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COMMISSION ON ELECTIONS
MANILA
OPPOSITION
pray that the Petition be denied due course on the grounds that:
1987 Constitution;
shopping;
and
(8) The Petition is, in fact, insufficient as it does not meet the
THE OPPOSITORS
PREFATORY STATEMENT
are not wasted for the conduct of the registration and plebiscite
who are for the rule of law, respectfully call upon this Honorable
prevailing jurisprudence.
and much less give due course to, the instant Petition calling for a
people’s initiative.
It is beyond cavil that the provision granting the people the right
legislation, thus –
even entertain the same or take any action thereon, much less
II
occasion to rule that Republic Act No. 6735 cannot serve as the basis
Honorable Commission.
III
marked and made integral parts hereof as Annexes “1” and “2”,
respectively.
on the website which provides that “(3) Senators whose term of office
12
thirtieth day of June 2010” was omitted from the instant Petition.
reads as follows –
the very same document subject of the instant Petition, and not just a
Constitution.
IV
Constitution.
“on their own behalf and together with the registered voters who have
(Petition, paragraph 2), there is no showing that they have been duly
reforms x x x.”
any authority to act for and in behalf of the registered voters whose
forum shopping.
held that –
VI
16
Notably, even Section 3(a) of Republic Act No. 6735, which the
supplied).
as the basis for the current initiative which clearly refers to a major
VII
Worse, the instant Petition embraces more than one (1) subject
matter, contrary to the provisions of the very law it invokes and the
following restriction –
more than just one subject. It involves not only a shift from the
than one (1) subject matter, in patent contravention of the very law
VIII
Even assuming for the sake of argument that the Petition may
be filed pursuant to Republic Act No. 6735 and Resolution No. 2300,
the total number of registered voters, and that at least three percent
Petition.
23
for the 3rd District and the OIC for the 1st and 2nd District of Davao
provides that –
For all the foregoing reasons, the outright denial of the instant
PRAYER
that:
1987 Constitution;
shopping;
and
26
(8) The Petition is, in fact, insufficient as it does not meet the
EXPLANATION
(Pursuant to Section 11, Rule 13 of the
1997 Rules of Civil Procedure)
GILBERT V. SEMBRANO
COPY FURNISHED:
DEMOSTHENES B. DONATO
Counsel for the Petitioner Raul L. Lambino
Autoland Building
1616 Quezon Ave.
South Triangle, Quezon City
ALBERTO C. AGRA
Counsel for the Petitioner Erico B. Aumentado
No. 12, Fourth St.
Saint Ignatius Village, Quezon City
28
NOTARY PUBLIC
Doc. No. _____;
Page No. _____;
Book No. _____;
Series of 2006.
29
REPUBLIC OF THE PHILIPPINES )
____________ CITY )
SECRETARY’S CERTIFICATE
I, Carlos P. Medina, Jr., Filipino, of legal age, and with office address at Room
101, Ground Floor, APS Building, No. 20 Rockwell Drive, Rockwell Center, Makati City,
after having been duly sworn in accordance with law, hereby certify:
1. I am the duly elected and incumbent Corporate Secretary of ONEVOICE,
Inc., an association duly organized and existing under the laws of the Philippines, with
principal office at 16th Floor West Trade Center, West Ave., Quezon City, Metro Manila.
2. At the special meeting of the Board of Directors of ONEVOICE, Inc. held
on 25 August 2006 at its principal office, at which meeting a quorum was present and
acting throughout, the following resolutions were unanimously approved and adopted:
“RESOLVED, that the Corporation appoints its Chairperson, Christian S.
Monsod, to be its true and lawful attorney‐in‐fact to cause the preparation and
filing of an OPPOSITION before the Commission on Elections of the Philippines
to the Petition filed by Raul L. Lambino and Erico B. Aumentado in the matter of
proposing amendments to the 1987 Constitution through a People’s Initiative
filed on 25 August 2006.
“RESOLVED FURTHER, that said Christian S. Monsod be authorized and
empowered to sign and deliver any and all verification, certification, or
agreement, or file any and all pleadings as are relevant to accomplish the
purpose of his appointment.
“FINALLY RESOLVED, that this designation shall remain valid and binding
until modified, altered or revoked by a subsequent Board Resolution.”
3. The foregoing is in accordance with the records of ONEVOICE, Inc..
4. The foregoing resolutions have not been modified, altered or repealed
and are still in full force and effect.
IN WITNESS WHEREOF, I have hereunto affixed my signature this 27th day of
August 2006 in Makati City.
CARLOS P. MEDINA, JR.
Corporate Secretary
SUBSCRIBED AND SWORN to before me on this 27th day of August in
_________, affiant exhibiting to me his Community Tax Certificate No. 24802242 issued
on 1 January 2006 in Marikina City.
Doc. No. ______;
Page No. ______;
Book No. ______;
Series of 2006.
30
AFFIDAVIT OF SERVICE
I, Ray Paolo J. Santiago, Filipino, of legal age, single, with business address at
Room 101, APS Building, Rockwell Drive, Rockwell Center, Makati City, Metro
Manila, after being sworn in accordance with law, hereby depose and state that:
1. I work for the Ateneo Human Rights Center, Room 101, APS Building,
Rockwell Drive, Rockwell Center, Makati City, Metro Manila;
ALBERTO C. AGRA
Counsel for the Petitioner Erico B. Aumentado
No. 12, Fourth St.
Saint Ignatius Village, Quezon City
SUBSCRIBED AND SWORN to before me this 28th day of August, 2006, affiant
exhibiting to me his Community Tax Certificate No. 12883420 issued on 03
January 2006 at Parañaque City.