorro-Joson be directed to file   COMMENT   forthwith .

 

          In the interim, specifically, upon filing hereof, it is further prayed to

this Honorable Court that the peremptory Temporary Protection Order,

Inspection Order and Production Order under Sec. 14, A.M. No. 07-9-12-

SC as amended by A.M. No. 07-9-12-SC, be issued, a) ORDERING

respondent Judge Thelma Pinero-Cruz to cease and desist from further

acting in any manner to delay the promulgation of the Decision already due

since 2004 / 2005, in C.C. No. 938-M-98 and P-405-98, b) ORDERING her

toIssue the Decision in C.C. No. 938-M-98 and P-405-98 (Ordered by

hersubmitted for Judgment on September 22, 2004 and June 17, 2005 -

Annexes C and C -1) and c) ORDERING her to rectify her 2004, 2005,

2006, 2007 and latest 2008 falsified certificates of services, from said dates

until the cases’ Decision is released in accordance with the mandates of the

1987 Constitution, the Canon of Judicial Ethics and R.A. 3019, and

d) ORDERING the Branch Clerk of Court / OIC, respondent Mrs. Lerida

Socorro-Joson to obey the 3rd Division S.C. Decision against her, in A. M.

OCA IPI No. 05-2157-P - specifically to Order her to Include in

themonthly Reports, inter alia, the said Cases as

those submitted forDecision as of said dates ,   December, 2004 and

September, 2005.

 

      SPECIFICALLY, it is prayed to this Honorable Court, to Petition Chief

Justice Reynato Puno / Supreme Court, to appoint a Lawyer –Branch

Clerk of Court, for Br. 16, RTC, Malolos, Bulacan, and in the meantime

to detail / transfer respondent Mrs. Lerida Socorro-Joson to the OCC,

RTC, Malolos, Bulacan, in the interest of public service since she is abar

flunker, who is absolutely disqualified to be a legal researcher (thereby

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placing in jeopardy the destiny of litigants, detention

prisoners and thebar / bench, because of her gross ignorance of the law /

procedures and for having absolutely

tarnished the image of judiciary because of clear graft and corruption,

uncer R.A. 3019, violation of the Canons of Ethics for court

personnel and R.A. 6713, inter alia, in the end) –

TO STOP THE EXTRA-JUDICIAL KILLINGS and

DESAPARECIDOS; specifically, the 15th Judge Navidad and Fr. Rey

Roda were mercilessly gunned down on the very day/s of January 15 / 16,

2008 (when the Supreme Court’s Logo was halved by fire – 2007

January 15) (since the UN Philip Alston Report stated that litigants have

no more recourse since the courts are very corrupt according to

the 2005and 1995 twin SWS surveys, inter alia; and without even

mentioning the predicted FIRES that burned RTC, Malabon, except

undersigned’s sala onJanuary 22, 2000, and the prophesied Triple / Mystic

Fires that burned theentire 4th floor Court of Appeals, the halved logo of

the COMELEC and the Muntinlupa MeTC court on 2007). (Annexes J,

J-1, “Timeline: Philippine Standout Events (2006-2007)”, WikiPedia

article created by petitioner is attached to prove his dire prophecies, 2006-

2007)

        It is finally prayed to this Honorable Court, to call the attention of

Chief Puno / Supreme Court regarding the existence of a) the Magicians,

b) Cardiologists, c) Latian – and the immense corruption practiced here

at RTC, Malolos City, which is shocking to the conscience of the judiciary.                    IN WITNESS WHEREOF, I signed this pleading – verified petition, this 29th day of January,     2008 , at Malolos City , BULACAN.

 Judge FLORENTINO V. FLORO, JR.,

Petitioner/ by himself, for himself, as litigant,123 Dahlia, Alido, Malolos, 3000 BULACAN, Tel/#(044) 662-82-03;

[I.D. Number:  RTCJ-317 / EDP Number: 38676300; ROLL OF ATTORNEY’S NO. 32800, Pg. No. 60, Book No. XIV].

  

NOTICE 

To: The Division Clerk of Court, Court of Appeals, Manila    Please AGENDUM / SUBMIT the instant Amparo Petition to

thePonente / Division to which this case is raffled forthwith in accordance with the mandates of A.M. No. 07-9-12-SC as amended by A.M. No. 07-9-12-SC immediately upon raffle and receipt hereof.

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Judge FLORENTINO V. FLORO, JR.,Petitioner

 

VERIFICATION and Certification of Non-Forum

Shopping /AFFIDAVIT OF SERVICE

  

REPUBLIC OF THE PHILIPPINES )Malolos City, BULACAN                   ) S.S.       I, Judge Florentino V. Floro, Jr., under oath, depose / say, that:            I am the petitioner in this case. I caused the preparation, signed and read the initial petition duly filed in this case and all the contents / allegations thereof are true and correct of my own personal knowledge or based on authentic records. 

                     I CERTIFY (a) that I have not theretofore commenced any action or filed any claim involving the same issues in any court, tribunal or quasi-judicial agency and, to the best of my knowledge, no such other action or claim is pending therein; A. M. OCA IPI No. 05-2157-P against respondent Mrs. Lerida Socorro-Joson was already decided with finality on March 8, 2006 and is no longer

pending; (b) if there is such other pending action or claim, I will file a complete statement of the present status thereof, but there is none; and (c) if I should thereafter learn that the same or similar action or claim has been filed or is pending, I shall report that fact within five (5) days therefrom to the court wherein his aforesaid complaint or initiatory pleading has been filed, and on January 29, 2008, I served copies of this pleading with all annexes in this case “Judge Florentino V. Floro, Jr. vs. Judge Thelma Pinero-Cruz and Mrs. Lerida-Socorro Joson”,  SP. No. ______, by registered mail with return card, upon respondents Judge Thelma Pinero-Cruz and Mrs. Lerida Socorro Joson, as proved by the registry receipts pasted hereunder on the original copy hereof, on page 25,  in accordance with Rule 13, Rules of Court. 

     

Judge FLORENTINO V. FLORO, JR., 

            SUBSCRIBED AND SWORN to before me, on this 29th day ofJanuary, 2008, hereat Malolos City , Bulacan, affiant exhibited to me his CTC NO. CC12005 # 21783592, issued at Malolos, Bulacan, on 2-27, 2007.  DOC. NO.  485, PAGE NO. 98,                                    BERNAR D. FAJARDOBOOK NO. 75, SERIES OF 2008.                                Notary Public,                                                                                       Until Jan.31, 2009,

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                                                                                       PTR NO. 4591703, 1- 2,’08,                                                                                       Atty.’s Roll No. 33633,                                                                                       IBP OR # 708299, 1-2,’08

           Malolos, Bulacan.  

COPY FURNISHED (By registered mail with return card):

 Explanation: Due to lack of messenger, and impracticality, since undersigned’s maid was sick and he has no other person to have this personally served and in view of the impracticality, service of copies of this pleading was made by registered mail with return card upon herein respondents:  Judge Thelma Pinero-Cruz,respondent,Presiding Judge , Br. 16, RTC,3000 Malolos City , Bulacan, and  Mrs. Lerida Socorro-Joson,respondent,Branch Clerk of Court / OIC / Legal Researcher,Br. 16, RTC, Malolos City , 3000 Bulacan. 

 

AFFIDAVIT OF SERVICE

  

REPUBLIC OF THE PHILIPPINES )Malolos City, BULACAN                   ) S.S.       I, Judge Florentino V. Floro, Jr., under oath, depose / say, that:                                I CERTIFY  that on January 29, 2008, I served copies of this pleading with all annexes in this case “Judge Florentino V. Floro, Jr. vs. Judge Thelma Pinero-Cruz and Mrs. Lerida-Socorro Joson”,  SP. No. ______, by registered mail with return card, upon respondents Judge Thelma Pinero-Cruz and Mrs. Lerida Socorro Joson, as proved by the

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registry receipts pasted  hereunder on the original copy hereof, on page ____,  in accordance with Rule 13, Rules of Court.  

      COPY FURNISHED (By registered mail with return card):

 Explanation: Due to lack of messenger, and impracticality, since undersigned’s maid was sick and he has no other person to have this personally served and in view of the impracticality, service of copies of this pleading was made by registered mail with return card upon herein respondents: 

Addressees            -          Address                                            Registry Receipt No. 

Judge Thelma Pinero-Cruz,respondent,Presiding Judge , Br. 16, RTC,3000 Malolos City , Bulacan, and  Mrs. Lerida Socorro-Joson,respondent,Branch Clerk of Court / OIC / Legal Researcher,Br. 16, RTC, Malolos City , 3000 Bulacan.  

Judge FLORENTINO V. FLORO, JR., 

            SUBSCRIBED AND SWORN to before me, on this 29th day of January, 2008, hereat Malolos City , Bulacan, affiant exhibited to me his CTC NO. CC12005 # 21783592, issued at Malolos, Bulacan, on 2-27, 2007.  DOC. NO.  486, PAGE NO. 99,                                    BERNAR D. FAJARDOBOOK NO. 75, SERIES OF 2008.                                Notary Public,                                                                                       Until Jan.31, 2009,                                                                                       PTR NO. 4591703, 1- 2,’08,                                                                                       Atty.’s Roll No. 33633,                                                                                       IBP OR # 708299, 1-2,’08

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           Malolos, Bulacan. 

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