1. acts of lav 11-3107
TRANSCRIPT
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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460
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5580,
Junt
Pasig
CitY
.fULIEU[fyN,R,
oulNDOZA,
.
ComPlainant,
ESTO
L'
DELOS
SAilTOS'
through
the
Responclenti
IAfTY'
ERI{I
ion,
most
tto
this
Honorable
Commiss:
undersigned
counsel
and
ur
t
PaPer
and
state
that:
respectfuliy
subutits
tl.is
Position
Paper
ano
sLaL(
ATTY.
ERI{ESTO
".
L.
DE
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
tnrrocence
_
sanctionr
,ob""ilnae
of,due
p
>
burden
of
ln
fawr
of
o,ii
.,
*
t*,era'*,a,2
Sr.Ich
being
the
case',
tht
;
$
fu
iartnirrnt
to
otta
c
o
me
swcf.
P
r
e
suttYtior
t''
proof
is
on
tft;r
,
r
''
''
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i
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urrat
there
ls
an
q,ea
wh,re
a'
lnwgefs
It
has'leen
:ec:r'"*'-7i^ii*';'
;''tn-
rn"
tonons
o
the
mofg;t
code
conduct
fiorg
not
be
inconso'----
becattsehls
mlsb
,..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**,
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s1"34,
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Pagc
1
of28
7/21/2019 1. acts of lav 11-3107
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":,
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
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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
':
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,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':-^O1".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
'
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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
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.
...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
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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
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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$.i::Dirring
such
time,
respondent
was
flooded
with
love
notes
and
pictures
coming
from
the
Juliewhyn.
Rernaining
copy
of
the
picture
**S
"tt
"hed
to
respondent's
Answer
as
Annex
u4',
whlch
was.
ordmltted:,
6y
,Jtrtlewlrrgn
,'durlng
the
ng;ndqitory
co4fetence
o,t
Ilccentber
2,
2O77;
L2.
Juliewhyn
only
s'tayed
in
the
university
for
a
brief
period
of
less
.
----l
::-
)2cC.
than
a
year
or
so
and
theleafter
engaged
in
different
endeavors.
Though
no
longer
studyrng
in
the
University,
she
frequently
visits
respondent
in
the
Ermita
Tourist
Inn,
a
business
establishment.
also
owned
by
respondent's
Mfidavit
of
Yoland
a
Cdlanza
famrty
where
he
also
previously
held
office'
ThO
'
attesting
to
this
fact
was
4ttached
to
respondent's
Answer
as
Annex
*5';
workingindifferentprovincesawayfromtherespondentwou
surprise
the
latter
by
her
unexpected
visit
in
Ermita
Tourist
Inn'
Juliewhyn
during
those
vrgits
*oUtd
in
turn
1ve' |:t
*
her'need
for
financial:help,'
olll
thaee'utstts,
as
well
as
tl1'E
t"lason
for
""tn
alstts
uqne
dutg
admttted
bg
Juttewhgn
durlng
the
ng;ndatory
.L4.Byreason]:olrespondentbeingapublic.figure,itta:<esones
credulity
that
Juliewhyn
has
no
knowledge
about
his
family
status
from
1988
up
to
L994
or
a,
yeqr after
she
gave
birth
to
respondent's'
daughter'
'
1^ G'll lrnnrr Actloe
marital
and
Mergarett.Veronica..Havingsuchfullknowledge.ofrespondent,s
'familystatus,.Juliewhyn,sallegationst]ratrespondentrepreset
l
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as
slngle
*d
that
there
was
a
sincere
mdhtrg.
proposal
by
the respondent
to
Juliewhyn
is
implausible;
B. Respondent
ltq,s
netter lhrcd-
less uetballg,
or
ihgstca;llg
ahteed hcr
:
'
15.
ContrSly
to
Juliewhyn's
allegations,
re-spondent
has never
lived-
in
with,
much
less
verbal$
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
;
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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
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'
-
--,|
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'
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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
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'
.
+,,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'<e1'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
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,;
.,,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
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L4 of?a
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.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
c^ogorltiot"
**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
\.
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-'
--.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:
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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;
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l:
,
,
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
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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;
':']
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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
message
to
the
respondent.
Copy
of
the
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
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'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
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'
.,.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:
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-
.,,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
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28
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;'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
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..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
of28
7/21/2019 1. acts of lav 11-3107
http://slidepdf.com/reader/full/1-acts-of-lav-11-3107 26/27
ROLL
No.
38963
MCLEIII,Compliance
No.
OO2O414;
April
13,2011
PTR
No.
VC-96[U0
IBP Life
Meh
.
'
.o,'R,,'No.
650003
/
April
15,r20o5
MCLE
Compliance
No. IV-0002500
/
August
CARAIG
/,o
-2O
L1'/
Valenzuela
CitY
L6,2,011
:Copy
nrntned
b1
paV
of rcgptored
nallr
AT[Y,
.l,lRGq,IO
A.
GABIITGO
Counsel
for
the
ComPlainant
'fhe
Law
Offi.ce
of'Virgilio
A.
Garingo
Capitol
ComPorrnd
Trecer
Martires,
Cavite
'JUtIDlwIm{
R,
QTIIITDoaA
'
Nor
39-A
Everlasting
Street
W
fi,**q
&(+
fiorr"
htrk
flA+
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ilyrr- lL
tH[(
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f
MV
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P.T.R,NO.
4632815
'I"B.P.
l,ifetime'
Nd.,0995
1
Quezon
City
i
i
[s
been
filed
and
iredictable
traffic
ive
the
same.
Page
28
of28
7/21/2019 1. acts of lav 11-3107
http://slidepdf.com/reader/full/1-acts-of-lav-11-3107 27/27
(
.I
, ""ii
,.,i
:'
f;. _.
i ,i'
REPUtsLIC
OF
THE
PHILIPPINES
.,1
VERIFICATION
)
)
,
i
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_
-
-
ll
ho'y^
"
(^+n
Q1a,L
-
ry
signed
this
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
,Jh
n
rp
LG
e
o*
tr{ret.,t/h
C,
OTraltut
pffiu1o
yry
.tetL
Doc.,frl6,
,Page'No.
Book'No.
Sbries
of