Beruflich Dokumente
Kultur Dokumente
ASSOCIATSION
PREFATORY STATEMENT
1. A Notice of Hearing from the National Water Resources Board
(NWRB) was recently received by the office staff of the xxx Subdivision
Homeowners Association, Inc. (xxx) inviting all affected parties:
(a) to appear in a hearing to be conducted on December 7, 2015, at 9:00 in
the morning at the NWRB-WUD Conference Room, 8/F, NIA Building,
EDSA, Quezon City; and
(b) to file on or before the said hearing their Oppositions, if any, to the
pending application of the xxx Subdivision Multi-Purpose Cooperative
(xxx) for a Certificate of Public Convenience to operate and maintain a
waterworks system in Xxx Subdivision.
Hence, this Opposition.
OPPOSITORS
2. The names and other personal circumstances of the herein Oppositors are
as follows:
(a)
(c)
5. Thus, the herein oppositors hereby request the NWRB to order the
applicant to furnish them and all the other interested and affected parties
and entities, as named above, with authenticated copies of the document
referred to in Par. 3 hereof, supra, during the initial hearing set by the
Board on December 7, 2015 at 9:00 AM to give the herein oppositors a fair
(b)
The filled up Application Form, dated 15 October 2015 (Exh. 3), and;
(c)
7.1.
7.2.
7.3.
7.4.
7.5.
24.
The leaders of applicant xxx falsely claim that they are the
incumbent directors and officers of xxx.
They unjustly undermine the legitimate leadership status of the herein
oppositors.
They intentionally create political disunity and sociological confusion
among the homeowners.
Hence, the herein oppositors were constrained to file recently with the
HLLURB a petition praying that it supervise the next regular election of xxx
which is supposed to be held this month (December 2015) per its By-Laws.
25.
The parties have submitted their position papers. It is now ripe for
resolution.
The herein oppositors (and the homeowners of the Subdivision) are now
waiting for the final resolution by the HLURB of the said petition for the
common good of the homeowners.
26.
As soon as the next regular election of xxx is held under the
supervision of the HLURB, it will restore unity in the Subdivision.
The directors and officers of xxx that will be elected therein could work in
peace in finalizing with the MWCI the full implementation of the water
connectionsindividualization scheme.
The said plan has been the subject of negotiations between the MWCI and
the xxx (represented by the herein oppositors) since 2009.
Unfortunately, the brains behind the applicant xxx and their cointerlocking directors/officers in xxx have tried to sabotage the plan to the
grave detriment of the homeowners.
27.
The pending application of xxx for a Certificate of Public
Convenience is part of its continuing attempt tofraudulently control the
xxx water system (which it does not own) in order to rake in huge profits
therefrom to the grave detriment of the homeowners.
And others.
29.
Furthermore, nothing in the records shows that it has registered
its existence, its economic operations, and its water-related incomes with
the proper regulatory agencies, such as:
Office of the Mayor of xxx, xxx (Business Permit and Licensing Office);
(A cooperative, despite its tax-exempt status is still required by law to
register with the Municipality for purposes of business license/permit
monitoring, fire clearance, health clearance, building inspection clearance,
and the like).
(Non-profit and tax-exempt entities are still required by the SSS law and
regulations to register its workers with the SSS for the protection of the said
workers).
Pag-Ibig Fund;
(Non-profit and tax-exempt entities are still required by the Pag-Ibig Fund
law and regulations to register its workers with the Pag-Ibig Fund for the
protection of the said workers).
And others.
30.
Finally, nothing in the record shows that the applicant has (a) the
financial capacity, (b) the moral integrity, (c) the organizational, technical
and engineering competence and experience, (d) the mass support of the
homeowners, (e) the model corporate social responsibility, and (f) the
excellent track record as a water service provider to justify its application
for a Certificate of Public Convenience.
WHEREFORE, premises considered it is most respectfully prayed
that the application of the xxx Subdivision Multi-Purpose Cooperative (xxx)
for a Certificate of Public Convenience (CPC) be DENIED for lack of merit
and for being tainted with intentional fraud and misrepresentations.
FURTHER, the herein oppositors respectfully pray for such and other
reliefs as may be deemed just and equitable in the premises.
xxx for Quezon City, December 4, 2015.
(NAMES AND ADDRESSES OF THE OPPOSITORS)
VERIFICATION
We, X X X X. whose residential addresses and other personal
circumstances are stated in Par. 2, supra, of the foregoing Opposition, after
having sworn in accordance with law hereby depose and say: That we are
the Oppositors in the foregoing Opposition; that we caused the preparation
thereof; that we read the contents thereof; and that the same are true and
correct based on our direct personal knowledge and based on authentic
records.
(NAMES AND ADDRESSES OF THE OPPOSITORS; AND
NOTARIAL ACKNOWLEDGEMENT)
Cc:
XXX Subd. Multi-Purpose Cooperative
Applicant
c/o XXX Chairman XXX
(Address)
Administrator
Metropolitan Waterworks & Sewerage System
MWSS Bldg.
Katipunan Road, Old Balara, Quezon City
Legal Department
Manila Water Co., Inc. (MWCI)
MWSS Compound, Balara, Quezon City
Regional Director (Region IV-A)
Cooperative Development Authority
CDA Regional Office, Calamba City, Laguna
Regional Director - Expanded NCR Field Office
HOUSING AND LAND USE REGULATORY BOARD
HLURB Bldg., Kalayaan Ave. corner Mayaman St.
Diliman, Quezon City
Chairman
Barangay xxx
Barangay Hall
xxx, xxx