Republic of the Philippines

SUPREME COURT
Manila

EFREN MORILLO, MARTINO

MORILLO,
VICTORIA
MORILLO, MA. BELEN DAA,
MARLA
DAA,
MARIBETH
BARTOLAY,
LYDIA
GABO,
JENNIFER
NICOLAS
AND
MARILYN MALIMBAN,
Petitioners,

-versus-

G.R. No. _______________

For: Issuance of the Writ of
Amparo

THE PHILIPPINE NATIONAL

POLICE, represented by PDG
RONALD DELA ROSA, Chief,
Philippine
National
Police,
PSSUPT.
GUILLERMO
LORENZO T. ELEAZAR, QCPD
Director, P/SUPT. LITO PATAY,
QCPD PS 6 Station Commander,
P/SI EMIL S. GARCIA, PO3
ALLAN
FORMILLEZA,
PO1
JAMES AGGARAO AND PO1
MELCHOR NAVISAGA and/or
any of their agents,
Respondents.
x---------------------------------------x
JOINT PETITION FOR THE ISSUANCE
OF THE WRIT OF AMPARO
PETITIONERS, through counsel, and unto this Honorable
Court, respectfully state:

PREFATORY STATEMENT
There are two chief kinds of carnage taking place here, these
wet Manila nights. There is the buy-bust operation, in
which the targeted criminal attempts to buy some drugs, only
to find that he is dealing with undercover police. He panics
and reaches for a weapon, a pistol perhaps or a kind of
homemade shotgun. Before he can use it (so the familiar
script reads) the police shoot him dead. There have been
around two thousand of these buy-bust killings since the war
on drugs under President Rodrigo Duterte began at the start
of July. The dead are both pushers and users. If youre a user,
Dutertes wisdom has it, then youre also a pusher. And even
if you arent a pusher, the users of the drug in question,
shabu or crystal meth, very soon forfeit their claims to
humanity. They lose their souls. The only thing to do with
them is kill them.

An EJK, the second form of carnage, is an extrajudicial

killing, and it was outnumbering the buy-bust incident, this
December, by roughly two to one. A buy-bust is of its nature
attributable. A particular group of policemen takes
responsibility for a particular killing on grounds of selfdefense, and though doubt may be cast on their story (which
repeats and repeats the same formula) there is no mystery
about the people involved. The people the police shoot in
self-defense are classed as nanlaban, which means fought
as in he fought back

In a survey by Social Weather Stations, 69 percent of those

polled thought the incidence of EJKs was either very or
somewhat serious. Only 3 percent thought it not serious at
all. As to whether they believed that police were telling the
truth that the suspects they killed in buy-bust operations had
really resisted arrest, doubters and believers were evenly
split, with 28 percent saying the police were definitely or
probably telling the truth, and 29 percent saying they were
definitely or probably not doing so. Overwhelmingly,
however, 88 percent agreed, strongly or somewhat, that since
Duterte became president, there has been a decrease in drug
problems in their area. And that is the perception that
2

appears to have trumped all others.

Theres less of a drug problem. You can walk the streets at
night, one is told. And yet the price paid is most striking.
Asked how worried they were that they or someone
they knew would become the victim of an EJK, 45
percent replied that they were very worried, and a
further 33 percent that they were somewhat worried.
That is to say, four out of five respondents were
worried to a significant degree that they, or a friend of
theirs, might end up bound and gagged in the gutter, or
shot by a masked man on a passing bike, or woken in
the small hours to receive a bullet in the head.
Are they right to worry? Statistically, the answer
would seem to be no. If you are young, male, and poor,
then, yes, you should worry. For Dutertes war seems
very much to be a war against the poor. But the further
you move up the social ladder, the less you are likely to
be affected.
That kind of reasoning, however, rather ignores the
pervasive effect of terrorism. The targeted killings have
their message for the world of the drug users and
dealers. The crazy and seemingly haphazard
extrajudicial killings, the corpses suffocated with
packing tape and dumped at the side of the road with
sadistic jokes on cardboard signs (and one that, when
turned over, revealed a smiley face) have a message for
everyone: nobody is safe.
- James Fenton, Murderous Manila: On the Night
Shift (first of two parts), New York Review of
Books, February 9, 2017 issue [emphasis supplied]1

What runs counter to common sense is not the nihilistic

principle that everything is permitted, which was already
contained in the nineteenth century utilitarian conception of
common sense. What common sense and normal people
refuse to believe is that everything is possible. We attempt to
understand elements in present or recollected experience that
1Available

at http://www.nybooks.com/articles/2017/02/09/murderous-manila-on-the-nightshift/<last visited January 24, 2017>

simply surpass our powers of understanding. We attempt to

classify as criminal a thing which, as we all feel, no such
category was ever intended to cover. What meaning has the
concept of murder when we are confronted with the
production of corpses?
- Hannah Arendt, The Origins of Totalitarianism,
441 (1962 ed) [emphasis supplied].

Here, people would not be able to imagine such

phantasmagorias, even in their dreams. A surrealism from
slapdash absurdities and povertys impure colors, the
incongruities between people and things, things and people
here they have absolutely no idea what this means.
- Kazimierz Brandys, A Warsaw Diary, 1978-1981

The official version of the inhuman horrors assailed in this

Petition reads like the writers have seen too many old Tagalog action
movies shown on television on sleepy Sunday afternoons that they
unconsciously wove into their script a familiar but all-too wooden if
not improbable dialogue from bygone days of Filipino cinema.
HINDI KAMI PAPAHULI NG BUHAY!, the victims
allegedly shouted upon seeing the approaching lawmen, before they
unleashed a hail of bullets on the police officers.
From thereon, the official narrative could not move beyond
sheer incongruity. The official police reports claim it was a chance
encounter during a tokhang operation, but in interviews with media,
they said they caught the victims holding a drug session; in thus
making conflicting accounts of their deadly action, they effectively
rendered irrelevant the two categories of carnage the prize-winning
American journalist James Fenton came up with in his recent
reportage of several episodes of the on-going drug war in the
country.2
Had he known about it, Fenton would have been better served by the categories established by
the UN Minnesota Protocol, otherwise known as UN Manual on the Effective Prevention and
Investigation of Extra-Legal, Arbitrary and Summary Executions (U.N. Doc. E/ST/CSDHA/.12
[1991] ).The Minnesota Protocol deals with the effective investigation and prosecution of extra2

To begin with, the assailants Police Senior Inspector EMIL

GARCIA Police Officer 3 Allan Formilleza, Police Officer 1 James
Aggarao and Police Officer 1 Melchor Navisaga are members of a
police community precinct that has no operational jurisdiction in the
area where the killings happened.
And in a comical attempt to hide this fact, the police officers
fabricated death certificates and police reports for the young men
they mercilessly gunned down, to show that the carnage happened in
another barangay that properly belonged to their police stations area
of operation.
Indeed, it was such a bloody Sunday afternoon like the killers
were running after an approaching deadline that when the smoke
cleared, four young men lay lifeless in gory pools of human blood
and bits and pieces of human flesh and bones amid the pained and
frightened cries of their loved ones.
The dead: Marcelo Daa, Jr., Raffy Gabo, Anthony Comendo,
and Jessie Cule. They fit the profile of the usual victims of extralegal
killings in the war against drugs male, young and poor. They were
men on the cusp of life, ages ranging from 22 to 36 years old at the
time of their brutal demise. They lived with their families in squalor
in Payatas, the dumpsite for the whole Metro Manila area. They were
garbage collectors and scavengers, barely eking out a living.
The houses in this community of scavengers very near the La
Mesa Dam are no more than clumps of haphazardly built structures
made from an assortment of plastic, wood, and pieces of scrap metal
all salvaged from the trash thrown out of the houses of other
people. 3
legal, arbitrary and summary executions. These executions include: (a) political assassinations; (b)
deaths resulting from torture or ill-treatment in prison or detention; (c) death resulting from
enforced "disappearances"; (d) deaths resulting from the excessive use of force by lawenforcement personnel; (e) executions without due process; and (f) acts of genocide. These
categories of killings carried out by the State and persons acting at its behest or acquiescence may
be subsumed under the shorthand extralegal killings (ELKs).
3 As the well-known Filipino folk singer Gary Granada sang in his iconic composition of the same
title:
Isang araw ako'y nadalaw sa bahay tambakan
Labinglimang mag-anak ang duo'y nagsiksikan
Nagtitiis sa munting barung-barong na sira-sira
Habang doon sa isang mansyon halos walang nakatira
Sa init ng tabla't karton sila doo'y nakakulong
Sa lilim ng yerong kalawang at mga sirang gulong
Pinagtagpi-tagping basurang pinatungan ng bato
Hindi ko maintindihan bakit ang tawag sa ganito

Humble the home may be, but it is sacred. As an American

scholar would put it:
The maxim that a man's house is his castle is one of the oldest
and most deeply rooted principles in Anglo-American
jurisprudence.'It reflects an egalitarian spirit that embraces all
levels of society down to the poorest man living in his
cottage. The maxim also forms part of the fabric of the Fourth
Amendment to the Constitution, which protects people, their
homes, and their property against unreasonable searches and
seizures by the government.4
This sacrosanct space was shockingly violated by the
policemen-murderers. The victims were in the premises of the home,
spending a quiet Sunday afternoon on games and leisure, when the
policemen descended upon them without warning, rounded them up
while laughing and joking among themselves and pretending to look
for pokemon monsters in the house. Then the policemen shot the
victims one by one, execution-style.
And when it was all over, as if nothing happened, the lawmen
sat near the broken bodies of the salvaged victims and helped
themselves with food and drinks from a sari-sari store owned by the
Ay bahay
Sinulat ko ang nakita ng aking mga mata
Ang kanilang kalagayan ginawan ko ng kanta
Iginuhit at isinalarawan ang naramdaman
At sinangguni ko sa mga taong marami ang alam
Isang bantog na senador ang unang nilapitan ko
At dalubhasang propesor ng malaking kolehiyo
Ang pinagpala sa mundo, ang dyaryo at ang pulpito
Lahat sila'y nagkasundo na ang tawag sa ganito
Ay bahay
Maghapo't magdamag silang kakayod, kakahig
Pagdaka'y tutukang nakaupo lang sa sahig
Sa papag na gutay-gutay, pipiliting hihimlay
Di hamak na mainam pa ang pahingahan ng mga patay
Baka naman isang araw kayo doon ay maligaw
Mahipo n'yo at marinig at maamoy at matanaw
Hindi ako nangungutya, kayo na rin ang magpasya
Sa palagay ninyo kaya, ito sa mata ng Maylikha
Ay bahay
4 Jonathan L. Hafetz, A Mans Home is His Castle?: Reflections on the Home, the Family, and Privacy
the Nineteenth and Early Twentieth Centuries, 8 Wm. & Mary J. Women & L. 175 (2002), available at
http://scholarship.law.wm.edu/wmjowl/vol8/iss2/2 <last visited January 25, 2017>.

family of one of the victims another surreal, if phantasmagoric

thread to this horrendous tale of police brutality.
The murderers-in-uniform say the five young men are illegal
drug suspects who deserved the death they died, a claim belied by
members of the community who witnessed what happened.
The perpetrators cite OPLAN TOKHANG, the governments
campaign against drugs, as justification for the killing and maiming
of illegal drug suspects. This policy of murder is furthered by
members of the SWAT and SOCO who tampered with the crime
scene and attempted to erase evidence implicating the principals of
the crime.
And perhaps, that this Petition is being filed at all before this
Honorable Court is only because a fifth victim, a 28-year old
vegetable vendor named Efren Morillo, put up such a fight against
death that he somehow improbably escaped its cold fangs, and
mustered the courage to speak about what happened to him and his
friends on August 21, 2016 at Group 9, Area B, Payatas, Quezon City.
But the perpetrators of the gruesome crimes want to silence
Morillo and his family, the families of his slain friends, and the entire
community where the killings took place, by carrying out a
continuing campaign of harassment and intimidation against them.
Five months after the killings, the policemen involved continue
to sow terror at Group 9, Area B, Payatas, Quezon City, to intimidate
and harass into a paralyzed silence an entire community that had
witnessed their crime. Composed mainly of informal workers,
garbage collectors and scavengers, the powerless and povertystricken community is vulnerable to fear and pressure coming from
men armed with guns and given the mantle of protection by no less
than the government in their rampage in the name of the war on
drugs.
And this carnage is just one incident of a continuing drug war
that barely seven months after it was launched has already
claimed the lives of more than 7,000 persons.5 Alas, the Jewish
philosopher Hannah Arendt may yet be proven right once again, that
as the dehumanized bodies slaughtered in the drug war pile up,
everything is now possible.
5

Phelim Kine, Deadly Milestone in Philippines Abusive Drug War: 7,000 Filipinos Killed Since July
Shows Rule of Law Collapse, Human Rights Watch Dispatch, July 24, 2017, available at
https://www.hrw.org/news/2017/01/24/deadly-milestone-philippines-abusive-drug-war <last visited
January 26, 2017>.

This Petition for the issuance of the Writ of Amparo is the

Petitioners and aggrieved parties cry for help and protection against
further violation of their constitutional and human rights to life,
liberty and security.

I.

PARTIES

A. PETITIONERS
1) Petitioner EFREN C. MORILLO is Filipino, 28 years old,
and a resident of San Isidro, Montalban, Rizal.
2) Petitioner MARTINO MORILLO is Filipino, of legal age, a
resident of San Isidro, Montalban, Rizal, and the father of Petitioner
Efren Morillo.
3) Petitioner VICTORIA MORILLO is Filipino, of legal age, a
resident of San Isidro, Montalban, Rizal, and the mother of Petitioner
Efren Morillo.
4) Petitioner MA. BELEN DAA is Filipino, of legal age, a
resident of Area B, Group 9, Bgy. Payatas, Quezon City, and the
mother of deceased victim Marcelo Daa, Jr.
5) Petitioner MARLA DAA is Filipino, 20 years old, a resident
of Area B, Group 9, Bgy. Payatas, Quezon City, and the younger
sister of deceased victim Marcelo Daa, Jr.
6) Petitioner MARIBETH BARTOLAY is Filipino, 34 years old,
a resident of Area B, Group 9, Bgy. Payatas, Quezon City, and the
live-in partner of deceased victim Marcelo Daa, Jr.
7) Petitioner LYDIA GABO is Filipino, of legal age, a resident
of Area B, Group 7, Sto. Nino, Bgy. Payatas, Quezon City, and the
mother of deceased victim Raffy Gabo.
8) Petitioner JENNIFER NICOLAS is Filipino, years old, and a
resident of Area B. Group 7, Sto. Nino, Bgy. Payatas, Quezon City,
and the sister-in-law of deceased victim Raffy Gabo.
8

9) Petitioner MARILYN MALIMBAN is Filipino, of legal age,

a resident of Area B, Group 7, Sto. Nino, Bgy. Payatas, Quezon City,
and the live-in partner of deceased victim Jessie Cule.
10) All the Petitioners may be served with court processes and
pleadings through the undersigned counsel, Roque & Butuyan Law
Offices, at Unit 1904 Antel 2000 Corporate Center, 121 Valero St.,
Salcedo Village, Makati City 1277 Metro Manila.
B. RESPONDENTS

11) Respondent PHILIPPINE NATIONAL POLICE (PNP) is a

government entity, with offices at Camp Crame, Quezon City
represented by its head, PDG. RONALD DELA ROSA the
Philippine National Police (PNP) Director-General.
12) Respondent PSSUPT. GUILLERMO LORENZO T.
ELEAZAR is of legal age, Filipino, and the District Director of the
Quezon City Police District (QCPD), with office address at Camp
Karingal, Quezon City.
13) Respondent P/SUPT. LITO PATAY is of legal age, Filipino,
Station Commander of QCPD Police Station 6, and with his office
address at QCPD S6, Bgy. Batasan, Quezon City.
14) Respondent P/SI EMIL S. GARCIA is of legal age, Filipino,
a police officer assigned at QCPD Police Station 6, and with office
address at QCPD S6, Bgy. Batasan, Quezon City.
15) Respondent PO3 ALLAN FORMILLEZA is of legal age,
Filipino, a police officer assigned at QCPD Police Station 6, and with
office address at QCPD S6, Bgy. Batasan, Quezon City.
16) Respondent PO1 JAMES AGGARAO is of legal age,
Filipino, a police officer assigned at QCPD Police Station 6, and with
office address at QCPD S6, Bgy. Batasan, Quezon City.
17) Respondent PO1 MELCHOR NAVISAGA is of legal age,
Filipino, a police officer assigned at QCPD Police Station 6, and with
office address at QCPD S6, Bgy. Batasan, Quezon City.

18) Respondents PNP and above-named police officers may be

served with summons, court processes, and pleadings at their
addresses as specified above.
19) Respondents PNP and police officers are also served
summons, court processes, and pleadings through the Office of the
Solicitor General, with address at Amorsolo Street, Legaspi Village,
Makati City, Metro Manila.

II.
A. SOURCES
FACTS.

OF

STATEMENT OF MATERIAL FACTS

MATERIAL

20) The material facts of this case are culled from the sworn
affidavits of the following Petitioners which are attached to this
Petition as annexes:
a.
b.
c.
d.
e.
f.
g.
h.

Efren Morillo (Annex A);

Maribeth Bartolay (Annex B);
Rowena Cordero (Annex C);
Marla Daa (Annex D);
Maria Belen Daa (Annex E);
Lydia Gabo (Annex F);
Marilyn Malimban (Annex G);
Jennifer Nicolas (ANNEX H);

B. IDENTITY OF THE DECEASED

VICTIMS.
21) Almost all the Petitioners are related to deceased-victims
of the extralegal kilings perpetuated by Respondent-policemen as
named in this Petition. This is with the exception of the lone survivor
of the killings, Efren Morillo, and his parents, Petitioners Martino and
Victoria Morillo.

10

22) The names of the deceased victims of extralegal killings

perpetrated by police officers named below are as follows:
a. MARCELO DAA, JR. who was Filipino citizen, 31 years old,
and a resident of Area B, Group 9, Bgy. Payatas, Quezon
City.
b. JESSIE CULE who was a Filipino citizen, 20-25 years old,
and a resident of Area B, Group 7, Bgy. Payatas, Quezon
City.
c. RAFFY GABO who was a Filipino citizen, 23 years old, and
a resident of Area B, Group 7, Bgy. Payatas, Quezon City.
d. ANTHONY COMENDO who was a Filipino, 36 years old,
and a resident of Area B, Group 13, Bgy. Payatas, Quezon
City.

C. RELATIONSHIP
PETITIONERS
TO
DECEASED VICTIMS.

OF
THE

23) Petitioner EFREN C. MORILLO is the victim of a

frustrated murder, and the only survivor of violence committed by
Respondent-police officers named in this Petition.
24) Petitioner MARTINO MORILLO is the father of
Petitioner Efren Morillo.
25) Petitioner VICTORIA MORILLO is the mother of
Petitioner Efren Morillo.
26) Petitioner MA. BELEN DAA is the mother of deceasedvictim Marcelo Daa, Jr.
27) Petitioner MARLA DAA is the younger sister of
deceased-victim Marcelo Daa, Jr.
28) Petitioner MARIBETH BARTOLAY was the live-in
partner of deceased-victim Marcelo Daa, Jr.

11

29)
Petitioner LYDIA GABO is the mother of deceasedvictim Raffy Gabo.
30) Petitioner JENNIFER NICOLAS is the sister-in-law of
deceased-victim Party Raffy Gabo.
31) Petitioner MARILYN MALIMBAN was the live-in
partner of deceased-victim Jessie Cule.
D. CHRONOLOGY
MATERIAL FACTS.

OF

32) In the afternoon of 21 August 2016, Marcelo Daa, Jr.,

Raffy Gabo, Anthony Comendo, Jessie Cule and Efren Morillo were
in the house of their friend Marcelo Daa, Jr. at the foot of a hill in Bgy.
Payatas, Quezon City.6 Morillo was there to collect a debt from Daa,
while Daa, Gabo, Comendo and Cule were passing time until their
six o clock work shift in the evening as garbage collectors.7
33) A little after one o clock in the afternoon, five men and
two women in civilian clothes suddenly arrived. They entered the
wooden gate and rushed inside the yard, startling Daa, Cule and
Morillo, who were playing pool at a pool table in a hut on one side.
The men pulled out short firearms and aimed them at the latter.
Gripped by fear, Daa, Cule and Morillo put up their hands in
surrender.
34) The armed men handcuffed Daa and Morillo. They pulled
electric wire from the ceiling of the hut which they used to tie Cules
hands. They fetched Gabo and Comendo who were at the hammock
at the back of the house and also tied their hands with electric wire.
Then, they made Daa, Morillo, Cule, Gabo and Comendo sit side by
side on a bench. The whole time, the armed men kept accusing the
five captives of being involved in illegal drugs. Realizing that the
armed men are policemen, Daa, Morillo, Cule, Gabo and Comendo
piteously protested their innocence of any crime.8
35) The armed men entered the house. Cowering inside were
Marcelo Daa, Jr.s live-in partner, Maribeth Bartolay, and also his
Aunt Ising. The armed men proceeded to ransack the house,
Efren Morillo, Maribeth Bartolay and Marla Daa corroborate each other on this point in their
sworn affidavits attached as ANNEX A, ANNEX B and ANNEX D respectively.
7 Efren Morillo attests to the foregoing in his sworn affidavit attached as ANNEX A.
8 Efren Morillo and Marla Daa attest to Paragraphs 27 and 28 and corroborate each other in their
sworn affidavits attached as ANNEX A and ANNEX D respectively.
6

12

rummaging through personal effects and furniture. They took a

cellphone and tablet device they found therein. They forced Maribeth
to take off her silver necklace and rings and hand these over to them.
They also took Marcelos collection of metals which the latter
painstakingly acquired by scavenging. All the while, the armed men
were laughing and mocking Maribeth and Ising: Ilabas nyo na yung
Pokemon! Saan mo ba nilagay yung Pokemon?9
36) Outside, Marcelo Daa, Jr. was having an emotional
exchange with his younger sister, Marla Daa. Marla was originally
inside the house with Maribeth and Ising, but she ran out when the
armed men entered. She dashed to her brother who was seated on
the bench with the four other captives. She wailed: Kuya, paano ka
na? Although handcuffed, Marcelo exerted effort to remove the
bracelet and ring he was wearing. He handed the bracelet and ring to
Marla and said dolefully: Pumunta ka na sa taas. Kaya ko na to.
Clutching the bracelet and ring and crying, Marla left.10
37) The armed men emerged from the house carrying a silver
foil and a lighter in the shape of a gun. They crowed to Daa, Morillo,
Cule, Gabo and Comendo that the items prove the latters
involvement in illegal drugs. The five captives fervently denied
owning the said items.
38) The armed men hustled Daa, Morillo, Cule, Gabo and
Comendo to the back of the house. One of the armed men took Daa
and Morillo to a makeshift room at the back connected to the house,
but whose two walls are missing. One opening leads to a ravine
about three meters away. The armed man made Daa sit on a wooden
chair and Morillo on the armrest thereof. Then, without warning, he
pointed his firearm at Morillo and shot him on the chest. Morillo fell
to the ground bleeding, but he did not lose consciousness. Next, the
armed man shot Daa, who fell to the ground beside Morillo. Daa was
shot a second time on the head as he lay on the ground. He died.
39) Lying beside Daa, Morillo played dead. When the armed
man left the room, Morillo crawled out of the opening and onto the
edge of the ravine. Pressing one hand over his bleeding chest, he slid
down the ravine and landed on the bank of a stream at the bottom
thereof. Morillo crossed the stream, trudged up the hill on the other
side and walked until he reached the highway. There, providentially,
he encountered an acquaintance who was the barker of a jeepney.
Maribeth Bartolay attests to the foregoing in her sworn affidavit attached as ANNEX B.
Efren Morillo and Marla Daa attest to Paragraphs 27 and 28 in their sworn affidavits attached
as ANNEX A and ANNEX D respectively.
9

10

13

The latter and the jeepney driver took pity on him and acceded to his
request to be brought to a hospital near his home in Montalban, Rizal.
40) Morillo was brought to the Montalban Infirmary in
Kasiglahan Village, Rodriguez, Rizal. Unfortunately, there was no
doctor on duty at the infirmary so that only first aid could be applied
to his chest wound. Moreover, personnel at the infirmary reported
his condition of being shot to policemen at the Community Police
Action Center (COMPAC) near thereat.
41) Policemen from the COMPAC went to the infirmary to
see Morillo. At the latters behest, the policemen went to Morillos
house in San Isidro, Montalban, Rizal to inform his mother, Victoria
Morillo about what happened and take her back with them to the
infirmary.
42) Morillo recounted to the Montalban policemen the attack
against him and his friends earlier that afternoon by policemen in
Quezon City. But much to his alarm the Montalban policemen
insisted that they turn him over to Quezon City Police Station 6,
whose area of responsibility includes Bgy. Payatas, the place of the
incident.
43) Morillo pleaded not to be handed over to Station 6,
insisting that he did not commit any crime and that in fact he is a
victim himself. He was terrified when he realized the likelihood that
the policemen who shot him and killed Daa, Cule, Gabo and
Comendo are assigned at the said station. Despite his pleas, the
Montalban policemen loaded Morillo in an ambulance and brought
him to Quezon City Police Station 6 in Bgy. Batasan Hills, Quezon
City. The only concession given him was the company of his mother
Victoria in the ambulance.
44) Efren Morillo arrived by ambulance at Quezon City
Police Station 6 at nine o clock in the evening. There he was made to
wait indefinitely, the policemen unmindful of his serious wound.
Morillo slipped in and out of consciousness as he lay on the
ambulance stretcher. At one point, he heard a voice say: Matibay ang
bata na yan. Alas tres pa may tama na, hanggang ngayon buhay pa.
Finally, after many pleas by his mother Victoria, the policemen
transported Morillo to East Avenue Medical Center. Morillo was shot
at three o clock in the afternoon but because the Montalban police

14

footdragged in taking him to the hospital, he only received proper

medical attention at around midnight, or nine hours later.11
45) The armed men who turned out to be policemen executed
Gabo, Comendo and Cule one by one in cold blood. They made the
three kneel on the ground at the back of the house and shot them to
death. Jessie Cule was the last of the three to be killed. He begged to
be spared, hugging the legs of one of the armed men and sobbing. As
he would not let go of his hold, the man shot him on the nape.12
46) Concerned relatives and neighbors gathered at the top of
the hill near the highway as soon as news spread about the presence
of armed men in the house of Marcelo Daa, Jr. Hearing gunshots
coming from the latter direction, they ran down the hill towards the
Daa residence. They were stopped from fully entering the inside of
the yard, but not before catching a glimpse of a shocking sight at the
back of the house. A relative of the Daas, Rowena Cordero, saw Raffy
Gabo and Anthony Comendo sprawled and lifeless on the ground.
She also saw Jessie Cule on his knees but his torso bent forward to
the ground. Cule was still alive, his chest and shoulders heaving up
and down. At this point, one of the armed men stopped Cordero
from going in farther.
47) Angrily, Cordero confronted the armed men: Bakit Sir,
may warrant ba kayo? Asan ang barangay? Bakit nyo binaril agad, hindi
naman sila nanlaban. Paano sila manlalaban wala naman silang baril." The
man ignored Corderos admonition. One of the women with the
armed group, Lea Barcelona, also known as Neneng, whom Cordero
was able to identify because she used to live in the neighborhood,
told the man blocking Cordero: Sir, tiyahin 'yan ng isa sa pinatay
'nyo." The man did not deny or object to the statement. Based on
these exchanges, Cordero surmised that the armed men are
policemen;
48) The armed men pushed Cordero and the other relatives
and neighbors out of the compound and closed the wooden gate.
However, the latter remained outside the gate and kept vigil there.
From outside the gate, they can see the inside of the compound
through the wooden slats of the gate and fence. At one point, one of
the armed men said: Sir, may humihinga pa. The man accompanied
his statement with a motion of breathing in and out. The armed men
then walked toward the back of the house. A few moments later, two
Efren Morillo attests to Paragraphs 31, 32, 33, 34, 35, 36 and 37 in his sworn affidavit attached as
ANNEX A.
12 Marilyn Malimban attests to the foregoing in her sworn affidavit attached as ANNEX G, as
spontaneously recounted to her by fourteen-year old eyewitness Nonoy.
11

15

gunshots rang out. Sometime later, one of the armed men also
exclaimed: Putang ina! Natakasan pa tayo. Hanapin nyo! Sabagay, hindi
na makakaligtas yun, puso ang tama.13
49) The armed men stayed several more hours inside the Daa
residence. They ate at the pool table area using the family plates and
utensils.14 They even had the insolence to solicit from Maribeth
Bartolay food and drinks from her sari-sari store.15
50) Before four o clock in the afternoon, about ten (10) men
and women in full police and/or SWAT uniform arrived and
entered the house. At around five o clock, another round of gunshots
was fired, the sound coming from the back of the house. At seven o
clock in the evening, scene of the crime operatives (SOCO) and
members of the media arrived.
51) One of the armed men gave a media interview and
confirmed that they are in fact policemen assigned to QCPD Police
Station 6 in Bgy. Batasan Hills, Quezon City. He introduced himself
as Police Senior Inspector EMIL GARCIA and announced that he and
PO3 Allan Formilleza, PO1 James Aggarao and PO1 Melchor
Navisaga had killed Marcelo Daa, Jr., Raffy Gabo, Anthony Comendo
and Jessie Cule in a police operation implementing OPLAN
TOKHANG. He claimed that the victims were notorious drug
suspects and were also known robbers. Curiously, the police also told
the media that they caught the victims during a drug session, even if
this fact directly contradicts the narrative of the police report they
later filed.
Copies of the Police Report, Joint Affidavit of Arrest and the
Police Blotter Excerpt of Entry are attached hereto as ANNEXES I and
series.
Copies of the videos of the news reports are attached hereto in a
compact disc as ANNEX N and series.
52) At eight o clock in the evening, the dead bodies of
Marcelo Daa, Jr., Raffy Gabo, Anthony Comendo and Jessie Cule

Rowena Cordero attests to Paragraphs 39, 40 and 41 in her sworn affidavit attached as ANNEX
C.
14 Maribeth Bartolay and Rowena Cordero corroborate each other on this point in their sworn
affidavits attached as ANNEX B and ANNEX C respectively.
15 Maribeth Bartolay attests to the foregoing in her sworn affidavit attached as ANNEX B.
13

16

were carried out of the house and brought to Light Funeral Services
in Kamuning, Quezon City.16
Copies of the Death Certificates of the victims are attached
hereto as ANNEXES J and series.
53) Efren Morillo survived his gunshot wound and
recuperated at the East Avenue Medical Center. However, his fear for
his life did not ebb because during the whole ten (10) days that he
was confined at the hospital, as policemen from QCPD Police Station
6 kept him captive in his hospital room. Thankfully, officials from the
Commission on Human Rights (CHR) later on arrived and rescued
him from the said policemen.
A copy of Efren Morillos medical certificate is attached hereto
as ANNEX K.
54) Morillo is now in the custody and under the protection of
the CHR. But as a way to reach him, his assailants filed a false charge
of Direct Assault Upon Agents of Persons in Authority against him
with the Quezon City Metropolitan Trial Court.17

55) Marilyn Malimban, the live-in partner of one of the

victims Jessie Cule, also fears that the policemen who killed Jessie
and his friends would come back and harm her. Her fears are
grounded on facts because during the wake of Jessie in their
residence at Area B, Group 7, Sto. Nino, Bgy. Payatas, some
unidentified men arrived. From inside the house, Marilyn heard
them ask her landlady: Sino rito ang asawa ng namatay? She went
inside her room and stayed there until the men left.18
56) A few days after the killings, a television reporter of
GMA 7, Jay Taruc, and his crew visited the place of the incident in
Area B, Group 9, Bgy. Payatas and sought to interview witnesses.
However, No one agreed to speak with him or even come near him
because unbeknownst to him, the police escort he took with him to
the area is PO3 Allan Formilleza, one of the policemen involved in

Rowena Cordero, Marla Daa and Marilyn Malimban attest to Paragraphs 43, 44 and 45 and
corroborate each other in their sworn affidavits attached as ANNEX C, ANNEX D and ANNEX G
respectively.
17 Efren Morillo attests to the foregoing in his sworn affidavit attached as ANNEX A.
18 Marilyn Malimban attests to the foregoing in her sworn affidavit attached as ANNEX G.
16

17

the killings. All the members of the community were terror-stricken

at the sudden appearance of Formilleza that day.19
57) In the afternoon of 27 October 2016, three policemen
involved in the killings PO3 Allan Formilleza, PO1 James Aggarao
and PO1 Melchor Navisaga again went to the Daa residence in Area
B, Group 9, Bgy. Payatas. Marla Daa, the younger sister of one of the
victims Marcelo Daa, Jr., was home alone at that time. Brazenly and
without asking for permission, Formilleza, Aggarao and Navisaga
entered the gate and started taking videos of the whole compound
and house. One of them was even carrying an M-16 Armalite rifle.
Despite her profound fear, Marla mustered the courage to ask: Bakit
kayo nagvi-video? The three ignored her. After several minutes, they
left.20
58) Again in the afternoon of 22 November 2016, one of the
policemen involved in the killing was spotted in the area. The said
policeman got out of a vehicle and went to the store near the road. He
asked the owner of the store, Nica: Saan dito may bentahan ng droga?
Recognizing the man as one of the killers, Nica replied: Wala na nga
e, pinagpapatay nyo na. The policeman did not answer and simply
walked away.21
59) After the incident, Petitioners obtained copies of he
reports from the police concerning the operation. It is readily
apparent that the police fabricated the police reports. In the report
filed by the QCPD S6 Station Illegal Drugs Special Operation Task
Group to the Quezon City Prosecutors Office (for the purpose of
filing criminal charges against Efren Morillo)22 and their Joint
Affidavit of Arrest, they claim that the Aggrieved Parties fired at
them first. They even allege that the Aggrieved Parties shouted
HINDI KAMI PAPAHULI NG BUHAY! They also alleged that
they found guns and drug paraphernalia in their possession. These
are nothing but lies.
60) Another grave anomaly is the reported place of the
incident. In all the documents from the Respondents the Police
Report, the Joint Affidavit of Arrest and the Police Blotter Excerpt of

Rowena Cordero attests to the foregoing in her sworn affidavit attached as ANNEX C.
Marla Daa attests to the foregoing in her sworn affidavit attached as ANNEX D.
21 Marla Daa and Maria Belen Daa attest to the foregoing in their sworn affidavits attached as
ANNEX D and ANNEX E.
22 The police filed a criminal case against Efren Morillo for Direct Assault Against an Agent of a
Person in Authority. The case is pending before MeTC Branch 42 of Quezon City. Curiously, they
did not file a case for a violation of R.A. No. 9165 even if they alleged that they found drug
paraphernalia in the place of the incident.
19
20

18

Entry, and even in the Death Certificates of the deceased -- the place
of incident is Group 9, Brgy. Bagong Silangan, Quezon City.
61) This is false, as the place of incident is the house of Marcelo
Daa, Jr. at Group 9, Area B, Bgy. Payatas, Quezon City. This is not a
simple oversight and is actually evidence that the Respondents are
fabricating and manipulating evidence.
62) First, Respondents know that the place of incident is in Bgy.
Payatas and not Bgy. Bagong Silangan. This was not an inadvertence.
In their Joint Affidavit of Arrest, they categorically said the following:
THAT, at about 2:00 PM, on the same date, we were
dispatched to conduct Oplan Tokhang, house to house
visitation to a known drug personalities (sic), particular in
the house of certain Marcelo Daa Jr., at Group 9 Area B,
Brgy Bagong Silangan, Quezon City.
63) However, they knew that the house of Marcelo Daa, Jr. is in
Group 9 Area B, Bgy. Payatas, Quezon City. This is evident from the
Police Report, where it was indicated as such. This is the true
address, as provided in the Barangay ID of Marcelo Daa, Jr. As
policemen detailed in QCPD S6, they should know that these are two
different areas altogether. They are not expected to make such a
patent error as this.
A copy of the Barangay ID of Marcelo Daa, Jr. is attached
hereto as ANNEX L.
64) Second, the motive for the fabrication is obvious. As admitted
by Respondents Garcia, Formilleza, Aggarao and Navisaga in their
Joint Affidavit of Arrest, they are detailed at Bagong Silangan Police
Community Precinct 4 (PCP-4). However, Bgy. Payatas is covered by
a different Police Community Precinct -- PCP 5.
65) Thus, Respondents had no authority to conduct OPLAN
TOKHANG operations in Bgy. Payatas, where the incident occurred.
It is thus quite obvious that they fabricated evidence to make it
appear that they had jurisdiction to conduct OPLAN TOKHANG
operations where the incident occurred. Otherwise, if it were indeed
a legitimate operation, there is no need to lie about the place of the
incident.
66) Third, Respondents merely substituted Bgy. Payatas with
Bgy. Bagong Silangan while retaining all other pieces of
information about the place of the incident.
19

67) This shows that intercalation was a mere afterthought, and a

poor one at that. There is no place called Group 9 Area B, Bgy.
Bagong Silangan, Quezon City. Bgy. Bagong Silangan is divided
into sitios and puroks, unlike Bgy. Payatas which is separated into
groups and areas. This is due to the huge size discrepancy between the
two barangays.
68) The foregoing show how the incident on 21 August 2016 was
not a legitimate police operation that resulted in a shoot-out between
suspects and policemen. It was a summary execution that was
enabled by OPLAN TOKHANG, and which follows the worn-out
narrative that the deceased victims were notorious drug suspects
who fought back against the policemen. Nanlaban. The attempt to
cover up the crime and glorify it as a police achievement is achieved
through a systematic conspiracy among different units of the same
police district, part of which is to silence and frighten possible
witnesses and aggrieved parties from speaking up in the name of
justice.

III. GROUNDS FOR THE ISSUANCE

OF THE WRIT OF AMPARO
A. RESPONDENTS
P/SI
GARCIA, PO3 FORMILLEZA,
PO1 AGGARAO AND PO1
NAVISAGA
CONTINUE
TO
THREATEN THE PETITIONERS
EVEN AFTER THE INCIDENT.
69) The chilling and gruesome murders of victims Marcelo
Daa, Jr., Raffy Gabo, Anthony Comendo and Jessie Cule and the
near-fatal wounding of Petitioner Efren Morillo are gross violations
of their basic human right to life.
70)
Members of the police - namely, Respondents P/SI
GARCIA, PO3 Formilleza, PO1 Aggarao and PO1 Navisaga, brazenly
admit to the killings of Daa, Gabo Comendo and Cule, and the
maiming of Morillo. The swiftness of their attack, their desecration of
20

the home, their ignominy and cruelty to the victims, their callousness
and derision toward family, kin, neighbors and community of the
latter, and their disrespect for the dead show utmost disregard for
human rights.
71) Worse, after the killings, the Respondent police officers
involved in the killings repeatedly went back to the scene of the
crime, went into the residential houses of some of the petitioners in
an obvious attempt to manipulate evidence and to antagonize
witnesses.
72) Petitioner Efren Morillo continues to fear for his life.
Because he survived the attack of the perpetrators and identified each
and every one of them, his life is in grave danger. Moreover, the
trumped up charge of Direct Assault Upon Agents of Persons in
Authority filed against him is clearly persecution on the part of the
perpetrators. In addition, the incident has dealt a serious blow on the
financial stability of his family. To pay for his medical bills, Morillos
parents Martino and Victoria Morillo were forced to sell their house.
They have no more income, since Morillo, who was the sole
breadwinner of the family, could not resume work because of the
danger to his life. Thus, there is a clear and grave threat to his right to
life, liberty and security.
73) The other Petitioners suffer the same violation of their
right to life, liberty and security. They are terrified for their own lives
and the lives of their family members, relatives and loved ones
because the perpetrators keep returning to intimidate and harass
them into silence. They are violated in their own homes because the
perpetrators freely barge in. They could not go to work because they
are afraid to leave their children alone in their houses. Their lives are
at a standstill. Even the neighbors and members of the larger
community are victimized because of the paralyzing fear wrought by
the blatant threats of the policemen involved in the killings from the
time of the incident to date.
74) With respect to the Daas who reside at Group 9, Area B,
Bgy. Payatas, where the incident occurred, the same Respondents
Formilleza, Aggarao and Navisaga returned at least twice.
75) As detailed in the affidavits of Marla Daa23 and Maria
Belen Daa,24 the three policemen returned on 27 October 2016. This
was two days after the first hearing for the criminal case filed by the
23
24

ANNEX D.
ANNEX E.

21

policemen against Efren Morillo. In the affidavit of Marla Daa, she

recalls:
We buried Kuya Nonoy and tried to recover from the
violence and trauma of his murder. However, in the
afternoon of 27 October 2016, barely two months after
the incident, the three policemen who killed my
brother and his three friends and shot Efren MorilloAllan Formilleza, James Aggarao and Melchor
Navisaga- again appeared at my parents house. I felt
suffocating fear as I was home alone at that time.
Brazenly and without asking for permission, they
entered the gate and started taking videos of the
whole compound and house. One of them was
carrying an armalite. Mustering courage, I asked:
Bakit kayo nagvi-video? they ignored me. After
several minutes, they left.25
76) A month later, on 22 November 2016, the same policemen
attempted to return. She narrates:
Again in the afternoon of 22 November 2016, one of the
policemen who killed my brother Nonoy and his three
friends and shot Efren Morillo was spotted in our area.
Said policeman got out of a vehicle and approached one
of the sari-sari store near the road. He asked the owner of
the store, Nica: Saan dito may bentahan ng droga?
Recognizing the man as one of the killers, Nica dared
reply: Wala na nga e, pinagpapatay nyo na. The
policeman did not answer and simply walked away.
Later, Nica narrated to us the foregoing exchange.26
77) With respect to the relatives of Raffy Gabo, the funeral
wake of the victim was disturbed by the presence of three individuals
lurking around their house. Their presence was disturbing enough to
rouse the curiosity and agitated reaction of their neighbors.27

Paragraph 13 of ANNEX D.
Paragraph 14 of ANNEX D.
27 Lydia Gabo attests to the foregoing in her sworn affidavit attached as ANNEX F.
25
26

22

B. QCPD

STATION
6,
REPRESENTED BY RESPONDENT
P/SUPT. PATAY, TAKE PART
IN

THE

CONTINUED

THREAT

THROUGH A CONSPIRACY TO
COVER UP THE CRIME.

78) Respondents have exhibited what lengths they can take

in order to cover up for their crime and make it appear like a
legitimate police operation. They have manipulated official
documents and even filed these before the Courts.28 They even
instituted a criminal action against Efren Morillo in order to frighten
the victims and their families from testifying or filing any charges
against them.
79) Certainly, the attempt to cover up does not start and end
with the perpetrators of the crime. The Scene of the Crime Operative
(SOCO) Team Leader, PCI Nellson Sta. Maria, is detailed under the
QCPD SOCO Division stationed at EDSA/Kamuning, Quezon City29
The investigator of the case, PO2 Jerome Dollente is detailed at the
QCPD CIDU Unit at Camp Karingal, Quezon City.30 Moreover, the
Police Report that was filed before the Quezon City Prosecutors
Office was signed by Respondent P/SUPT LITO PATAY, QCPD S6
Commander.31
80) Further, numerous witnesses recall having heard another
volley of gunfire when SWAT Officers went to the scene of the crime.
This was hours after the incident, and after the bystanders were
forced to move away from the place of the incident. This only bolsters
the fact that Respondents have conspired to manipulate the evidence
in order to afford them impunity and even make it seem like an
achievement for the police force.
81) Petitioners fear for their lives, as their knowledge of the
facts of the incident belie the claims of Respondents. Their fear thus
not only stems from Respondents Garcia, Formilleza, Aggarao and
Navisaga, but extends to the entire QCPD. Their knowledge will
show how the crime was covered up through a systematic
coordination between different units of the QCPD. Thus, there is a
The Police Report, Joint Affidavit of Arrest and Excerpt of Entry were filed as evidence before
the MeTC Branch 42 in Criminal Case No. M-QZN-16-09092-CR.
29 ANNEX I-1.
30 ANNEX I-1.
31 ANNEX I-1.
28

23

very reasonable basis to afford the Petitioners protection from the

QCPD.

C. THE PHILIPPINE NATIONAL

POLICE TAKE PART IN THE
CONTINUED THREAT THROUGH
ITS OPLAN TOKHANG.

82) The Philippine National Police (PNP), represented by

Respondents PNP PDG RONALD DELA ROSA, QCPD District
Director PSSUPT GUILLERMO LORENZO T. ELEAZAR and QCPD
Police Station 6 Station Commander P/SUPT. LITO PATAY, is a most
interested institution in this petition because the perpetrators are
members of the PNP and the crimes were committed in the course of
a police operation. The policemen involved in the killings are under
the direct command of the PNP.
83) At the very least, indirectly, the PNP gives institutional
imprimatur to the disregard of the rule of law and the murder of
illegal drug suspects. In the incident here involved, members of the
SWAT and SOCO are accessories to murder, having obviously staged
the crime scene and erasing evidence implicating the principals of the
crime. Moreover, the concept of operations of PROJECT TOKHANG
as discussed in Command Memorandum Circular No. 16-2016 which
involves the conduct of house to house visitations to persuade
suspected illegal drug personalities to stop their illegal drug
activities is a direct violation of the right to liberty and security, and
under the constitutional framework, the rights of the accused and the
right against unreasonable searches and seizures. In addition, the
incredible pressure on police officials to perform above par in the
implementation of PROJECT TOKHANG on pain of being relieved as
per Command Memorandum Circular No. 16-2016 drives them to
ignore protocol and breeds in them contempt of the law.
A copy of Command Memorandum Circular No. 16-2016 is
attached hereto as ANNEX M.
84) Assuming arguendo that the deceased victims were illegal
drug personalities, the police authorities should have followed the
rule of law by charging them and causing the issuance of arrest and
search warrants against them. Instead, they were summarily
24

executed and were lumped together with other victims who allegedly
fought back, or nanlaban.
85) There is thus a very serious threat to the life, liberty, and
security of the Petitioners, as well as the entire community of Area B,
Bgy. Payatas, Quezon City. Their rights to life, liberty, and security
are violated or threatened with violation by an unlawful act or
omission of public officials or private individuals who are herein
Respondents.
PRAYER
WHEREFORE, PREMISES considered, Petitioners respectfully pray
that the Honorable Court:
(a) Issue a Temporary Protection Order under Section 14(a) of
the Rule on the Writ of Amparo against herein Respondents
and any of their agents, directing them to refrain from
issuing or carrying out any threat to the life, liberty and
security of the Petitioners, including but not limited to:
i)

A prohibition against entering within a radius of five

kilometers of the residence and work addresses of the
Petitioners;

ii)

A
Temporary
Restraining
Order
on
the
implementation of OPLAN TOKHANG in Area B,
Bgy. Payatas, as well as all areas under the jurisdiction
of QCPD S6;

(b) In the interim, cause the issuance of a Production Order

under Section 14(c) of the Rule on the Writ of Amparo
against herein Respondents, directing them to produce and
permit the inspection and copying or photographing of
intelligence and surveillance reports, police blotters,
coordination, video and all other official and unofficial
documents and material pertaining to the police operations
conducted on 21 August 2016 against the Aggrieved Parties
in relation to their being suspected drug personalities under
OPLAN TOKHANG, and to other operations or activities
subsequent to such incident in relation to herein Petitioners
Parties.

25

(c) After due hearing, to issue the privilege of the Writ of

Amparo to protect the Petitioners/Aggrieved Parties from
any further violation of their rights;
Petitioners pray for other just and equitable relief.
Respectfully submitted, Makati City for Manila. January 26,
2017.

By the counsel for Petitioners:

ROQUE & BUTUYAN LAW OFFICES
UNIT 1904 ANTEL CORPORATE CENTER
121 Valero Street, Salcedo Village
Makati City 1227
Email: mail@roquebutuyan.com
Tel. Nos. 887-4445/887-3894
Fax No: 887-3893
26

By:
JOEL RUIZ BUTUYAN
Roll No. 36911
PTR No. 5916291 | Jan. 9, 2017 | Makati
IBP No. 01742 | Lifetime
MCLE Compliance No. V-0013082 | Jan. 12,
2016

ROGER R. RAYEL
Roll No. 44106
PTR No. 3804125/ Jan. 4, 2017 Quezon City
IBP No. 02159 / Lifetime
MCLE Compliance No. V-0013140 | Jan. 12,
2016

ROMEL REGALADO BAGARES

PTR No. 5916298| Jan. 9, 2017 | Makati
IBP No. 1060904| Jan. 10, 2017| So. Cotabato
MCLE Compliance No. V-0022679 | June 29,
2016

GILBERT TERUEL ANDRES

Roll No. 56911
PTR No. 3176091/ ?/ Makati City
IBP No. 877499/Jan. 3, 2012/ Negros
Occidental
MCLE Compliance No.III-0013698,
April 22, 2010

27

GEEPEE A. GONZALES
Roll No. 59686
PTR No. 5916299| Jan. 9, 2017 | Makati
IBP No. 1060903| Jan. 10, 2017| Oriental
Mindoro.
MCLE Compliance No. V-0013167| Jan. 12,
2016

ETHEL C. AVISADO
Roll No. 56254
PTR No. 5916293 | Jan. 9, 2017 | Makati
IBP No. 1060902| Jan. 10, 2017| Davao City
MCLE Compliance No. V-0022681| June 29,
2016
ZHARMAI C. GARCIA
Roll No. 62891
PTR No. 5916297 | Jan. 9, 2017| Makati
IBP No. 013345 | Lifetime | RSM
MCLE Compliance No. V-0013105| Jan. 12,
2016
CRISTINA I. ANTONIO
Roll No. 64154
PTR No. 7115606 / Jan. 6, 2017 / Cagayan
IBP No. 1008162 / Lifetime / Cagayan
MCLE Compliance: N/A (Admitted to the
Philippine Bar in 2015)
GIL ANTHONY E. AQUINO
Roll No. 65698
PTR No. 5916294 / Jan. 9, 2017 / Makati
IBP No. 014871 / Lifetime/ Makati
MCLE Compliance: N/A (Admitted to the
Philippine Bar in 2016)

28

COPY FURNISHED:
RESPONDENT PDG RONALD DELA ROSA, Camp Crame,
Quezon City
RESPONDENT PSSUPT GUILLERMO LORENZO T. ELEAZAR,
Camp Karingal, Quezon City
RESPONDENT P/SUPT. LITO PATAY, QCPD S6, Bgy. Batasan,
Quezon City
RESPONDENT P/SI EMIL S. GARCIA, QCPD S6, Bgy. Batasan,
Quezon City
RESPONDENT PO3 ALLAN FORMILLEZA, QCPD S6, Bgy.
Batasan, Quezon City
RESPONDENT PO1 JAMES AGGARAO, QCPD S6, Bgy. Batasan,
Quezon City
RESPONDENT, PO1 MELCHOR NAVISAGA, QCPD S6, Bgy.
Batasan, Quezon City
OFFICE OF THE SOLICITOR GENERAL
134 Amorsolo Street, Legaspi Village,
Makati City, 1229

29

Explanation
This Petition is being served to the parties by registered mail because
of time, personnel and distance constraints, pursuant to the Revised
Rules of Procedure.
GIL ANTHONY E. AQUINO

30