ON CUDIA -- NO PROOF 'CHAMBERING' ALLOWED; SECRET BALLOTING MUST BE UPHELD
ON CADET ALDRIN JEFF P. CUDIA CASE
NO PROOF 'CHAMBERING' ALLOWED;
SECRET BALLOTING MUST BE UPHELD
These are some of the points I raised in the Motion for Reconsideration that I filed today, 30 March 2015, at the Supreme Court, arguing against what we firmly believe as incorrect rulings of the Highest Court of the land.
Let me cite, by the way our strongest points in our discussions of argument, regarding inconsistency of secret balloting to co-exist with chambering to attempt to change the mind of the one who dissented to the majority, to wit:
The summary of the points I raised can be known from the Grounds I raised, as follows:
NO PROOF 'CHAMBERING' ALLOWED;
SECRET BALLOTING MUST BE UPHELD
These are some of the points I raised in the Motion for Reconsideration that I filed today, 30 March 2015, at the Supreme Court, arguing against what we firmly believe as incorrect rulings of the Highest Court of the land.
Let me cite, by the way our strongest points in our discussions of argument, regarding inconsistency of secret balloting to co-exist with chambering to attempt to change the mind of the one who dissented to the majority, to wit:
SECRET BALLOTING
INCOSISTENT WITH
CHAMBERING
Nothing can justify co-existence of secret balloting with chambering.
Any judge who does justify commits an act of grave abuse of discretion.
Ergo, it is a patent error for the Supreme Court En Banc to rule “executive session” or “chambering” is not at all prohibited or that “there is nothing inherently wrong with the practice of ‘chambering’”, with due respect.
With this premise, all the justifications written in the decisions for chambering are absurd to say the least.
Why the heck would the voters go to a secret balloting if one of them would be chambered anyway to explain the vote contrary to what majority expressed?
If they would be chambered anyway to explain each’s vote contrary to the majority’s opinion, they better do the voting in viva voche or raising of hands.
What about the interest of complete fairness that deliberately avoids any suggestion that will subject the decision-making to suspicion? It is not a question of whether one voter who was “chambered” was actually intimidated or not. It is rather the issue of removal of any cause of suspicion of unfairness. And the fact that there was that second stage that is a clear attempt to modify the vote after the submission of secret ballots generates suspicion of unfairness.
The summary of the points I raised can be known from the Grounds I raised, as follows:
With due respect to
the Court En Banc, it committed errors as follows:
(1) In overlooking that SECRET BALLOTING IS NOT CONSISTENT WITH
CHAMBERING so that if it was established by the Supreme Court that the voting on
Aldrin Jeff Cudia’s case was done by secret ballots, chambering can never be
allowed;
(2) In not noting that it is undisputed and established that all
voters are asked first if they were ready to vote and only after all voters said
they were ready can the voting begin;
(3) Claim of “New Practice” of chambering has no proof and not written
in the Honor System procedure or the “Procedure During Formal Investigation”;
(4) In rejecting the CHR’s findings of facts taken with full
formalities and solemnities while doing the opposite giving full faith even without
any supporting evidence to mere allegations of Cadet Lagura, particularly on
the claim that Siklab Diwa Class of
2014 since their first year practiced “chambering”;
(5) Assuming that the High Court has the power to determine the truth
or falsity of the affidavit of Cadet Lagura, the Honorable Court failed to note
that the claim of Cadet Lagura in his affidavit that chambering was practiced
by Siklab Diwa Class of 2014 is highly improbable to be believed in;
(6) In accepting with 100% faith the affidavit of Lagura when the High
Court is not a trier of facts and when Lagura stated two inconsistent
positions:
a. Lagura said in Paragraph 6 and Paragraph 7 that after the votes
were collected and counted and showed a result of eight (8) for “guilty” and
one (1) for “not guilty” they were told to go inside the chamber where he
listened to all other voters explaining to him their “guilty” votes: and
b. Lagura said in Paragraph 10 of the same affidavit that only two
cadets, Cadet Mogul and Cadet Arlegui, were with him inside the chamber;
(7) In not noting the “next-to-impossible” claim of Lagura in
Paragraph 5 of his affidavit where Lagura claimed that he voted “not guilty”
comfortably because he claimed he voted “not guilty” with a reservation in his
mind that they will still be discussing their verdicts if they arrive at 8-1 or
7-2 vote – It is “next-to-impossible” for this claim of Lagura to have happened
because no person can be assured that the vote shall be 8-1 or 7-2;
(8) In ruling that Cadet Cudia can go for his career or school
anywhere except for the PMA but the Supreme Court did not order the PMA to
remove the statement “on indefinite suspension” at the end of the transcript of
records (TOR) and give him clearance to enroll somewhere else in order to
graduate with a baccalaureate degree.
If you are interested to read the entire Motion for Reconsideration, here it is:
Republic of the
Philippines
Supreme
Court
Manila
FIRST CLASS CADET ALDRIN
JEFF P. CUDIA of the Philippine
Military Academy represented here
by his father RENATO P. CUDIA
who also acts on his own behalf
and BERTENI CATALUÑA CAUSING,
Petitioners,
- versus - G.R. No. 211362
THE COMMANDANT &
THE SUPERINTENDENT OF THE
PHILIPPINE MILITARY ACADEMY
(PMA), THE HONOR COMMITTEE (HC)
OF 2014 OF THE PMA and HC MEMBERS,
and CADET REVIEW AND APPEALS
BOARD (CRAB),
Respondents,
x--------------------------------------------------------x
FILIPINA P. CUDIA, in behalf of CADET
FIRST CLASS ALDRIN JEFF P. CUDIA,
and on her own behalf,
Petitioner-Intervenor,
x--------------------------------------------------------x
Motion for Reconsideration
The petitioners, by
the undersigned counsel, respectfully move the Honorable Court to RECONSIDER
its Decision promulgated 24 February 2015.
The Timeliness
On 17 March 2015 the undersigned received a
copy of the Decision.
The fifteen (15) days within which to file
this Motion for Reconsideration falls on 1 April 2015.
Hence, the filing of this Motion for
Reconsideration today, 30 March 2015, is timely.
The Grounds
With due respect to
the Court En Banc, it committed errors as follows:
(1) In overlooking that SECRET BALLOTING IS NOT CONSISTENT WITH
CHAMBERING so that if it was established by the Supreme Court that the voting on
Aldrin Jeff Cudia’s case was done by secret ballots, chambering can never be
allowed;
(2) In not noting that it is undisputed and established that all
voters are asked first if they were ready to vote and only after all voters said
they were ready can the voting begin;
(3) Claim of “New Practice” of chambering has no proof and not written
in the Honor System procedure or the “Procedure During Formal Investigation”;
(4) In rejecting the CHR’s findings of facts taken with full
formalities and solemnities while doing the opposite giving full faith even without
any supporting evidence to mere allegations of Cadet Lagura, particularly on
the claim that Siklab Diwa Class of
2014 since their first year practiced “chambering”;
(5) Assuming that the High Court has the power to determine the truth
or falsity of the affidavit of Cadet Lagura, the Honorable Court failed to note
that the claim of Cadet Lagura in his affidavit that chambering was practiced
by Siklab Diwa Class of 2014 is highly improbable to be believed in;
(6) In accepting with 100% faith the affidavit of Lagura when the High
Court is not a trier of facts and when Lagura stated two inconsistent
positions:
a. Lagura said in Paragraph 6 and Paragraph 7 that after the votes
were collected and counted and showed a result of eight (8) for “guilty” and
one (1) for “not guilty” they were told to go inside the chamber where he
listened to all other voters explaining to him their “guilty” votes: and
b. Lagura said in Paragraph 10 of the same affidavit that only two
cadets, Cadet Mogul and Cadet Arlegui, were with him inside the chamber;
(7) In not noting the “next-to-impossible” claim of Lagura in
Paragraph 5 of his affidavit where Lagura claimed that he voted “not guilty”
comfortably because he claimed he voted “not guilty” with a reservation in his
mind that they will still be discussing their verdicts if they arrive at 8-1 or
7-2 vote – It is “next-to-impossible” for this claim of Lagura to have happened
because no person can be assured that the vote shall be 8-1 or 7-2;
(8) In ruling that Cadet Cudia can go for his career or school
anywhere except for the PMA but the Supreme Court did not order the PMA to
remove the statement “on indefinite suspension” at the end of the transcript of
records (TOR) and give him clearance to enroll somewhere else in order to
graduate with a baccalaureate degree.
The Discussions
SECRET BALLOTING
INCOSISTENT WITH
CHAMBERING
Nothing can justify co-existence of secret balloting with
chambering.
Any judge who does justify commits an act of grave abuse of
discretion.
Ergo, it is a patent error for the Supreme Court En Banc to
rule “executive session” or “chambering” is not at all prohibited or that
“there is nothing inherently wrong with the practice of ‘chambering’”, with due
respect.
With this premise, all the justifications written in the
decisions for chambering are absurd to say the least.
Why the heck would the voters go to a secret balloting if
one of them would be chambered anyway to explain the vote contrary to what
majority expressed?
If they would be chambered anyway to explain each’s vote
contrary to the majority’s opinion, they better do the voting in viva voche or raising of hands.
What about the interest of complete fairness that
deliberately avoids any suggestion that will subject the decision-making to
suspicion? It is not a question of
whether one voter who was “chambered” was actually intimidated or not. It is rather the issue of removal of any
cause of suspicion of unfairness. And
the fact that there was that second stage that is a clear attempt to modify the
vote after the submission of secret ballots generates suspicion of unfairness.
Before amplifying
these and other points to prove why secret balloting is not consistent with the
claim of existence of chambering, let it be resolved first that secret
balloting was used in the voting done in the case of Cadet Cudia.
In all contests of allegations that have no supporting
evidence, the judges based their conclusions as to the truth or falsity of the
allegations on the way the witnesses deliver their testimonies.
In a
situation where the Supreme Court is provided only with affidavits and no
supporting evidence, the High Court that is not a trier of testimonies has no
authority to say whether certain affidavits alleged the truth. The most that the High Tribunal can do is to
look for admissions or declarations in favor of the interests of the parties
adverse to the affiants.
In this
case, no less than the respondents admitted that in the case of Cadet 1CL
Cudia, the Honor Committee (HC) conducted the voting by secret balloting and
they also admitted that they conducted “chambering” to question Cadet 1CL
Lagura when the ballots turned out that the vote was 8 “guilty” and 1 “not
guilty.”
The respondents
presented the affidavit of Cadet 1CL Lagura where the affiant said in Paragraph
No. 6 that the votes were collected where the verb “collected” must have
referred only to the secret ballots filled up by the voters and said in
Paragraph 7 that Lagura asked for another sheet of voting paper.
The Supreme Court cited the “Procedure During Formal
Investigation,” said to be a supplement to the Honor Code and Honor System
Handbook, where it is stated that “voting is done by secret ballots” and that
after the deliberation by the voters the blank ballot sheets are distribute to
each of the voting members who then signify his vote by writing “Guilty” or
“Not Guilty.”
At any rate, it is established that secret balloting was
done in the case of Cadet 1CL Cudia.
The next factual issue to be resolved is whether the vote at
the secret balloting was eight (8) “Guilty” and one (1) “Not Guilty.”
Because
the respondents submitted the affidavit of Cadet 1CL Lagura, where he admitted
that he voted “Not Guilty” in the secret balloting, it is already admitted that
indeed the vote was 8-1 during the secret balloting.
Now, let
it go to whether or not there was “chambering” that was conducted after the
secret balloting.
Again, because
the respondents submitted the affidavit of Cadet 1CL Lagura, where he admitted
that the Honor Committee conducted the so-called “chambering” after the vote
turned out to be 8-1, it is now deemed settled that indeed there was
“chambering” that took place after the vote turned out to be 8 for “guilty” and
1 for “not guilty.”
Finally,
let it go to the factual issue of whether the “chambering” resulted in the lone
dissenter, Cadet 1CL Lagura, changed his vote from “Not Guilty” to “Guilty.”
This is
also admitted no less than by Cade 1CL Lagura.
The only
issue left now is legal: whether or not the holding of “chambering” or
“executive session” is null and void and as such it is a grave abuse of
discretion.
We beg to
disagree with the Honorable Court En Banc.
There is
no other conclusion that is acceptable by men in the whole of the universe:
that chambering is an act of grave abuse of discretion when there was already a
vote taken and when the purpose is to change the vote.
Let now
the reasons cited by the Honorable Court be refuted.
First,
the High Court ruled that “executive session” or “chambering” is not at all
prohibited. It based its ruling on a passage from Page 25 of “The Honor Code
and Honor System Handbook”, Series of 2011, Rollo, p. 165.
The said
passage read:
After a thorough discussion and deliberation,
the presiding member of the Board will call for the members to vote whether the
accused is GUILTY or NOT GUILTY. A
unanimous vote (9 votes) of GUILTY decides that a cadet is found guilty of
violating the Honor Code.
First, it
is a doctrine that the power to hear and decide is jurisdictional and as such
it is substantive.
Second,
power, including the power to judge, cannot be presumed. It must be expressed and vested by a statute.
Third,
anything that prejudices rights must first comply with the Substantive Due
Process requirement. That it must be
published first or be notified first to all persons who may be affected
progressively, not retroactively, before it can validly prejudice a
person.
This is
akin to the wisdom in the principle that states: “There is no crime if there is
no law punishing” (Nullum crimen nulla
poena sine lege.)
This
means that if the power to decide is exercised without jurisdiction, that
decision is null and void.
In the
case of school discipline, as part of the bigger zone of academic freedom,
their right or power to exercise discipline can never be unlimited. There must be a set of standards established
for that purpose.
Under the
present regime, there is no law that specifically defines what acts must be
punished by every academic institution and how shall the procedure be in
arriving at a decision whether to punish or not.
Every
school, including the Philippine Military Academy, has freedom on how to perform
or exercise the power or right to impose disciplinary rules on its own
students. But that freedom is not
unbridled, else it will result in chaos and abuse.
In the
exercise of this power or right to discipline students, every school, including
the PMA, has the obligation to come up with its own set of rules.
If a
school has no definite rule because it failed to establish or promulgate one,
it is allowed by general laws to exercise the power or right to discipline its
students; but it is nevertheless required to follow the general law established
by the statutes and jurisprudence. In
the PMA, it has its own Honor Code and Honor System.
The
procedure laid out in the established rules shall be followed strictly. And the only way to treat what are
established rules is to know what are written.
All others cannot be presumed and bear the heavy burden of proof.
It cannot
be denied that among these established rules of school discipline is the power
to vote whether a student subjected to disciplinary procedure is guilty or
not.
As such,
the power to vote can be exercised only by those who are empowered or entrusted
to vote as written in the rules of school discipline and exercised only by
means what the written rules state.
In the
instant case, the provision in the HC and HS Handbook does not say beyond
saying “after a thorough discussion and deliberation, the presiding member of
the Board will call for the members to vote.”
Because
it is established that the manner of voting is by secret ballots, it only means
that once the vote is called and cast by submitting the filled-up secret
ballots, the voters have spoken and what they wrote in the ballots cannot be
reviewed or modified even if those votes are deemed erroneous.
Because
the said HC and HS Handbook provision does not say of chambering the minority
voters, it follows that the minority has no power or jurisdiction to change vote.
And
because it is proven that Cadet 1CL Lagura admitted he was chambered and
changed his vote in the chamber, his new vote of “Guilty” is null and void.
Note that
in the provision cited by the Supreme Court, it is required that before voting
the discussion and deliberation on the issues involved must be thorough. So what is the use of this thorough
discussion and deliberation if only those who voted in the minority will be
chambered and face the possibility of changing vote?
It is
therefore absurd to say that just because “chambering” is not prohibited it can
be done.
To say
that one act not prohibited can be done refers only to harmless acts or acts
that do not impair vested rights.
In this
case, it is already a vested right of Cadet 1CL Cudia to hold on to the result
of the secret balloting. For him to be
held liable by means of “chambering” is not authorized by the Honor Code and
Honor System.
From the
foregoing, it can now be said that the essence of secret balloting is not
addressed to the correctness of the decision but to the bigger interest of
fairness.
Additionally,
it is erroneous for the respondents to justify that chambering is necessary
because of the criticism that one sympathetic voter can acquit an accused in the
secret balloting. It is two-fold. It can also be said that the additional
procedure meant to ensure guilty verdict will also be erroneous if the accused
cadet is innocent and it happened that only one or a minority saw his
innocence. In this case, it becomes a
tyranny of the majority.
Further, there is the higher interest to achieve highest fairness
possible, a kind that deliberately avoids any suggestion that will subject the
decision-making to suspicion in the eyes of the public.
So that
it is erroneous for the High Court to justify chambering just because there is
no proof that the one who was chambered, Cadet 1CL Lagura, was actually
intimidated.
It is
rather the issue of removal of any cause of suspicion of unfairness that
chambering is not allowed. There is no
doubt that the chambering meant to modify the vote after the submission of
secret ballots generates suspicion of unfairness.
Moreover,
it is erroneous for the respondents to posit that chambering is like a
procedure in the jury in order to justify it.
In jury
trial, jurors go to the chamber after the trial and they do not have any
decision yet at that moment.
The
jurors will deliberate and discuss all issues of a case inside the chamber. The jurors will review the evidence
presented. They will debate each other
as to what do the pieces of evidence say.
After these, they will come to a vote.
The
objective of the jurors is to come out with a unanimous vote of “guilty” or
unanimous vote of “not guilty.” So that
the jurors have no time limit up to when they can achieve a unanimous vote.
In the
Honor Committee, the voting members have no obligation to vote unanimously for
the finding of “not guilty” in order to acquit. Their only obligation is to come up with a
unanimous vote of “guilty” to convict.
So that if all the jurors in the Honor Committee say they are ready to
vote, as soon as all the ballots are cast the vote must end. The result terminates the procedure.
VOTERS ASKED IF THEY
WERE READY TO VOTE
NEGATES CHAMBERING
One thing that negates the claim that chambering
is legal is the fact that it is undisputed and established that all voters are
asked first if they were ready to vote and only after all voters said they were
ready can the voting begin.
What then is the purpose that the voters were
all asked first to signify if they were ready or not and if they say they are
ready they will vote?
There is no other possible purpose but to
ensure that if the jurors of the Honor Committee are not ready there shall be
no vote and if all are ready all shall now vote.
So that when the voting members of the Honor
Committee vote it means they are all informed of the evidence for each of them
to make an intelligent vote.
It is therefore presumed that when the voting
members of the committee vote they are making their intelligent decisions.
And if the vote is presumed intelligent,
there is no legal reason to question each voter and subject him or her to
chambering.
With this, it is therefore improper and
highly irregular to attempt to change the mind of any voter.
From the start, the intention and the system
is clearly seen why there is a need for the voting members to discuss and
deliberate the case thoroughly: That
there shall be no more voting to be done after the votes are cast.
NEW PRACTICE OF
CHAMBERING HAS
NO PROOF OF EXISTENCE
The claim
of Cadet Lagura and Cadet Mogul that the practice of “chambering” was practiced
and allowed in Siklab Diwa Class 2014
for four (4) years since their first year is not true.
The claim
of Mogul and Lagura that this “New Practice” of chambering existed has no proof.
It is not
written in the Honor Code and Honor System Handbook.
It is not
also written in the alleged “Procedure During Formal Investigation,” which was
presented to the CHR according to its report cited by the Supreme Court as
Footnote No. 199.
In the
same footnote, it said:
Here, the Committee (voting members) engages in an open and
thorough discussion of the merits and demerits of the case. The presiding officer then aligns the
different circumstances, mitigating and aggravating and once again present the
evidences to the voting members for examination. After which, the Presiding Officer will ask
the Voting Members if all of them are ready, satisfied and ready to vote. Just one member (not) ready to vote will
postpone the voting and continue the deliberation until all doubts are cleared.
Voting is done by secret ballots. After deliberation, the blank
ballot sheets are distributed to each of the voting members who then signify
his vote by writing ‘Guilty’ or ‘Not Guilty’ and justify why he write the said
vote. The Presiding Officer counts the
ballots and announces the result to the Committee.
COURT HAS NO AUTHORITY
TO GIVE FULL WEIGHT TO
LAGURA’S AFFIDAVIT &
REJECT
CHR FINDINGS OF FACTS
The Supreme Court has no power to try to determine
facts. It therefore has no power to say
that the affidavit of Cadet 1CL Lagura is true or believable.
That is,
even if Cadet 1CL Lagura was the one who is at the center of the controversy.
This
cannot be supported by any principle of evidence or Rules of Evidence.
And if
the High Court gave credence to the affidavit of Lagura when there was no
justification, it is absurd for it to reject the findings of facts by the Commission
on Human Rights (CHR) that is a Constitutional body when these findings were a
result of the performance of its official functions.
There is
no issue that it is only recommendatory.
But when there is no contrary evidence better in quality, the same must
be persuasive enough.
Between
the affidavit of Lagura and the CHR findings of facts, the latter has more in
quality in terms of believability.
It cannot
be denied that the facts of the CHR were taken with full formalities and
solemnities, all witnesses were put under oath to testify the truth and nothing
but the whole truth.
HIGHLY IMPROBABLE
CLAIM OF LAGURA
Moreover,
it is absurd to believe in Lagura’s affidavit when all his allegations were not
even supported by evidence, particularly the claim that Siklab Diwa Class of 2014 since their first year practiced
“chambering.”
How can
it happen that the new practice has been practiced at the behest of Siklab Diwa Class when its members had
no actual power to dictate on their seniors holding the reins of the Honor
System or the Honor Committee when they were in first year?
Even if
the members of Siklab Diwa Class of
2014 were in their senior years, they cannot control the Honor System and the
Honor Committee when all other members came from three classes, the junior, the
sophomore and the freshmen.
BELIEVING 100% IN
AFFIDAVIT OF LAGURA
Even if
the Supreme Court is authorized, it is absurd for it to give 100% faith in the
affidavit of Lagura.
The High
Court must have overlooked two inconsistent positions stated by Lagura.
Lagura
said in Paragraph 6 and Paragraph 7 that after the votes were collected and
counted and showed a result of eight (8) for “guilty” and one (1) for “not
guilty” they were told to go inside the chamber where he listened to all other
voters explaining to him their “guilty” votes: and
Now, Lagura said in Paragraph 10 of the same
affidavit that only two cadets, Cadet Mogul and Cadet Arlegui, were with
him inside the chamber.
NEXT-TO-IMPOSSIBLE
CLAIM OF LAGURA
The
Supreme Court must have also overlooked the “next-to-impossible” claim of
Lagura in Paragraph 5 of his affidavit.
In this
paragraph, Lagura claimed that he voted “not guilty” comfortably because he had
a reservation in his mind that they will still be discussing their verdicts if
they arrive at 8-1 or 7-2 vote.
It is
“next-to-impossible” that this claim of Lagura happened. It is because nature says that no person can
be assured that the vote shall result in 8-1 or 7-2 to have an opportunity for
discussions.
IMPROPER FOR COURT
TO MAKE FINDINGS OF
FACT THAT CUDIA IS GUILTY
The Honorable Court was correct in stating that not being a
trier of facts it cannot pass upon the issue of whether Cadet Cudia lied.
But by way of “supplementing” some points, it passed upon
the same issue.
To the mind of the petitioners, this is improper.
FINDINGS OF HC, CRAB,
PMA NOT SUPPORTED
Contrary to the ruling of the Honorable Court, there are
actually findings by the HC, CRAB and the PMA not supported by evidence.
The finding alone that the “chambering” was allowed is not
supported by any written rule or evidence of practice.
The affidavit of Cadet Lagura is not the evidence allowed to
support the finding that “chambering” was allowed.
‘ON INDEFINITE
SUSPENSION’
At the end of the Transcript of Records of Cadet Cudia,
there is stated “ON INDEFINITE SUSPENSION.”
With this phrase, Cadet Cudia cannot be accepted by any
other academic institution if he enrols just to complete his baccalaureate
course.
No less than the Court stated that nobody can deprive Cadet
Cudia from the choice of seeking equally-noble profession in the civilian
career.
However, how can he enrol in other schools if there is this
phrase “on indefinite suspension” at the end of his Transcript of Records?
With this problem, the Honorable Court must order the PMA to
remove the phrase “on indefinite suspension” at the end of the TOR and direct
the same to allow Cadet Cudia to enrol somewhere else.
The Prayer
WHEREFORE, it is respectfully prayed of the Honorable Court that its Decision
promulgated February 24, 2015 be reversed.
Additionally,
it is prayed that the Court directs the PMA to remove the phrase “ON INDEFINITE
SUSPENSION” at the end of the Transcript of Records of Aldrin Jeff P. Cudia be
removed and the PMA issue him a certification that he is cleared to enrol in
other educational institutions.
Other
reliefs just and equitable under the circumstances are likewise prayed
for. Manila, 30 March 2015.
Causing Sabarre Castro Pelagio
Unit 1, 2368 JB
Roxas St. corner Leon Guinto St., Malate, Manila
By:
BERTENI CATALUÑA
CAUSING
IBP
No. 949537/ 06-01-2015 / Manila IV
PTR
No. 3834103 / 06-01-2015 / Manila
Roll
No. 60944/MCLE No. IV – 0007338 issued 10 August 2012
EXPLANATION
Lack of personnel and distance
compelled services by mails.
BERTENI CATALUÑA CAUSING
Cc:
1) Office of the
Solicitor General (by registered mail Reg Rec # _____
134 Amorsolo Street,
Legaspi Village, 1229 Makati City Date _________
2) PUBLIC
ATTORNEY’S OFFICE, DOJ Agencies Bldg., Reg Rec # _____
NIA Road corner East Avenue,
Diliman, Quezon City Date _________
3) The Commandant
& The Superintendent Reg
Rec # _____
Philippine Military
Academy, Fort General Gregorio H. del Pilar Date
_________
Loakan Road, 2600 Baguio
City
4) Cadet Review
& Appeals Board [CRAB] Reg Rec #
_____
Philippine Military
Academy, Fort General Gregorio H. del Pilar Date _________
Loakan Road, 2600 Baguio
City
5) Honor Committee
Chairman [HC] Reg
Rec # _____
Philippine Military
Academy, Fort General Gregorio H. del Pilar Date
_________
Loakan Road, 2600 Baguio
City
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