REPUBLIC OF THE PHILIPPINES
PRESIDENTIAL ELECTORAL TRIBUNAL
Manila
FERDINAND “BONGBONG” R.
MARCOS, JR.,
Protestant,
- versus - PET Case No. 005
FOR: Election Protest
Vice President
MARIA LEONOR “LENI DAANG
MATUWID” G. ROBREDO,
Protestee.
x - - - - - - - - - - - - - - - - - - -x
URGENT OMNIBUS MOTION FOR (1) CLARIFICATION
(ON THE RESOLUTION DATED 05 DECEMBER 2017);
AND (2) TO ALLOW PARTIES AND THEIR
REPRESENTATIVES TO BE PRESENT DURING THE
INVENTORY PRIOR TO TRANSPORT TO THE
DESIGNATED STAGING AREA/HUB
PROTESTEE MARIA LEONOR G. ROBREDO, by the
undersigned counsel, to the Honorable Tribunal, respectfully
states:
1. On 22 December 2017, protestee Maria Leonor G.
Robredo (hereafter “Robredo” for brevity) received copy of
the Resolution dated 05 December 2017.
2. In the said Resolution, the Honorable Tribunal
resolved to:
“(b) DIRECT all City and Municipal
Treasurers and Election Officers to
DELIVER to the PET Retrieval Team at
the designated staging area/hub at the
Camarines Sur Convention Center,
Capitol Complex, Cadlan, Pili, Camarines
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Sur, or if the Convention Center is not
available, at the Freedom Sports
Complex of the Department of
Education, Region V, Division of
Camarines Sur, all the ballot boxes and
their contents with their keys, if with
locks; voter’s receipts (if not included
inside or with the ballot boxes); list of
voters, particularly the EDCVL; VRRs;
and book of voters and other election
documents and paraphernalia used in
the 2016 National and Local Elections,
regardless of the pendency of any
election protest or election related case
before the House of Representatives
Election Tribunal, Senate Electoral
Tribunal, Commission on Elections or
any trial court, based on the schedule
below:
January 23, January 24, January 25, January 26,
2018 2018 2018 2018
(Tuesday) (Wednesday) (Thursday) (Friday)
Cabusao Naga City Tigaon Baao
Sipucot Camaligan Lagonoy Balatan
Lupi Calabanga Tinambac Bato
Ragay Bombon Siruma Buhi
Del Gallego Canaman Presentacion Bula
Libmanan Magarao Garchitorena Iriga City
Pamplona Ocampo Caramoan Nabua
Pasacao Pili San Jose
San Fernando Sagnay
Milaor Goa
Gainza
Minalabac
(c) DIRECT the Regional Trial Court
judges befre whom any election protest
involving the clustered precincts of the
Municipalities of Siruma and Calabanga
are pending to RELEASE to the PET
Retrieval Team in Camarines Sur, under
proper receipt and with notice to the
parties, the ballot boxes and their
contents with their keys, if with locks;
voter’s receipts (if not included inside or
with the ballot boxes); list of voters,
particularly the EDCVL; VRRs and books
of voters and other election documents
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and paraphernalia used in the 2016
National and Local Elections based on
the above schedule;”
3. Hence, protestee Robredo is constrained to seek a
clarification on the procedure for the collection and retrieval
of the ballot boxes, election documents and paraphernalia in
the protested clustered precincts in the Province of
Camarines Sur.
4. Based on the said Resolution of the Honorable
Tribunal, it would appear that the respective Municipal
Treasurers and Election Officers will merely deliver the ballot
boxes, election documents and paraphernalia to the PET
Retrieval Team based on the schedule as provided.
5. However, in doing so, the parties will not be able
to see the original state of the ballot boxes in its storage.
6. Consequently, representatives of the parties will
not be able to write down their observations and comments
during the inventory of the ballot boxes, election documents
and paraphernalia while at their storage.
7. More importantly, the parties will not be able to
verify the completeness of the ballot boxes and the
correctness of the items being collected and retrieved.
8. Finally, the presence of the parties during the
inventory of the ballot boxes, election documents and
paraphernalia will enable them to make a preliminary
observation as to its state, i.e., the condition of the ballot
boxes, locks and seals prior to the retrieval.
9. Thus, for purposes of transparency, protestee
Robredo asks that the parties be allowed to:
9.1. Be present during the inventory of the ballot
boxes, election documents and paraphernalia prior
to its transport to the designated staging
area/hub;
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9.2. Escort/Accompany the ballot boxes, election
documents and paraphernalia from their
respective storage while being transported to the
designated staging are/hub; and
9.3. Thereafter, be allowed to escort/accompany
the ballot boxes, election documents and
paraphernalia from their respective storage while
being transported to from designated staging
are/hub to the Supreme Court-Court of Appeals
Gymnasium, Supreme Court Compound, Ermita,
Manila.
10. This motion is not intended for delay but dictated
solely by the foregoing exigencies.
PRAYER
WHEREFORE, PREMISES CONSIDERED, it is respectfully
prayed to the Honorable Tribunal that a Resolution be
issued:
1. CLARIFYING the Resolution dated 05 December
2017;
2. ALLOWING the parties and their representatives to
be present during the inventory at the storage;
3. Thereafter, ALLOWING the parties to
escort/accompany the ballot boxes, election
documents and paraphernalia from the storage to
the designated staging area/hub; and
4. Finally, ALLOWING the parties to
escort/accompany the ballot boxes during its
transport from the designated staging area/hub to
the Supreme Court-Court of Appeals Gymnasium,
Supreme Court Compound, Ermita, Manila.
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Protestee Robredo prays for such other reliefs as may
be just and equitable under the premises.
Pasig City for Manila. 03 January 2018.
ATTY. ROMULO B. MACALINTAL
Lead Counsel for Protestee
Maria Leonor G. Robredo
13 Cagayan Valley Street,
Philamlife Village, Las Pinas City
Telephone No. 0918-9107454
Roll No. 29040
PTR No. 11214198J/12 January 2017/Las Pinas City
IBP Lifetime No. 0724
MCLE Compliance No. V-0018139/13 April 2016
rbmacalintal@gmail.com
SARDILLO SARDILLO SALOM LAW OFFICE
Collaborating Counsel for Protestee
Maria Leonor G. Robredo
Unit 802, Taipan Place, F. Ortigas Avenue,
Ortigas Center, Pasig City
02.706.4272/02.706.4273
By
MARIA BERNADETTE V. SARDILLO
Roll No. 45897
PTR No. 3474221/03 January 2018/Pasig City
IBP Lifetime No. 07133
MCLE Compliance No. V-0010907/30 September 2015
beng.sardillo@s3law.com
REQUEST
THE SECRETARY OF THE TRIBUNAL
PRESIDENTIAL ELECTORAL TRIBUNAL
MANILA
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Please submit the foregoing “Urgent Omnibus Motion
(1) For Clarification (on the Resolution dated 05 December
2017); and (2) For the Parties and their Representatives to
be Present During the Inventory Prior to Transport to the
Designated Staging Area/Hub” for the consideration and
approval of the Honorable Tribunal immediately upon receipt
hereof without need for oral arguments.
MARIA BERNADETTE V. SARDILLO
NOTICE OF HEARING
ATTY. GEORGE ERWIN M. GARCIA
ATTY. JOAN M. PADILLA
G. E GARCIA LAW OFFICE
Lead Counsel for Protestant
Ground Floor Laiko Building
372 Cabildo Street, Intramuros,
1002 Manila
OFFICE OF THE SOLICITOR GENERAL
134 Amorsolo Street
Legaspi Village, 1229 Makati City
Please take note that undersigned counsel will submit
the foregoing “Urgent Omnibus Motion (1) For Clarification
(on the Resolution dated 05 December 2017); and (2) For
the Parties and their Representatives to be Present During
the Inventory Prior to Transport to the Designated Staging
Area/Hub” for the consideration and approval of the
Honorable Tribunal immediately upon receipt thereof without
need for further oral arguments.
MARIA BERNADETTE V. SARDILLO
Copy furnished:
ATTY. GEORGE ERWIN M. GARCIA
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ATTY. JOAN M. PADILLA
G. E GARCIA LAW OFFICE
Lead Counsel for Protestant
Ground Floor Laiko Building
372 Cabildo Street, Intramuros,
1002 Manila
OFFICE OF THE SOLICITOR GENERAL
134 Amorsolo Street
Legaspi Village, 1229 Makati City
EXPLANATION
Due to unavailability of messengers and the distance of
the parties, a copy of the herein “Motion” were sent to the
above-named parties by registered mail.
MARIA BERNADETTE V. SARDILLO
