1. acts of lav 11-3107

7/21/2019 1. acts of lav 11-3107

http://slidepdf.com/reader/full/1-acts-of-lav-11-3107 1/27

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ESTO

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through

the

Responclenti

IAfTY'

ERI{I

ion,

most

tto

this

Honorable

Commiss:

undersigned

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and

ur

t

PaPer

and

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respectfuliy

subutits

tl.is

Position

Paper

ano

sLaL(

ATTY.

ERI{ESTO

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L.

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LOS

SN{TOS,

ResPondent'

[Iil*"i,,lion,

Inc'

vs'

Ronranillo'

t

San

Jose

Homeownets

I

Ir,

,ri"*

of

the

nature

and

consequences

I

],,.r,]disilarmentbeingthemostSevereformof'disciplinary

against

Iawyert

rocess

.crnd

the

presumptton

of

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r

e

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urrat

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inconso'----

becattsehls

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,..avior

or

ir

Ats

notrsuilnot'to

dtsctlllnary

actlon

r.dclous,

It

is

:

'-iR

connection

with

a'lawyer

lual

corrgress

question'-oi:immo1{

uslut

)e,efit

of

marrrage

shoulcl

be

with

a

woma

LBHi,'r'J;.::'"fr;;it**,

"osE

No.

s1"34,

December

14,

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4rz

scRA

621'

2

Uytengsu

lll

vs'

ut

3

Id.

Pagc

1

of28

7/21/2019 1. acts of lav 11-3107


":,

characterized

as

"grossly

immoral

conduct,"

will

depend

on

the

surrounding

circumstances.a

.

t f- t

And

to

deprive

a

lawyer

of

his

honored

station

in

life,

his

lifetime

profession

acquired

after

long

and

laborious

shrdy,

by

years

of

patience'.rnal

and

ability,

which

Would

result

in

irreparable

inju{/,

must

requlrc

proof of

tle

ftrtghe$

degree.s

THE

PARTIEg

comptainant,

"luriewrryn

R.

Quindoza

(hereinafier

refened

t::

Jutiewhgnl

was

a

former

student

at

the

university

of

Manila,

who

attended

a

r I

'-

-ondent's

mentorship

sometime

1988'

class

under

resP

Respondent

is

a

co'owner

of

the

University

of

Mania

-TO

:"0"*O

:l:

services

therein

o.s,8",

'full

;time

professor.

He

also

held

office

as

the

University,sExecutiveVicePresident,ViceChairmanoftheBoardof

rt

Trustees

and

universily

Registrar.

Aside

from

being

the

overall

sports

coordinator,healsohandledotherUniversityAflairs'

Juliewhynseeksthedisbarmentofrespondent.However,the

complaint

rras

no

basis

both,

in

fact

and

in

law

considerinu

Tt'

resPondelt

il;

-".,

exhibited

towards',Juliewhyn

or

to

the

communi:

:

general'

immoral.

conduCt,.

that

cbnduct

which

is

willful,

f 1rant,

o:

*T"'.'',-T,1

i

which'shows

armoral

indiffeience

to

the

opinion

of

the

good

and

respectable

':

r

--

-r

--+r-

lia'

members

of

the

communitt'

tha

Respondent,sfar.nilyestablishedandownedtheUniversiq

un

lgL3."Bein;ia

coiowner

of':the

Universit-y'

respondent-

-I1--

i;*""*

"t

tr.e

University

as,a

fifl

*"

n::*ssor.

He

also

held

offrce

as

the

,*;;rrty,.

Executivel,ivicei

President,

vice

chTrmqn-:

::

Board

of

'Trustees

and

universitv

Registrar.

Aside

from

being

the

overall

sports

coordinatoi,

t

e

also

h

dred:other

universit5r

Affairs.

M#

+'ri*lH-*ls ;ir*'-e**186

,CofuitWcor,Jr.r'us

l'"'-'t

t'--L

Page

2

of28

7/21/2019 1. acts of lav 11-3107


l,

:::,

t.

i":

ln

June

4,

L978

bY

reason

Respondent

got

married

to

Edita

Baltasar

t

of

her

pregngncy.

However,

after

five

(5) months

of

living

togetJrer

as

husband

and

wife,

Edita

Baltasar

for

some

special

reasons

went

abroad

and

lwasbelievedbythelattertobemerely

eft

respondent

in

Manila

whicl

temporary,

hence,

he.permitted

Edita

Baltasar

to

leave

the

country'

But

for

no

apparent

reason,

communications

reached'

the

respond'ent

that

his

wife

pursued

a:divorce.

Years

after,

respondent

learned

thlt

his

wife

married

anotirer

abroad.

-,;-.

,.*4.r+

Brokenhearted

and

shocked,

respondent

longed

for

a

partner

in

life

and

he

les11d,his

answer

in

the

person

of

Fe

Delilah

DagUinsin

with

whom

respondent

has

beCn

fiving

for

more

than

thirt]'(30)

years

now'

Out

of

such

relationship

they

begot'three

.(3)

children'

namely:'

virgil

Patrick

De

Los

santos,

David

vincent

De

los

santos

and

Helen

Julien

De

los

santos'

. L1-

-

Fe

Delilah

Dagrinsin

previously

reports

daily

to

the

Universit5r

because

she

was

ihired

by

respondent's

gfandmother

as

her

personal

assistant.

She

mingles

with

respondent's

friends,

colleagues

and

students

in

't

t,

-L:f-

the

university.

she

and

all

of

respondent's

child.ren

would

normally

attend

the:

periodical,University

and

sports

affairs'

Juliewhyq,

onithe

other

hand,

was

thel

a

sftrden:

:t

*t

univerlil^lf

fuIanila'

holding

6"i'.t.r*

under

respondentis

mentorship

sometime

1988'

b.r.irrg

"rr"f,

timef

,iporra"nt

was

flooded."with

love

notes

and

pictures

coming

from

JuliewhYn'

'

l

-

.,

"

i,'

,i.

.

,

,..-:

-

trabrief

periodof

less'than

JuliewhynonlystayedintheUniversityforabnetpeno(r

"*.

-:'^:u

".r"*#engaged

in

d.ifferent

endeavors.

Though

no

torrger

a

year

or

so

arl

eiU''iv",sity,shefrequentlyvisitsrespondentintheErmita

hrdYing

in

th

;

, r

lentls

family

'business

establishment

also

owned

by

responc

Tourist

Inn,

a

where

he

also:previously

held

ofifice'

: ; i.r-

'

':'

'

i'

i,

Juliewhyn

wtro

was

then

For

tfie

period

ftom

1990

up

to

1993'

'"ot*,11

l:

'

----.--

t-^6

+lra

resnondent

WO

workingin'differeptprovmce$awayfromtherespondentwouldattimes

,r.

,

,

;, .,,,,

expected

visit,in:Ermita

Tourist

Inn;

D.uring

surpnse

the'latter

bY'her

l-t1t

i:i

il

rl

. il

,:i

':

Page

3

of

28

7/21/2019 1. acts of lav 11-3107


,l

i'

',,I

those

visits,'Juliewhyn

would

in

tur1"l

reveal

that

she

was

prompted

to

visit

.

by

her

need

fol

financial

heIP.

By

virtue

of

respondent

being

the

eldest

child

and only

son of

the then

university

President

and

chairman

of

the

Board

of

Trustees

of

the

rr i l---. 1

University,

ffid

the

rpositions

held

and

activities

handled

by

him

in

the

university,

respondent's

private

life

is

no

longer

private

but

is

widely

known

not

only

to

t1.e

students

but

to

the

faculty

and

non-faculty

personnel

of

the

University

as

well.

*11._..

'-'*4h'

By

reason of respondent being

a

public

figure,

it

taxes

ones

credulity

that:Juliewhyn

hasino

knowledge

about

his

family

status

from

L988

up'to

Lg;g4

or

a

year

after

she

gave birth

to

respondent's

daughter,

Mergarett

veronica. Having

such

full

knowledge

of

respondent's

marital

and

falnily

stahrs,

Juliewtryn's'

allegations

that

respondent

represented

himself

as

single

and

that

there

was

a

sincere

malriage

proposal

by

the

respondent

to

Juliewhyn

is

imPlausible.

contrary

to

Juliewhyn's

allegations,

respondent

n":

never

lived-in

with,

much

less

verbally

or

physically

abused:her.

Respondent

has

always

been

a,ilo.ring,

caring

and

responsible

partner

to

his

wife

;"rHI

Dagqinsin

with

whom

respondent

lived

for

more

than

thirty

(3

,..foraent

did

not

display

abuse

to

Fe

Delilah

Daguinsin

with

whom

he

lived

for

a

prolonged

period

of

time,

how

can

he

possibly

display

verbal

or

ptvri"rt,abuse

to-someone

living

away

from

him

or

with

whom

respondent

:..,

nirporrdent

has

never

abandoned

his

daughter

nor

failed

to."t*ilo::

her,

from

the

time

5l.ii,was'

born

until

the

day

of

respondentfs

alleged

abandonment.

Rcsp""q""t::

:; ;;;;;rose

periods

u.p**t"d

noritheir

communications

seveled.

In

fact,:dunng

th

alleged,

it

was

not

the'respondent

who

abandon*

n':-Ô1".Fl,l"t

tt'ttt**::'

dYing

effort

td

be

PersonallY

I

V"ronica

but iuliewhy'n,lwho

in

her

persistent

i

..

?aband6ned:MergarettVeronicato.thecustodyofPilar

baggage

lree,

arett's'grandmother'

antiago,

Merg

rr'r

'

Page

4 of28

7/21/2019 1. acts of lav 11-3107


Respondent

has

been

consistently

providing

Mergarett

Veronica

and

Juliewhyn

with

financial

support.

Juliewhyn

herself

.

admitted

that

fu*nt

has

been

providing

her

and

Mergarett

with

financial

support'

The

open

and

constant

communication

between

respondent

and

Mergarett

Veronica

belies

the

accusation

that

respond'ent

molested

her'

If

6ca

islthe

victim

as

Juliewhyn

clqrms

her

to

be,

why

then

*"':T::''-::::JT:Ijr"l"rl,

isases

or

rove

and

care

to

wouldl

Mergarett

Veronica

send

myriad

of

mee

respondent?

If,,indged,

respondent

committed':qffi$'

unfathomable

act

to

Mergalett

veronica,

human

reaction:'

suggests

that

the

victim

'

should

manifest signs'of

tt*rma,

which

is absent

throughout

Veronica's growing

up

;,

rr,

irlaeed,

respondenr

cornmitted

the.alteged

*:,

,]t:ln

"

lrrould

have

shielded

heq

daughter,ifrom:the

respondent

after

the

incident'

But

as

rborne

by

the

evid'ence

preSented,

Juliewhyn

not

o1''

elfitea

***:1

veronica

to

endless$,solicit

money

from

the

respondent

but

even

used

her

for

respondent

to'submilto:her

whims

and

capric€s'

cther

manifold

of

cases

were

On

the contr4ry, the

instant

case

and

all

:reinrespondenttoirregularlyuseourCourtsofJusticefor

iled

agqrnl'

h:

riewhyn

and

her

cohorts'.

purposes

of

:servinE.the

inordinate

motives

of

Ju

rmrprxpn

,oR

ESTABLISIIED

DISCIPLIIYARY

RESPIOI{DEI{T

lr,

'Res,Po,nd"ot,

W ,' . t:i

rrlortlsented

hlrnself

-:

stiote,

neltler

nds

rcJpondent

nude

sng

,

mrifiqga,';.

i,ftoP,oSal

to

ar1,frdwhtgn.'r

't

,',

ISSUE

ITOT

J.UTIEWTTYN

HAS

;nry

cAusE

ro-E

ACTION

,

AGAINST

Resoottdent

..

hq$

l:'

no'ti""

*hllblt,,i

';;;r;";d"--

.t

rtt

.hsn

ot

ta

the

;;^;tw

tn

siners\

tmnwro,t

ZZ:;;;;";'

lij;|',"

iiryl:yu'',..,':

uarra'nt'

T.SPONdEdIIS

Page

6

of28

7/21/2019 1. acts of lav 11-3107


.

...i

i.

Respondentrs

farhily

established

and

owned

the

University

of

Manila

in

19'L3.

Puisuant'

to

the

ownership

of

his

family

in

the

said

University as shown

in

the

Notices

of

Postponement

of

Annual

Stockholders

Meeting

dated

June

1,+,2oo}

up

to

Jqne

:1.4,2011,

his

family

members,

namely,

Virgiliq

De

Los

Santos

(respondent's

father),

Respondent

himself,

Ramona

De

Los santos (respondent's

sister),

cynthia

De

Los

santos

(reipondent's

sister),

Ma.

Corazon

Ramona

De Los

Santos (respondent,s

sister),

Mariano

P.

De

l,os

Santos,

Jr.

(responddffi*,uncle)

and Cordelia

De

Los

santos

(respondent's

mother),

aggregately

owns

ninety-nine

percent

(99%)

of the University

shares.:Copies

of the

Notices

of

Postponement

were

attached

to

respondent's

Answer

as Annexes

*1,

to

,l-Cr.

The other

nominal

share

of

one

percent

(1%)

was

;nerely

given

by respondent's

father

to

others;

2.

Being

a co-owner

of

the University,

respondent Atty.

Ernesto

De

Los

Santos rendered

his services

at

the

University as

a

full time

professor.

He

also holds

office

as

the

Universit5r's

Executive

Vice

President,

Vice

Chairrrran

of

the

Board

of Trustees

and

University

Registrar. Aside

from

being the overall','sports

coordinator, he

also

handles

other

University

Affairs;

3.

He is

the

founding

President of the

Rotary Club

of

Ermita,

Manila

which

was

established

sometime

in 1990.

This organization

belongs

',

to

the

Premiere District 3810

which

covers

Manila,

Pasay,

Cavite

and

Mindoro

where'neispondent,

previously

served

as'

a

District

Coordinating

Chairrnan;

a,

Respgndent

is,also'the,founding

member

and

is

currently

the

advisor

of

the,

National'

Athletic

Association

of

Schools,'Colleges

and

Universities,

otherwise

known

as

NAASCU.

Its,membership

includes

the

Centro

Escolar

Universitjr,

New

Era

College,

University

of

Manila,

University

oi,P^rr5,,

University

of

;Makati,

Fatima

University, AMA Universify,

STI

Computer,College,,St,

Claire

College

of

Caloocart,'Sfu

Sebastian

College

of

Cavite,

Lyceum

of Subic

Bay

and

othersi

Page

6 of28

7/21/2019 1. acts of lav 11-3107


I':

,

5'

He

is

also

currenfly

a

member

of

the

Board

of

United

Nations

Association

of

the

Philippines,

the

Internal

vice

president

of

the

National

Association

of

Independent

Travel

Agents

of

the

philippines,

the

chairman

for the

National

capital

Rbgion

of

samahan

ng

Basketball

ng

pilipinas,

a

grantee

of

Doctorate

Ed.ucation

.

Honoris

causa

from

the

Lyceum

Northwestern

University,

Dagupan

City;

Mqnila

in

the

consorLium

of

universities

in'*.ffiic,

university

belt

area

composed

of

different

schools

including

University

of

santo

Tomas,

Far

Eastern

unrversify,:

universiff

of

t}le

philippines, university

of

the

East,

Adamson

university,

National

universiqr,

Mapua

university,

Lyceum

of

the

Philippines,

centro

Escol4q

university,

Maquel

Luis

eueznnuniversit5l

and

others;

President

and

chaiiman

of

'the

Board

of

Trustees

and

not

to

mention

the

v

lJrq

rrv

L LtJ,

J

aforementioned

positions

and

activities

being handled

by

him

in

trre

University,

respondent's

private

life

is

no

longer

private

but

is

widely

known

not

onl5r

to'the

students

but

to

the

faculty

and

non-faculty

personnel

of

the

University

as

well;,

i.

8,

'

Respondent

j8ot.married to

Edita

Baltasar

on

June

4,

LgTg

by

reason

of

her

pregnancy.

However,

after

five

(5)

months

of living

together

as

husband:tana

wife,

EditaiBaltasar

for

some

special

reasons

went

abroad

and

left

respondent:in Manila

which

was

believed

by

the

latter

to

be

merely

temporary,

hence,

he

permitted

Edita

Baltasar

to

leave

the

country.

But

for

no apparent

reason,

gor4rriunications

reached

the

respondent

that

his

wife

'

pursued

a divorce.

Years,after,

respondent

learned

that his

wife

married

another

abroad.

Copy

of.

Edita,Battasar's

Mbrriage

Certificate

Abroad

was

attached

to

respondent's

Answer

as

Annex

62r;

:

9.

,Brokenhearted,iahd,s{rocked,

respondent

longed

for

a

partner

in

::

.:

li

l

,,:

life

and

he

found

his;answ.er,

in

ilre

person

of Fe

Delilah

Daguinsin with

^

.

whom respondent

hasibeerllliving

with

for

more

than

thirty'

(30)

years

now.

Out of

such

relationship:they

begot

three (3)

namely,

Virgil

Patrick De Los

Santos,

David

Vincent:De'llos

Santos

and

Helen

Julien De

Los

Santosl

PageT of.28

,

,.1

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t:

7/21/2019 1. acts of lav 11-3107


i

;r:;

l

'ril

,,1

.

al

-:

",'f

10. Fe

Delilah

DagUinsin

previously

reports

daity

to

the

University

because

she

was

hired

by

respondent's

grandmother as

her

personal

assistant.

She

mingles

urith respondent's

fiiends,

colleagues

and students

in

the'University.

She'and

alt

of respondent's

children

would

normally

attend

the

periodical University

and

sports

affairs.

The

affidavit

of

Fe

Delilah

Daguinsin:attesting

to

this

fact

was

attached

to respondent's

Answer

as

Annex

n3';

-:*:E;.n,

11.

Juliewh5in,

on

the

other

hand,

was

then

a student

of

the

University

of

Manila'

hotaing

her

class

under

respondent's

mentorship

sometimerlgS$.i::Dirring

such

time,

respondent

was

flooded

with

love

notes

and

pictures

coming

from

the

Juliewhyn.

Rernaining

copy

of

the

picture

**S

"tt

"hed

to

respondent's

Answer

as

Annex

u4',

whlch

was.

ordmltted:,

6y

,Jtrtlewlrrgn

,'durlng

the

ng;ndqitory

co4fetence

o,t

Ilccentber

2,

2O77;

L2.

Juliewhyn

only

s'tayed

in

the

university

for

a

brief

period

of

less

.

----l

::-

)2cC.

than

a

year

or

so

and

theleafter

engaged

in

different

endeavors.

Though

no

longer

studyrng

in

the

University,

she

frequently

visits

respondent

in

the

Ermita

Tourist

Inn,

a

business

establishment.

also

owned

by

respondent's

Mfidavit

of

Yoland

a

Cdlanza

famrty

where

he

also

previously

held

office'

ThO

'

attesting

to

this

fact

was

4ttached

to

respondent's

Answer

as

Annex

*5';

workingindifferentprovincesawayfromtherespondentwou

surprise

the

latter

by

her

unexpected

visit

in

Ermita

Tourist

Inn'

Juliewhyn

during

those

vrgits

*oUtd

in

turn

1ve' |:t

*

her'need

for

financial:help,'

olll

thaee'utstts,

as

well

as

tl1'E

t"lason

for

""tn

alstts

uqne

dutg

admttted

bg

Juttewhgn

durlng

the

ng;ndatory

.L4.Byreason]:olrespondentbeingapublic.figure,itta:<esones

credulity

that

Juliewhyn

has

no

knowledge

about

his

family

status

from

1988

up

to

L994

or

a,

yeqr after

she

gave

birth

to

respondent's'

daughter'

'

1^ G'll lrnnrr Actloe

marital

and

Mergarett.Veronica..Havingsuchfullknowledge.ofrespondent,s

'familystatus,.Juliewhyn,sallegationst]ratrespondentrepreset

l

Page

8

of28

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as

slngle

*d

that

there

was

a

sincere

mdhtrg.

proposal

by

the respondent

to

Juliewhyn

is

implausible;

B. Respondent

ltq,s

netter lhrcd-

less uetballg,

or

ihgstca;llg

ahteed hcr

:

'

15.

ContrSly

to

Juliewhyn's

allegations,

re-spondent

has never

lived-

in

with,

much

less

verbal$

or

physically

abrwd

her.

Respondent

has

always

been

a

loving,

caring

and.

responsible

partner

to his

wife

Fe

Delilah

Daguinsin

wrtJl

whom respondent'Iived

for

more

than

thirty

(30)

years.

If

respondent

:did

not

idisplay,

abuse

to

Fe

Delilah

Daguinsin

with whom

he

lived

for

a

prolonged

period

of

time, how can

he

possiblSr

display verbal or

physical

abuse

to:'someone living

awaJr from

him

.or

with

whom

respondent

had no

opporEunity

to

do

so.

Copy

of

the aflidavit

of Fe Delilah

Daguinsin

attesting

to respondent's

nature as

a

husband

is

previously

attached

as

Annex

'2'

ofrespond.ent's Answer;

16,

The

AIlidavit

of

Antonio del

Monte

attesting

to

the

fact

that

he

personally

told

Juliewhyn

about respondent's marital

status

as

early

as

Febmary,

1993, as

Well

as

the allidavits of

respondent

family's

employees

and

previous

household

help

namely

Leonora Songalia,

Josephine

Pinera,

Richel

Artrnda,

Yolanda

Calxrya.;,all

attesting to

the

fact

that

respondent

never.

lived.-ih

with

Juliewhyn

were attached

to

respondent's

Answer

as

Annexes

(6't

*Tnr*gtt tg'and

*4',

respectively.

C.

R*pondent

,tars

nstar

'

'

'

obin. oned

';

11,1et

,

daugnbr

lWergarett

VetPnlca

,,

-

--

L-.-

,fiii11a;ntiihgn

admltted

l

that

respondent:

has

neuel.

,abandoned

hls

daughter

nor

forltcd

to

attend

to

her

frcm

thc

ttntc

she

uqs

born

untll

thc'

iag

oy

ttsponfienrt's

atleged

ahandOnment.

Respondent

and

d.aughter

Mergalett

,iVeronica

were

never

separated

nor

their

commrulications

sever:ed

;

Page

9

of28

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,".t.,.,

:i:

',

:

'::.

:.

'"]::,:,

,4",,

-:

,

*,.I

?:rr,

ituitewhgn

qdmrtt*d

tr.-t

rgs?2ondcnt

and

hts

daughter

frrerganett

last

saw

eqah

otrtcr

somfrrmc

september,

2orr,

and,

trvt

for

thc

_pteurous

georns

up

to

the

ttme

*o"n

*.;;;;'; ;;,

respondent

qnd,

tlts

formcr

trr,s

nernr

fortted,

to

"r"

-r*

."fu;;.";;

wtth

t:o

other:

tn

ract,

during

those

periods

alleged,

,,

;;"

;;-;;

respondent

who

abandoned

his

daughter

Mergarett

veronica

but

Juliewhyn,

who

in

her

persistentldyi,g

"*;=';;;;;""*,

"*;;;,

;;";

Mergarett

Veronica

.

to

the

custody

of

pil*;,5*;.;,

;;;;;;

grq4dmother.

s--

--

ae'rgwtt

v-ercnra;

wrth

,rioa*o'|Jrrtt

iohgo-

;;,

-;;;;;

vetpnlca's

other

stbttrtgs

on

aet,na,r

familg

occnsrons

ona

got;dngs

fipm

7994

up to

gear

2oaz

ana

ttercqfuri

@ttached.

as

Annexes

n77,'to

'

1114.9

of

rcspondent;is

A**i4

:l,lCInloi

n*r,

*o

*pon*nt,

qtd

dauglttor

frrergatett

-

vercnrca

ureie

new?

sepa;tuted

nor

thctr

""m^\i{catlons

sernred,.

D.

Respondent

ltu.s

been

conslstently

prcatdtng

Mergarett

Vetonlea

ornd,

Jutteuthgn

urtth

financlal

support

,

20.

Regpondent

has

been

consistently

providing

Mergarett

Veronica

arrd

Juliewhyn

with

financiat

support.

'Jttllewhgn'herself

admttted

belare

tlv

Honoruble

Commtssloner

on

December

2,

2OI7

tltat tzspondent

li.;* 'neuer

boen

rram{ss

,{n

,prc,utdtng

het

and

Mergateat

wtth

financtal

ruPport,

andr

such,admi.ssion

is

duly

reinforced

by her

admission

of

the

various

checks payable

to,:

and

duly

encashed

by

Juliewhyn

R.

euindoza.

:

Copies

of

,fl1s

issued

checks,

duly

endorsed

and.

encashed

by

Juliewhyn

were

lattached

'as,

Aanexds

,

tlg'

to

uI:o-L'-;

Annexes

sr5,

to

.16-r;

.,

Annexes

4l7n

to

*17-28";,and

Alrrox

*18r;

':

"

2 '. In

the

same.manner,

Jullteuthyn

admltted

ttspondent?s

fittt

,,

.

.',,:;

suppiort, to

"fiergerctt

iertllca's'

edrtcatlon,

hautng

qdmtttod

thc

sa

mc

rn'parqgWh

11 of'hcr,Complatnt,

qs

well as

bcforc thc

rronotuble

Page

1Oof28

7/21/2019 1. acts of lav 11-3107


'

-

--,|

Cofn{lgq{oner'otn'

Ilecentber

2,

2O1

7,

tltflt

respondent

hqs

ptoutded

for

Merganett

vetonlca's

edttco;fdlonal pbn,

tttl,f/ron

fee

pagments

bootcs

o;rtd

other

sclwol

needs,

as evidenced

by

the

poliry

certificate

including

the official

receipts'of payments thereon

gnd the official

receipts

from

the

saint Louis

uniGrsity

arrd bookstores

attached Annoxe

s

ul$n

to

"14-An

and

Annexos

*16'

to

'16-H''of

respondent's Answer,

respectively;

22.

In

fact,

Jutteiwhyn

ltkeuttse admttted

beforc

the

Honoru)te

Coa4fgstonen

tha;t

etan ller

cabi,le frl

subsutnfbn fs

behg

patd

for

bg

ttw

rcspondenL,

Copy

of

the admitted

Mountiiffiew

Cable TV

receipt was

attached

as

Anuex

ul,g'of

respondent's

Answer;

E.

Eespondent

hyes.

,

n;ewr

motested

hts d,aughter

23.

Anent

Juliewhyn's

'allegation

that

respondent

molested

his

daughtgr, Mergarett Veronica,

proofs

to

the contrary

would

reveal

Juliewhyn's

malicious

intent

to

degrade

and

taint

respondent's

good narne

and

that

of

his

family;

2+.

Juliewhyn,detailed

that

such

incident

happened

on

December

7,

20O27

or

specifically

on

the

day

of

Mergarett

Veronica's'first

holy

coIIIm-uruon;

.'25.

Juliewhyn's

effort

to

make

the

commission

of

the

allegecl

incident

a

year

earlier

can

be

put

to naught.

Mergarett

Veronica's,'Iirst

holy

co-mmunion

which:respondent

personally

attended

was

held

on

Decembe:i

7,

ZAOL

and

was oflicially

recorded

in the

school

records

the

following

day

or

on

December

8, 2OOl;

26',

Mergarett'

,Veronica's

schobl

record;

Iikewise

shows

that

I'ttte

lrecorded

date:rof

hersfirst,communion

is

December

8,

z}l'il

and

not

.Decemb'e,r,7,

2OO2

as

irlleged

by Juliewhyn.

Agaln,

durlng

the

narydatory

confe,rence

befoie,,ttt,l

Honorablc

Comrnlss

loner, Jullewli7n o,dllntqd

t}*t,copy

i1

tfr"'gt

te

w,lth'thc

prtnted

dqtc

taken

durtng

gg;ild

lwlg

conwrruntonl,*'uelrrihe

"Wy

of

Merganettts

sclw6l

rzcords

at

So,lnt

L{,uts

Unhrcrsttg

Laborstnry

Elementary

School

certtfied

on

September

z'See

para$aph

12,

Complaint-Allidavit'

Page

1ilof28

7/21/2019 1. acts of lav 11-3107


2, 207'7'

attached

as

Anneres

*2O'

respectively;

(2L'

of

respondent's

Answer,

dtl

27.

Juliewhyn

stated

that

after the

'disclosure

by Mergarett

Veronica

of

the

alleged

incident, she

immediately

went

to

the

Public

:-

Attorney's Office

in Baggro

to

make

a

complaint

and

that

despite

her

complaint

with:

the,

,Public

Attorney's

Oflice

in

BagUio

City,

she

was

disheartened and

no longer

pursued tl:re

case

because

nothing

came'ourt

of

her complaint;

r#:.

. I

",.

.

'-*.g*1

28.

It

ls uOrtn

notlng

t

ort,IUltewhyn

netnr

lodged

a

complalnt

i

l'

agatnst

respondent,tfur

altegedlg nto,listtng

lr'rts

daughtcr

tn

tlu

P.tbllc

nttorneg's

Offi*,(PAOI,in

Baguto

C:ffur

29.

In fact,

'the

ONLY,,

instance

when

Juliewhyn

sought

the

::

assistance

of the

PAO

against

respondent

was

on

January,

2OA2

regarding

her endless.claim

forthim

to:support

Mergarett

Veronica.

B5r

reason

of

such

complaint,

the

PAO

,lawyer,

Atty.

Merly

C.

Espiritu

prepared

a

letter

of

uNotice

of

Pre-Litigation'

for

the

purpose, A

copy

of

the

Notice

of

Pre-

.a

Ljtigation has

been

:previously

attaQhed

as

Annex

u22/'

of

respondent's

Answer;

30.

,

tne

nffiaavit

of

Marlen

Misa

of

the

Public

Attorney's

office

likewise

attests

to,thelfact

that

asid'e

from

the

Assistance

for

Support'

tJre

pAo

ieceived

no

other

complaints

from

Juliewhyn

Quindoza..

A

copy

of

the

Gx

t23'of

affidavit

of

Marlen

Misa

has

been

previously

attached

as

Ann

responden 's

Answer;

g1.

As

ai1lth

"11p;7",'pTzal1tts

adnr{sslons

bcfore

the

Honorpple

commlsstoner,

Jullewhgn

tlkeutse

admttted

the

aboue-nentloned

aoiru*nts

attached,asiAnnexcar

t22'

and

t2O"

of respondent's

Answer;

-:---

.

.

g2.'

Juliewhy4iJ',atlegation

that

respondent

requested

and

that

she

consented

to

respondent's

request

to sleep

beside

Mergarett

veronica

alone

to

recover

for

his

loss.

of

time

with

the

latter

is

very

imp.robable;

-

siderinb't

U'"

fact

that

after

she

'was

taken

from

her

t,.e

'oo.*

":":I:::j:,,::.,,::-

T".I*.^..

r

ase

where

grandmother'slCustody,in

Bulacan,

she

was

still

of

very

tendet

Page

12

of28

7/21/2019 1. acts of lav 11-3107


'

.

+,,c

respondent

would,ackriowledge

as

a

fathei

that

she

could

not

be

separated

from

her

mother's

bed;

34.

Respondent

does

not

normally

stay'in

Baguio

for

a

prolonged

period

becauser

a lrot

of

activities/businesses

await

him

in

Metro

Manila'

Considering

the

tender

age of

his

daughter

Mergarett

Veronica

at

the

time

of

the

aleted

incident

where

she

was

not'then

used,to

his

father's

presence,

regpond.ent

would

not

be

a coldhearted

father

to

deprive

his

daughter

of

the

warmth

of

her

mother

at

bed

time;

.".i"*o,,

35.

The

atlegg.tions

of

Juliewhyn

t].at

respondent

molested

his

nagination'

daughter

is

certainly

Juliewhyn's

product

of

creative

iI

Respondent

has

always

been

a

loving,

caring

and

responsible

father

to

all

his children.

He

has

always

been

close

to

them

and

would

always

want'the

best

for

them.

His only

daughter

with

Fe

Delilah

Daguinsin,

Julien

Helen

D'

resPondent

is

to

her

aird

to

;:::;

l;l,Jtffi:*::Jili#TTas

been

p,",,i.,,f

;,*"i.o

as

Artuex

'424'of

respondent's

Answer;

.,36.Respondentandhisdaughtershav'ealwayssharedacllse

father-daughter

relationship.

This

is

the

reason

why

Mergarett

veronica

.r..r.,

failed

to show

her

love,

care

and

concern

for

the

respondent'

E-copy

;;

ilr**

,.*r"*,s

text

messages

from

January

to

May

2OtL

has

been

previousl5l

+tPqfrea

a"

44qex

uzgn

of

respondent's

Answer;

37.

,,

The

open

andlconstant

qommunication

between

respondent

and

*.,*.,,

r#;"

r"*:

;;

;;"i"-"

T":

1"-r:*'":

""::

T'"":"d.:t:

If.M

tt

vcroni.*i*ltrr"

victim

as..nlrieltrrn

claims

her to

be,

why

then

-

^

.

-

^;^

A arreiarl rrt ttIeSSAPCS

(JI

lvYv

would

Mergarett

Veron-ica

'send

myqad

ol,-:"t*"ges

of

love

and

c'are

to

resp-o,ndent?

tf;,

indeed',

respondenl

""ii:t:.d

such

unfathomable

ac

to

Mer$arettVeronica,.hum4n,reactionsuggeststhatthe.victimshout$

manifest

signs

of

trauma

w-trich

is

absent

as

shown

in

the

pictures

taken

for

'during'Veronica'sgrowingupyears'previouslyattachtd:

several

vt*u

l''l"€;f::-:

Answer,

ar

of

which

u'ene

Annexos

,.11r

,to

r"L.t-.+g

of

responderrr':

r.

If,

indeed,

i^rr*d.

bg'&lte1'hgn

durlng

tlre

nand'atory

conf,erence

respondrrrt

"or,i*i

11,,e

alleged

act,

Juliewhyn

should

have

shielded

her

daughter

from

'*:,

tl':,l*.T:

rtz*d,

Mergarett

veronica

to

evidence

presented,

Juliewhyn

not

only

uti

Page

13

of28

7/21/2019 1. acts of lav 11-3107


,;

.,,I

endlessly

solicit

money

from

,the

respond.ent

but

even

,"id

her

for

respondent

to

submit

to

her whims

and

caprices;

38.

In

fact,

just

very

recent$,

respondent:received

a

text

message

from

Mergarett

'Veronica

who

greeted

respondent

on

his

birthday

last

september

L7,2oll.

Her

text

message

reads:

nGood

moming.

Happg

61st

biirlltlag,

Papa.

God

bless.'

An,

e-copy

of

this fnessage

is

attached

hereto

has

been

previousllr

attached

as Annexuhf:n

of respondent,s

Answer.

F. Trw

lnstqnt

ccse

qnd

a,ll

other

manlfold

of

cq,ttes

w,ene'

filgd,:l

gryltollnst

'

lt'rlteln

rcspondent':.

to' lrwgularlg

use

our

Courts

of .fitsttce

for

purposes

oj::serrtfitfl tlrc

.

tnotfdlncttc

',,

,ltotl,ltos

',

'of

,Iulleuihgn

a nd'her

caholrt;s.'

39.

There is a

GLARING

MOTIVE

behind

the

filing of

this

disbarment complaint;

fact

that

complainant

is

a

very

close friend

of

EMILY DE LEON,

the current

president

of

the

University

of lvlanila

who is

Mergarett Veronicals

godrtother.

Annexes

"271

tto'u27-pn

of respondent's

Answer

lus been

dmttted

bg

Julle;whgn tn be

coples

of

tha

ptwto

showtng

the

bapttsm'of

lfiergsrett

clnd:ln

atteidance {s,Emllg

A Leon. Also,

the affidavit

of

Yolanda

April

C,aJ

:at[esting to

'

]De

Leon

and

Juliewh5rn's close fellowship:has

been

previously

attached

as Annex

"4"

of

respondent's

Answer;

,^

4I.

For

purposes

of

apprising

this

Honorable

Oflice

as

to

the

real

,motivelbehind,the

inslant

case

against

herein

respondent

and

as

to

the

perion

of Bmily,De

ilron,

respondent's

pleading

denominated

as

the

"Opposition

to

the

Motion

for Reconsideration'

filed

before

the

Regional

Trial

Court of Manila,

Branch

49

docketed

as

SP

NO.

O7-LLS7L9

where herein

respondent

registered

his

opposition

to

his

father's

probate

of

the

alleged

i

:

ll:.'

hologp4$is

,wi11,

attaci,ted

as

Aanex

u28-A'

of respondent's

Manifestation

a

dated

Nqvember

29;'291,1:,.is

hereby

quoted

for

convenience,

thus:

,l

Page

L4 of?a

7/21/2019 1. acts of lav 11-3107


.tr

';i'

,'.'lt,

.;;''.'

r:

l::

.,:l

"22.

'Emily'De

kon met

my

family

when

she

was

hired by

:

the

:

University

.of

'

Manila

'as

recqrdp

clerk

at

the

Department

of School'Records.

'She:stayed

as

Records

Cleik

for

quite

some time

until

she became

the

University

Teacher

handling

:Math

and

Statistics

Subjects.

She

was thereafter

promoted;as

the Administrative

Oflicer

under the

OfEce

of the

Ehrirr";-*rrit"

*yi;th;t, virgilio

De Los

Santos

was

then

the

lJniv{rsiry fresident

and

was

simuttaneouslS,

holding

the

position

sf

ttre Chairman

of

the Board

of

Trustees.

In

no

tlme,

bmity:

De,Leon,became'

the

University'd

Vice

President

for.

Academic

A$airs;

23;

During

such

time,

Emily De

Ieon

frequently

visits,the 'conjugal-durc[ing'

of

my

'paients

at

No.

27= Scout

Santiago:St;;

Quezon

Crty

where

she

infffiires

in

the

care

of

my

father anai'in

the','management'

of:

the affairs

of

the

householtl.i

She iilso

ftequr:ntly'accompanies

'my'father

in

his

'

personal hnd

business

trips

abroad;

24,

Disputes.and

bickerings

occupied

my

family

at

,

'i

the

tibe,]h'ence,

s1"'mother

found

no

other

choicg-but

tofeave

the

unendurable

sifuation

at

their

conjugat

dwelling

and

was

compeled to

stay'inr.Ba

o:where

she eventuatly

died

of

a1

iltress

on::Ju1]r.:22,

2006.

Copy

of

her

death

Certificate

is

hereto

attached

as

Annex

"C"

25',

Irnmed'iately

after

tJle

death

of

my

mother

and

much

t

r"t';ffi;;

;y

father

surplsing[relinquish:d

hi:

post as

President

and

causgd

the

election of

Emill

De

I*on

as

ih;-

r"*,

U*""*ity-*"*ident.

-Copy

of-

F9.'

University

of

Manila's

Minutes

ofttre

Board.

of

Ttrrstees

Meeting

attesting

to

hi-

r*t

ia

rr"*i"

attactea

as

Annex

"D"i

,:

,

Z6i

,nmity,De.Leon'"36'smelf

enjoyed

tle

position

of

beihs

the

Univer;i$

Presid'ent'

In

fact;

sometime

Octobgl'

;6e.

d"iilA;

uretime

of

my

father,

the

Universily

of Manila

iiJ*

t*E"a.tEy-l-*"

beiore

the

securities

and

Exchange

6j};i"'";;G;AA;;Jtyi

"..rors

to

extend,

the_term

of

ttre

;;ffiJit

pr[-iakt

t;

;4"

(1)

vJar

term

to a

five

(5]

vear

terrr. but

was','rorainaielyta""i"h:uy

the

SEC'

coPy

of

-the

A#'";#

By-14;;-EJGrrre

the

s-Bc

is

hereto attached

as

Annex

oE''

'

t.

.ii..1.

,"

j'

.:

r.

.i.

I .,:,''

J,r

r.t.

:.

. rrl::

:,,.:

).,

I

i.,

..:;:;

'

of,the

,

2O1L,

',,,,ZVit,

As

l announced

by,Atty,

Madrid,

9t

:otp,1t"ll

"**r#i

o1i["1frali[:,J

ii'";l;is,

du5rns.

$

^Pr;1g.:i

ffiffiil

#s,i;'fi#;g,

thg

dgniar

*":

1y:-83:1, *:t rT:

;;ru;?

rJy-i,

i"n:stoct

côgorltiot"

**1

tit

i"Ut"

Ut

ir"rsit5r

of

:Manila'.A

gopy

fi

*

"taaS

-Uf""r.

s'

of

the

Meitin

g

date

d

M."y-,

1

8l

tlf;;r*;

ilr

such

denial

is

hereto

attached

as

the last

few years of

my

father's en$u118

,r;"ii"*

;.i"ths

of

him

clingng

to

life'

'l;;d,'

"q"--aurr"

amongst

our

famlly

aej,,,,'$o*"g4e,-

Jry1y:

399[-* 1..

ffiI*9,,Tfl*

H",,sfi'iic,i#ilf

;;;;hilEqriv.P.'L:""'L:f

*-1g,lg1

aurls'

-rrv1'6

ili--

;iiJ

&"

io

ur"Ltrrirrg

cilficulty

without

even

to

tJ:e'Asian

Hosl

',a.

t"::

.'a

:1

\.

Page

15

of28

7/21/2019 1. acts of lav 11-3107


-'

--.1

:

,

Januqry-l5;,2008

so'I tried

to

loiate

his

whereabouts.

Upon

it

qrrities,

I learned

that

my father

was

then

confined

in

a

30.

I

called

up

Emily

De

Iron

to

inquire about

my

father's

whereabouts

but

she

refused

to disclose

saying

that

my

father

wished

not

to

see

me nor

any of

our

family

vefy,well tatin

cared

of.

So-I

ihstnlcted

Delilafr Dagqi+qn

to

i"qi''ediately

inquire,frorir

{ifferent

hospitals

in

Metro

Manila'

:

where

we

fnaUy

aiscovered that

my

fiather

was

then

confined

;

in the Intensive Care

Unit

of

the Asian'Elospital;

,]

Santoe

:Cfran

in

the::Unittd

Statesrwho

rushed

her way

from

uS

tolManil.

when,I

and

my

sister

c:trthB

P".T*

Santos

Chan,w,ent,:to see

our ailing father

in

his

death

bed

inside the

IntensivelCare

Unit,

we

weie

prevented,.casted

and

driven

out

,

by

g*ily

De

Leon

and

by

my

sister

Ramona

Dg

F"

Santos.

Diys

afier

such

visit,

my

father

d.ied.

:A

copy_of

the

emd-avr1

ex#uted

by

my

sister

attesting

to

this

fact

is

hereto

attached

as

Annex"d"i''

'

42.

,

After'

'the,

death

l

of

.respondent's

'father,.

respondent's

sister

'

,Rambna

De

Ircs

Santgs,

who

is admittedly

the

live-i1

l*t*9r.

or

emllr

a1

Leon,

caused

the

liling

of

the

Fetition

for

probate of

their

father's

alleged,

anscriPt

of

hotogpaphic

will.,

copy

of

the

relevant

portrons

of

the

Tr

Stenoglaphic

Notes

on the

hearing

for

probate

held

on

October

3;

2008

where

reqpondentis,

,sister Ramona

De

Los

Santos

admitted

tl-at

Emily

De

Iron

is

her'lover

has

been

previouslSt

attached

as

A4nex

n28n

of

respgndent's'Answer;

43;

SurPrised,

with

the

conlent

"t

1

'responctenp.,qnd,'his'rsister tQlrnthia

De

los

Santos

Chan

regtstered

'their

bpposition'thereto.,Copy

bf

the

Opposition

to

the

Petition

for

Allowance

of

will

has

been

previously

attached

as

Annex

n?g"

of

respondent's

Answer;

.

;'

44..

'AftCr'thCi,'*r*''of

Respondent's

opposition

to'

the

probate

proceed.urgs,

Emily

De

Leonland

Complaina4t

Juliewhy-n

Quindoza

barraged

fr.r"Ul

ndent

wim

a

""*ter

of

malicious,

fabricated

and

unfounded

shed

light

on

what'transpired

on

'tltose'cases'

criminal

o"n

;Eisnondenf's

aforementionel

ln1"tY

t:

*'

Motion

for.

,:rReconsideiation,i,,

attached

as

Annex

r28-Ao

of

respondent's

. r

.,

i.

,

tvtarrirest*tio,

a,atea,xiivember

2g,2011,

is

again

hereby

quoted,

thus:

Page

16

of28

7/21/2019 1. acts of lav 11-3107


i,.l'

-Ihe

enumeration

of

the

petitioner

of

the

cases

filed

against

Ernesto

De

Los Santos

is not

only

incomplete and

selective

but

is

likewise

deceiving.

Worthy

of

note, however,,is

ttre

fact t}at

all

thesg cales

were

fiIed,

against,At$1::

:Ernesto

De

Los

Santos

after

e legistered

his

opposition

to

the

probate

of the

will

of

his'father,

Virgrlio

De los

Santos;

1.

To complete

petitioner's

list,

it

is

worthwhile

to'note

that

s6metimb

October,

2008,

Emily

de

Leon,

filed a

case

before

the

Oflice

of

the

City

Prosecutor of

Manila

for

Estafa

docketed

under

case

no.

-0il:1r?04

arhJB*"J"

p"

l,o"

santos'

copv

of

tt:e

complaint

is

f,ereto

attached

a"

Ott%ff_a

payroll

ghecks

have

been

isJued

in

favor

of Mr.

Gunnawa,

ihi

previous

employee

of

the University

of

Manila

but

was

depisited

to

the

personal'account

of

herein

complainant'

B-ify

De

Iton

'further

added

that

Mr.

Gunnawa

is

a

ghost

employee;

,

3,

In arresolution

dated

September

11,

2OO9;

hereto

attached

as

Annex

' 6',

the

Investigating

Prosecutor

declared,that

after'a

judicious

review

of

the

reridence

submitted

there

was

no

probable

cause

to

indict

herein

complainant

with

the

offense

charged;

4.

Ttre

investigating

Prosecutor

ratiocinated

that

the

complaint

failedito

estabtsh that

respondent

*i""ppi"d;EJ

th"

*o'nts

covered

by

the

u"il;Ua"t

checks'

and

further

declared

that

in

a

^C"-;fi;*tilt;;;a

ry

'.n"

Metrobank,

it

was

certified

thatitheisubject

checki

were

deposited

not

to

the

acco-unt

;i-E;.stO.be

Los

Santos

bul

to

the

Account

of

the

University

of

Manila;

',,

'

'

,r.

As

declared.

by

.

the

investigating

prosecutor.

the'certification

issued

by

Metrobant

was

;;;J;;;i;u

6r',tra1':cunnawa

himself

who

declared

that

h;;

;;t

h*"

ar,ry

bank

account

and

by-reason

of

:

such

fact;

,he

,usually

reque-sts

herein

complainant

to

,

enchsh,hisi,cheekS

Which

&e'

eventually,

deposited

to

tl.e

i;ifa;Countlof

trre

Univerprty

of

Manila;

,

,'

,6.1

In

her

persistent

9q9t

tq-hT"":

on

the

followine

vear

some';-i

March,

2OO9,

Emily

p9

Leon

;*;il4?i"-""*"-r*

Estafa

before

tl.e

office

of

the

city

'#o."qotor

of

lvlanila

docketed

as

case

N:'

IJ-9J-INV-0-9-

c_6h6d.;i";;tirs

her

allegations

involving

the

checks

;;;tdth;

.I"r"ry

of

Mr.

Gunnawa

but

this

time

tffid;il'airi"r"*

"et

or

check

num-bers.

copy

of

the

".*pfrita

is

hereto

attached

as

Annex

"\7"i

7.

Emily

De

Leon

aSTn

alleged,that

checks

:

issued

to,,,Mr.

Oii"""**,

,the

pririouu

emp.toyge

of

t11e

;*"";#

;IMr"t;;ttv

;*v

oi

salarv

totaling

to

Twelve

,

il;;r.;i,p.t;Jtpilpllz,ooo'oo)

were

actuallv

deposited

I

und.er

t1e'account

of

Ernesto

De

Iron;

Page

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,

,

1

' '

i':'

i':

l'l

I

'

8.

In

a

resoluti0n,dated

Ociober

L4,2OO9.,'

hereto,

attached

as

Annex

"18",

tlie Assistant City

Prosecutor

concluded

that the.,blements

of

Estafa

are

wantingratiocinating,'thu*:

(

,l

,::

,

',

'Mr.

Gunna:rra

himself

,has

attested:

that

he

actuatly

received

qll

amounts

indicated.

in

the

six.

(6)

'

checks

subject

of

this

cas€p

which

represent

his

monthly

salaries

as

utility

personnel.

By

practice,

his

pay

checks

are

errcashed

by

his

superiors

or

at

the

OIEce

where

he

is

assig4ed.

Then

the

,checks

are

deposited

back to

the

accounts

of either

UM or whomever

had encashed

it.

Ttris

practice

is

confirmed

by

Mrs.

Belano,

one

of

the

complainantls

supposed

witness,

urhen she states

under

o-"th

that; (Mr.

Gunnawa's) payroll

jg* ,.irrg

processed

by

the

Accounting

fiepartment

of

the'UffiVersity

of Manila

through

checks

encashed

through

the

Benguet

Pines

Tourist'

Inn

Collection/Castuef

departreent which

is

ownedlby the

U:riversit5/.

This

explieins

wtry

the

subject

,checks'

:,do

not

'aetually

bear, the

,

endorsement

of

respondent quite

contrarJr

to

the

allegations

in

the

complainf

:

under

paragraph

3

and

,paragraph

,8

of

the first

and

second

complaints,for Estafa,

Mr,

Gunnawa

was no

longer

employed

in

the

University of

Manila

at'the

time:of

the filing

of the

abovementioned

complalnts.

Emily

De

Leon,thirefore was

quite

certain

tha[

Ernesto

De

Los

Santosi:

would.'.experience

griqeme

difrculty

deferr{i4g

himself

because',tllere

would be

a

very

5lirn probability

that

he

could locate

Mr"

Gunnawa

:to

attest

to"

the

untmthfulness

of

Emily

De

Leon's

allegations;

:

10.

In

fact,

the

entire

members

of

tlle

Board

of

Trustees

with'Atty.

Madrid as

the

proBonent had

the

temerity

to autholize

the filing

of

these

cases

and even

utilize

ihe'finances

of

.the

Uniiersity

despite

Ernesto

De

los Santosf

explanation/objection

and

dispite

their

fulI

knowledge

that

said

measly

sums

representing'the

salary

of Mr,':Giinnawa'were

being

deposited

to

the

University's

ban*'

acc6unt;,,.Cupy

of

tfie Minut"".of

the

Board'of

Trustees Regular lrieeting

on

June

L7,

2OO9

attesting

to

'tlris

fact

is'hereto

attached

as

Annex

:Lg"i

,

of the

,abovementioned

complaints

for:Estafa,

Emily

De

Leon also

filed

a

case

for

Falsification

of

Public

Doctrment

Uefoi"

tfr",

Office

of

the

CiU

Prosectrtor

of

Manila

but

was

il;&;,dismissed

for

lack

of

jurisdiction.'Copy

of

the

resolutionl

dated

October,

29,

2}O8'is''hereto

attached

as

Anlex

lzt0"i

:

|

'

L2.

Thus,

she

again

filed

the

same

case

for

r.asificatiooitor

p"bd

-Oo""La"t

in

Makati

docketed,

'

underISNo.o8.J-8894.;Beingobvious1yb.ereftofany

;;rit,

[ile;',case

was

dismisied

noj. r-T-ulg"i:"cv

of'

Ja"rrJ;

but

for

LACK

oF

PROBABLP

CAUSE'

Copv

o-f

[on'dated

July

23,

2OO9

is

hereto

attac'hed

as

Page

18

of28

7/21/2019 1. acts of lav 11-3107


il

i:

13.

rUnsatisfiedr

with

such

dismissal

of

the

complaqlt, she

filed'

a'

Petition

for

Review

before

the

Department

of

Justice

questioning. sucl di,snqssel:

A1

expectCd,

the Department

of

Justice

in a

Resolution

dated

Miich

zs, zotti

again

dismissed

the

Petition

declaring

that

the

element of

the

ofrense charged

is wanting

in

the

case,

.Copy

of the

resolution

of

bismissal is

hereto

attached

as Annex

"22";

l

the

Department

oi.lustice,

petitioner

fi.led

a

Motion

for'

Reconsideration

from

such

Department's

Order

of

'dismissal.

Surprisingly

arid

for no apparent

cogent

reason,

that

same

Department

*,reversed

its

own

resolution

and instantly

recommeird6tl-.'ttre

filing

of

the

llnformation

for

Falsilication

before

the

Court.

This

,resolution

'

was'

'

mentioned'

in

the

Petitioner's

Manifestation

filed

before

this

Court last August

5,

2011.;

:,,

'

15.

Most

recently,

Euily,De

Leon

also

filed

alcase

for

Qualified'Theft

aga+nst

At y.

Ernesto

De

Los

sagtos

attributins

acts'of

th;ft

of,water

and

electricity

of

Bens-uet

Pines

tourist

Inn,which

is

owned

by

his

faqily

agaiist

him

for

a' huge

amount

of

Ttrlee

Mrflion

-fesos

pfrpa,OOO,000.O0)

making

it

a non-bailablg-

offengg'

B.ittglb"t"ft

of

any

legal nor

fl"tY4

basis,

the:Honorable

Fisci,Nenita

Orpiana

of

Baguio

City

stood

on

the

ground

of

truth,

senred

justice

on

ttre

basis

of

clear

and

;;"ri""dg

evidence

on

records

and

rendered

a

Resotution

dismissing

the

complaint.

A

copy

of

the

Resolution

datEd.J.rly

29,

2Ot1

is

hereto

attached

as

Annex

"23";

,pregpant,with:lies

and

fabricated

facts

was

also

recently

fiilf'b;tuJrie*nytte

n.

Qrit

doz1,

a

person-under

the

Dower

-of

herein

complainant

by

reason

of

monetary

-"Uo*urr""

being

received

monthly

by

Ms:

Quindoza

from

'

'

lV,

,

Emily De

Leon

utiliaing

her

authority

and

inltuence

or",

ih.

Board'

of

Tqustee.l

of

tfe

UJte*i*iiu*il"

and

again

as

Attv'

Madrid

as

the

oroiect, ororonirrit'"*u"ed-

the

posting

of

t4rpaulin

;;;t*"

i""-S"ting

about

four

(4) meters

by

six

(6). meters

5i"*iri-Ti";il#;

oiatty.

E*r.to

De

rron's

three.{3}

;ffid#, i-

rJ

beurar,

Daguinsin

and

Attv'

Man{iita

prfi|." 'at

digerent

consficuous

placeq

in

and

outside

i,.--U;&;;iil'

premises

^

depicting

th"

as

trouble

;;";;initrt"*-t

of

the

poited

tarpaulin:

'rrd

their

ffi;il;f

io""tir"r

are

heieto

attac,ia

as

Annexes

"24'

to

"24-F'i

l

,

::rr

18.

Emily

De

kon

had

mastered

the

art

of

controlling,

;r"idi;i"g,

subduing

the

will

of

the

people

iiitt*nl?';;;t.

In

-fl'ct,

even-

mv

voungesi

sister

ililan;t6",'i;;-5""il"

*r'o

is

nleviorl-l'

q111

overlr

,

;ffi;;i;tia["it

,,1

a""gt't"t

and

lister

is

now

amaingtv

stouthearted;

':']

Page

19

of28

7/21/2019 1. acts of lav 11-3107


45.'

The foregoing

facts evidently

reveals

the obvious'motive

of

Emily

De

Leon,and

her

cohort Juliewhyn

Quindoza

to

pressure

herein respondent

to withdraw,his

opposition

to

the probate and

to

prevent

him

from further

pursqng

his clgrr-n

to

his

father's

estate;

46,' Unsads{ied

wrth

all those

fabricated

cases

and maybe,stricken

with

awe

because

respondent

is still standing

and fighting

for

his

parent's

legacy,

Emily

De Leon

and

Complainant

Respondent

also

caused

several

Iibelous

ngwspaper:publicatlons

featuring

the

picture

of

the respondent

and

all

the

cases

filed

agqr4st

him.'Copies

of the

articles

in

People's

Journal

Tonight dated September

5,2,011

Volume

XX)il,

No.:31O

and

the

Midland

Courier

dated,Augpst

21,

2OLL

has

been

previously attached

as

Annex

"3O'

and'32'

of

respondent's

Answer,

respectively;

47.

Emily

De

Leon

and

complainant,

in

their

desperate

effurt to

discredit respondent

and

remove

him

from

the

University,

even

initiated

a

coerced

signature

calnpaign

seeking

respondent

and,Registrar

in,the

University-of

Manila.

Complainant

and

Emily

De

Leon

h4d,

the

temerit5,

to

oust

respond.ent

from

the

University

which

is

99%

owned'

by.

his

fa,nlily,

established

by

his

parents

and

great

grandparents

48.

The

fact

that

such

was

a

coerced

signature

campaign

was

communicated

to

the

respondent

by

a

concerned

employee

of

the

l/niversity

who

refused

to

disclose

his identity and

instead sent

an

email

message

to

the

respondent.

Copy

of

the

email

message

has

been

previously

attached

as

Annex

"g1n

of

resPondent's

Answer

:

.s

likewise

Published

in

the

49,

"This

coerced'signahrre

campaign

w4

full

page

lssue

of:

Peopleis

Journal

'Tonight dated

september

volunre-Xlofl,:

No.

31gi

ha*

been

previously

attached

as

Annex

"31-A?

of

respondent's

Answer

50.'

respondent,

opposlUOn

continuing;

Theseii

end'less

attacks

and

:

his

person,

familY,

dignitY

for

to

the

Ptobate

case

did

not

:

presuur.

Posed

against

the

tJre

resPondent

to

withdrgrv

his

iasily

end

and

in

fact,

is

still

Page

2O

of28

7/21/2019 1. acts of lav 11-3107


'51.

Juliewhyn and'

Emily:

De

Leon,

even

dragged

respondent's

daughter Mergarett Veronica, to

file

a criminal complaint

against

respondent'for

th.

atl.grd

crime

of

Acts of

La.sciviousness before

the

Oflice

of

the Prosecutoq;in

naguio City docketed as

I.S.

'No.

1 L-Olg4t

where the

allegations

in the

,Allidavit

executed by

Juliewhyn

Quindoza

is clearly

identical

to the herein cornplaint for disbarment.

Copy of

the Complaint

and

Juliewhyn

Quindoza's

Allidavit

thereto

has

been

previously

attached

as

Annex

*33'

of

respondent's

Answer;

-:.rr.;L*.,.

'

52.

JuliewhyU

and

her cohorts

wittingly

failed to

inform

this

Honorable CommisSion

that

,said

corylollnt

tor

ccts

o

la,sctatousness

lws

aheadg

bcen'DlStrdlSStD;:for lolck

of

ptoQapl,b'cause. Copy

of

the

Resolution

of

the'Oflice

of,the City

Prosecutor,

Baguio

City, dated

October

6,

2OLl

is hereto

attached

as Annex

*l-Posltlon

Paper'.

,

malicious,intent

to

harass

and

to

pressure

respondent,

filed

two

more

(2)

disbarrhent cases'against him.before

this

Honorable

Office docketed as CBD

'Case'No.

11-3166

and

CBD'Case

No.

LL-3167.

Copy

of

the

two

(2)

new

"o*p'1r*irrtS

has

been

previousll4

attached

as

Anuex

u34'

And

*35'

of

respondent's

Answer;

:

,

S,+.,

Worse,,,they

even

included

respondent's

probate

lawyer,

Atty'

Majurita

S.,

palabrical

in'the

said

disbarment

cases

who

has

recently

*iUrar**,

her

reprCsentation

in

the

said

probate

case

due

to

tlre

pressures

employed

upon

her.

copy

of

the

withdrawal of

Appearance

has

been

previously

attached

as

Annex

"96

of

respondent's

Ansu'er;

,

lss..,,',

,onrseptember

22,

20L1.,

respondent

was

arbitrarily

and

illicitly

,"**.a

by

Emily^De

Leon

as

the

Executive

vice-President

and

university

*;gt"O*t'iopy

o,

,".rond.ent's

Notice

of

Removal

has

been

previously

attacfrea

as

Annex

ugT'of

respondent's

Answer;

and

Juliewhyn

.rr..dirrrother

one

full-page

publi:iu":

notiffine

1:'":":

of

respondentls

ouster

from

tJle

UniversitSr

of

Manila

Copy

of

People's

Tonight,dated

volunie

xxXI,

'No.

328

d'ated

september

23'

2OLL

showing

Paee?l

of28

7/21/2019 1. acts of lav 11-3107


'

.,.i

such

publication

has

been

previously

attached

as

Annex

'38'

of

respondent's

Answer;

57.

The

foregoing

obstinate

and

relentless

effort

of

Ernily

De

Leon

and Juliewhyn

:Quindoza

to

pressure,

discredit,

dishonor

and

remove

respondent from

ttre

University

of

Manila can

be

best

explained

by the

following

events,as

expounded

by

the

respondent

in

his

Opposition

to the

Motion fsr

Reconsideration

filed

before

tlte

probate:court, thus:

.

_

''

*4*f,

',

'

u9.

ImriediatelJ,'after

the

deattr

of

'Cordelia

De Los

Santos

on

July

2i,

2006,

Emily

De

kon

wab

surprisingly made

thetuniversity

P-resident

by

the

late

Virgilio

De'Los

Santos.

The

late

Virgilio'De

[,os

Santos

who was

then

sfiil:,able

and

competent:unbelievably

and

without sligfrtest

notice,.

relinquished

his

post

as

the

University

President.

Minutes

of

the

Board

Meeting,

hereto

3

frea

aS

+Tei

"2"

uldicated,

tlruq:

'

"Before'Ure

election

of

the

Officers'

of

the

,Universrty;

the

president

of

the

University

made

a

statemeiit.',

l'Dr.':-Virgilio

De

Los

Sanios,

irrformed

the

g-"*e,rf

i*4f""*,d*t

ti*".has'

come

when

ttre

saying

'the

spirit

is'willing

but

the

flesh

is

weak'aPqlies.tg

hh'-

So

it,ivas

hiS.aeciSion

to

resign

or-retire

as

President

of

ttre University.

However,

he

ihafl

remain

as

Chairrran

of the,:Board

of

Tfusteei.

He'said

that

he

knew

the

Universitv

more than

anybody

else.

The

one

who

woufd

.a* ori

th"

mission

oi

Ure

Universily

dnd

keep

it

in

*J""hrrras

is

Dr-

Emily

D.

De

Leon.

He

(sic) said

that

she

is

indispensable

-in

the

continued

growttr

and

i**rSir"

of-^me'University;'

Dr.

De

Leon

will

continue

"=

S"t

iot

Vice

h'esident

and

Chief

Academic

oficer

for

trt:rr"ars

as'stated

in

the

Last

meeting

of

the

Board

of

i.""t""t

held.

on

April

26,2006'

She

will

enjoy

all

the

;fiffi;;;i;s;;

a

senior

Vice

President

and

chigf

d;;at"-6ir""7

or

t1.e

university.

In

accordance

wit1.

iir"

a"Jiie

of

the

Dr.'Virgilio

De

Los

Santtos,

uPon

motion

i"jr-ii"J;-;J

";"dJd,

ttre

Board

resolved

to-

accept

rus iesigration

with

deeP

regrets'"

'

,r

'

'

10.

'

T1re

Board

after

such

statement

immediatelv

proceeded

to

elect

the

oflicers

of

the

u"il;iJ"

rtia

due

to

the

surprising

preliminary

.t"t;;;ls

of

Virgilio

De

Los

Santos,

Emily

De

Leon

became

the

UniversitY

President;

'

,',,

'11.

In

the

sam-e

P{lutes,

hgwevel

Bryily

Derl,eon'*lo

,""

tntttally

hlred

ar thc

Recordl Cleflr

,

Ii

ffa-.lii"r**iiy

or

u""u"

wea

docfgnated

.ar

tle

;if,;Ifi,;AlI6.atorv

of

the

untwrrttv

ln'the

said

m".tiog,

thus:

: :,.,

"Inview

of

the

new

se

'

upon.motiotti"iy

*"at

and

s9c9.1ded.passed'

approved

:

,fia;aadpiea

UreioUowine

resolutions,

to

wit:

Page22

of26

7/21/2019 1. acts of lav 11-3107


-

.,,1

;

:

Resolve

as

it is

hereby

resolved,

o

change

the

r'

University

of

:.Mqrrila

deposited/placed

in. the

are,thi

sigiiaturi

aione

of

Dr,

Virgilio

De

Ios

Santos'or

the

joiht

signatqres,of

any.two

of

the

following

officere:

:,

I

Dr.

Viigilio'De

LoS

Sa4tos,

Dr.

Emily

D.

De

kon,

Atty'

,..'ErnestoIj.]De]I.os.Santo$.andDr;MaiiaRamonaL.De

:r

'

'

ascendanryrand

control

of

Emily

De

Leon'

over

the

late

:

Virsilio

De

Los Santos

after

the

death'of

Cordelia

De

L,os

.

Saiios

potently

reached

its

piat<;-et*''

,..13',.In{act,onAugust29,z|o 7Lr1r3B-oard'

of Trustees

approved

a resolution

giving

Emily

De

kon

'Vlrgfio

De

iron'a,blanket

authority

to

DRAW

CIIECKS'

'

'

,AitD.l'Bnengn,

'and

'to

sigl

endorse,

accept,

meke,

execute

and.

deliver

ehecks,

notes,

drafts,

acceptances

conferred.

on:Emily

De'I-con

shall

REMAIN

Iry

FULJI

force

and,

effect

until:a

FoRIvIltL

written,

notice

of

such

;;"#;*tJlJrl*r"

becn

issued'

Copv of

thp

Minutgs

lf

,,this'meeting

'dated

Augqst

29,

2OO7

grantinq

this

,

l

'

'

lourority

to

Epil)r

De

Leon'is

hereto

attacf,ed

""

An"e*

,

:

:

ylirsas

shorryn

in the

Notices

of'P,qs1gone11e1i

req{1lf

".&*"a-f,v

etff'

Diosdado

Madrid'

Copies

of

the

.

'iiotie."

are

-hereto

attached.

as

Annexesu4'tou4-Co."

:

I

.,tt58.

.'tTh"

estaie'rsubject

matter'of

probate

is

approximately

Eight

'ff.rllarrO-nniihon iesos:

(Php800,000.00)

composed

of

the

Universitv

of

-1

'r'-

"r'

pe*ils:in

different

places

and

all

other

business

entities'

Manila,

tsal

proPertieS'rn

ctrtlerel

.'.S9.

,,.

Agotn,,;

fluAW

fiv

q14mdatory

co4fetzncei

Ju$euthgn

,*;;,7

ir;fato

thb' Honoru.ble

Commlsetoner

tha

faat

thott

she

tt.ls

slnce',bcen

a'

ntily

altiu,olnce

ftom

tlrr

lmu

Dr'

Vtrylllo

De

'

'

'

"

"

r

corte,tta

oetos

snntos

of

tlw

untuerstty

of

Manltl4'

Ias Santos,cnd

..

.

.

l'

Qutndosa

rccefins

d

tnonthlY

unuld

fust

P4e?3of

28

7/21/2019 1. acts of lav 11-3107


;'t

i'r

iri

:r,

:was,

,lmpotslble

for her

uot

to havd

known

of

hlr

rubstctlng

marrlage.

She

herself

admitted

that

they

were

introduced

by her

friend and

fonrrer

classmate,.Ms.

Morales

who was

'at

fell.ovr

barangay'

officiat

of respondent.

She

admitted,'that

she

knew hiqlresidence,phone

number

and

that she

had called him

there.

She

also knew

that

respondent

is an

active

barangay

offi.cial

who

wen

ran

as

Provincial

Board

Member

int

2o0t.

Curiously,

she

never

refuted

iespondent'.s

allegations

that

she

had met

and,

lalked

to

his

'

wife

on several

occasions,

that dhe'lived

,near

his

residence,

that she-rhelped

hirn

in his

campaign,

orrttrat

she

knew

a lot

of:his

friends,

so,as,notto

have

known

of

his

marital

status.

Considering ttrat

s[e

previously

had

an

alfair

wit]r

Aquino,

who

was also

a

married rnar;

it

woutd

be

unnatural

for

her

to

:

have

jusb,plunged,into

: a

sextral

:relationship

with

respondent

'

whom

she

trad

known

for only a

short-ffie

without

veriSing

.

his

background;

if

it

were

true

that

she

preferred

'to

change

lherl

,life-for,]the

better,"

as

alleged

in;her

complaint.

We

Lellve

that'

her

eforementloned

dlegatlone

of

docsit

were

not

eatabllshed

by

clear

preponderant

evldence

resulred

tn

dtribarment

casec.

we ere

left

wtth the

moct

i"i"J

concluslon'that'rhe

freely

and

wtttlngty

entered

h;;;

ilt.It

and

lmmoral

relatlLurhtP

wtthie:pondent

ans"

e

y

mtetepreientatton

br

decelt:"

ol

hta

part."

(BWt*ii

supptied)

:

67.

Evidence

Presented

follows

that

respondent

has'not

considered,

the

inevitabte

conclqsion

extribited

towards

Juliewhyn

or

to

the

Page

26

of

2E

communitJr

in

general,

immoral

conduct

-

that,

conduct

which

is

willful,

flagran

or

shameless,,and

which

shows

a

moral

indifference

to

the

opinion

"

comrniiniSr

re

that'

would

sf

ths'.good,

and

respeqtable

members

of

the

lerifs:disbarnient.

In

fact,

at

the

time

when

old-fashio-ned

morality

still

prevailed,

it

has

been

held

that

intimacy

between

a

man.and

a

woman

who

are

not

married,

especially

in

the

light

of

the

circumstances

"ttbh

rthis.caser,is

neitJrer'so

colTupt

as

to

constitute'a

criminal

act

nor

so

unprincipled

as

to

warrant

disbarment

or

disciplin4ry

action

against

the

*or

a"

i

meryber'of'tJ:e

Bar'L4

'

'

68,

In

faqt,

comPlamal

orooflb

roa

aemonr**ie:and

substantiate

that

her

present

complaint

comes

=r-

,',,ro,

being

si*il#l,ro,'o,

may

evenr

be

considered

to

come

within

the

amtit

of

those

illustrative.cases

in

Arciga

vs'

'Maniwaf7g,L6

and

coiuangco'

ffi;i;,

us:.:Patma;,4g*,

case

No'

2474'

september

L5'

2044

t+

sobetatn

us.

vittaiEiit'1[c'

No'

215'

December

29'

1962'

t6

A.M.

No,,1608,

August,14,

1981'

-.:

,4

7/21/2019 1. acts of lav 11-3107


..1

Jr,,

us.

Palma,l7

where

lawyers

were

disbarred

for

exhibiting

grossl5r

immoral

conduct.

69.

on

the

contrar5r,

it

has

been

amply

proven

by

respondent

that

the

inslqnt

case

and

all.

otlier

manifold of

cases

were

filed

against

h'erein

lsspondent

to

irregdarly

tlse

our

Courts

of Justice

for

purposes

of

serving

the

inordinate

motives

of

the

complainant

and.

her

cohorts,,

70.

',

Complainant

fraving

railed

to

overcome

the

imperative

prgp4trlptlon

of

tnnocen:ce'l.n

fannr

of

resffident-lawyerl8

and

being

MALICIOUS,

FABRICATED

and

foT LACK

OF FACTUAL

AND

LEGAL

BASIS

:

it is

most

respectfully

prayed

of

this

Honorable

Commissioner

that

the

instant

case

be

DISMISSED.

.PRAYER

overcome

'the

imperative

prqur4gttlon

of

lnnocence

ln

fannr

of

reSpg.nfunt-lantger,,and

being mallclous, fabrlcated

and

for l,ack

of

factrial,,

and

legal

basle'it

is 'most

respectfutly prayed

of

this

Honorable

Commissioner

that

the instant

case be

DISMISSED.

Other,reliefs

just

and equitable under the

premises

are

likewise

prayed

for.

RESPECTFULLY

SUBMITTED

,,\

I

..

JUDITH.ZARRAGA

LUIS

,1

.

LAWFIRM

:.

Coungetforthe

Respondent

7256

J. Victor

St., Bara4gay

Pio

del

Pilar

t:

"

'

feL/Fax

Nos.

822'49-Ogl468-06-12

t7

Note

12,

supra

:

,u

i;ii*i"l"lfi;s.

Baduel;

ADM.

CASE

No.

5134,

psssmber

74,2Oo5,477

SCRA62L.

.

Page

27

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7/21/2019 1. acts of lav 11-3107


ROLL

No.

38963

MCLEIII,Compliance

No.

OO2O414;

April

13,2011

PTR

No.

VC-96[U0

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15,r20o5

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Compliance

No. IV-0002500

/

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CARAIG

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:Copy

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paV

of rcgptored

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.l,lRGq,IO

A.

GABIITGO

Counsel

for

the

ComPlainant

'fhe

Law

Offi.ce

of'Virgilio

A.

Garingo

Capitol

ComPorrnd

Trecer

Martires,

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ive

the

same.

Page

28

of28

7/21/2019 1. acts of lav 11-3107


(

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REPUtsLIC

OF

THE

PHILIPPINES

.,1

VERIFICATION

)

)

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i,

,

,

I; E.gp' To

DE l,os,

s,l$Tos,

of legal

age,

Filipino,

and.

lr,ith

residgnce.at

roS,cenacle

Drive

Sanville,

Tandang

Sora,

euezon

city,

after.

,h4ying,

been

dul)r

swofn

to

in

accordance

wit]:

law

hereby

deposes

and

states

that:

'-*1l.44'

1.

I

arn

the

respondent-appellant

in

the

above-entitled

case;

2.

I

have

,camsed

the

preparation

of:the

foregoing Position

Paper

and

the

filing

s111re

same;

3.

I

have

read

the

atlegations

thereof

and

found

the

same

to

be

true

and

correct

out of my o\

/n

personal

knowledge

and as

based

on

authentic

records

and

documents;

i> t.

IIY

WITilESS

WIIEREOF,

havp hereunto

l.f,fl'

.day.^r

of

.,

'l*-"Uy_

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ll

ho'y^

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signed

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document this

2O1,L',

here

at

6.r"%

A-,/*;:{&

ERI{ESTO DE

IJOS SANTOS

2i,oL,L,

aflient

'with

xhibiting

o:

-rrr€'

hisi

picture,and''sigfrature'

appearing

thereon, &s

competent

evidence

of

his

identity.

AIID

'SWORII

TO

before

me this

]lx*t

day

of

b

NoTARY

PUBLIc

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rp

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Doc.,frl6,

,Page'No.

Book'No.

Sbries

of

Documents

1. acts of lav 11-3107