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Republic of the Philippines COURT OF APPEALS Manila

FAIRYLAND PROTECTORS ON BEHALF OF THE RESIDENTS OF LOS BAOS AND CALAMBA CITY Petitioner, -versusMARIANG MAYBANGA MINING INC. (MMMI), MINES AND GEOSCIENCES BUREAU (MGB) Respondents. x-------------------------------------------x

CA-G.R. SP. NO. 23225 (Petition for Writ of Kalikasan with prayer for Temporary Environmental Protection Order [TEPO])

REQUEST FOR THE AN ORDER OF INSPECTION

Petitioners, through the undersigned counsels, and to this Honorable Court, respectfully requests the issuance of an Inspection Order to permit entry onto designated premises, land, or other property possessed or controlled by MARIANG MAYBANGA MINING INC.

It has been presented through the petition filed that by reason of the respondents open pit mining operations in Mt. Maybanga, a significant portion of the said mountain was lopped off. As a result of such environmental mutilation, the areas surrounding the mountain were exposed to increased risks of devastating floods, due to the inability of the mountain to contain the rainwater.

The natural defenses of the municipalities of Los Baos and Calamba against flash floods were reduced to a disastrous extent. Through the annexes

shown in the petition filed, assessments reports of previous typhoons reflect the average nature of floods that occur in the municipalities of Los Baos and Calamba. These were considered mild compared to the ones that resulted from the landfall of Typhoon Helena because the floods that devastated the two municipalities in June 2013 was unprecedented and incapable of prediction. Furthermore, a study made by the UP Los Baos College of Forestry and Natural Resources showed that the floods were caused by a heavier flow of water from nearby Mt. Maybanga. The same study also provided that the heavy flow of water was directly caused by the looseness of the soil in the upper layer of the mountain, which was brought about by an unnatural circumstance to which the petitioners attributre to respondent MMMIs open pit mining.

In order to obtain more information vital to the cause of the petitioners and as to prove that although the government through the Mines and Geosciences Bureau (MGB) awarded respondents the permit to operate and continue their mining operations, the respondents MMMIs open pit mining operations are detrimental to the Environment.

It is because of these circumstancesSpecifically the area of Mt. Maybanga where the mine was being developed so that the Petitioners Fairyland Protectors through its President Mick Alagma and other authorities may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.

Respectfully Submitted.

City of Manila, August 10, 2013.

RENE PILAPIL JR. Counsel PTR No. 456789/2-1-13 Roll of Attorneys No. 24404 IBP No. 892342/2-17-10/Manila MCLE Compliance Cert. No. Exempted JOVY ANNE QUERUBIN Counsel PTR No. 123456/2-2-13 Roll of Attorneys No. 27707 IBP No. 923433/2-7-13/Manila MCLE Compliance Cert. No. Exempted

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