IN THE MATTER OF THE IMPEACHMENT OF GABRIEL IGNACIO P.

ALEJO AS VICE PRESIDENT OF THE SANGGUNIAN NG MGA MAG-AARAL NG PAMANTASANG ATENEO DE MANILA, MIGUEL PAOLO P. RIVERA, JAMES VICTOR V. ROMAN, ET. AL., Complainants. x---------------------------------------------------x COMPLAINT FOR IMPEACHMENT Undersigned COMPLAINANTS most respectfully file this Complaint for the Impeachment of Mr. Gabriel Ignacio P. Alejo (hereafter, Respondent), currently the Vice President of the Sanggunian ng mga Mag-aaral ng Pamantasang Ateneo de Manila (hereafter, Sanggunian), upon the grounds of gross neglect of duty, as follows: PREFATORY STATEMENT When the students of the Ateneo de Manila University went to the first day of polls last February 14, 2012, they expected a clean and straightforward election. This years elections largely centered on the issues of representation, finance, politicization, and nation-building. What welcomed the students, however, was an issue largely alien to them. It was the amendment of the 2005 Constitution of the Undergraduate Students of the Ateneo de Manila Loyola Schools (hereafter, Constitution). This was a matter of utmost importance to every student and sector in the Loyola Schools. However, student leaders from all sectors, such as organizations, political parties, and even Sanggunian officers themselves, were shocked. It was apparent that the Plebiscite to amend the Constitution had continued without the prior knowledge of the constituency. Amending the constitution, though an important step in building and reforming the student government, had been presented in a manner that does not reflect its purpose and ultimate goal. The Constitution is a document that represents and embodies the highest collective aspirations of the students, it is to be treated with the highest regard, and consequently any action to amend it should be held to the same standard. The Committee on Constitutional Review (hereafter, CCR), is an auxiliary committee in the Sanggunian Central Board tasked with the duty of re-evaluating the Constitution and educating the constituency regarding any amendments made to the Constitution. This ensures that the student body will be well-informed of any changes regarding the structure of their government, how their representatives function, and as to how their rights as students and aspirations as a community will be defended by the people they trusted enough to be their leaders. It is clear that this very serious duty was thrown in the wayside in order to expedite a process that the student body was not prepared for. In his capacity as Chair of the CCR, Respondent sought to continue the plebiscite without prior approval of the Central Board, prior knowledge of the Student body and without due process. An action with such gravity cannot simply have been a form of miscommunication between organizations and parties. Instead, it was a deliberate act of imprudence and disrespect for the due process of the Constitution, and a betrayal of the public trust. The public must be outraged, for they have been rendered voiceless by the actions carried out by the Respondent in his misguided belief that amending the

Constitution need not go through the regular process of conscious deliberation accorded actions conducted in the public space. He had instead carried out actions accorded to him by the public out of his own self-interest of pushing through with the plebiscite at all costs. Having carried out his duties as Vice President and with utmost carelessness, imprudence, inefficiency, and mismanagement, the students of the Ateneo de Manila must make the Vice President accountable. He must be impeached. NATURE OF THIS ACTION Therefore, this action for impeachment is brought against Vice President Gabriel Ignacio P. Alejo in accordance with the provisions of Section 19, Article II of the 2005 Constitution of the Undergraduate Students of the Ateneo de Manila Loyola Schools, on the grounds of gross neglect of duty. THE PARTIES Complainants are bona fide students of the Ateneo de Manila University - Loyola Schools, responsible Filipino citizens, and are all of legal age. For purposes of the Complaint for Impeachment, complainants may be served with the copies of pleadings, notices, and processes to the Complainant Mr. Miguel Paolo P. Rivera at Matanglawin Room, Room 201, Manuel V. Pangilinan Center for Student Leadership, Ateneo de Manila University - Loyola Schools. They bring this action for and on behalf of the student body of the Ateneo de Manila University - Loyola Schools by authority of the Constitution, consistent with their civic and constitutional duties as students of the Ateneo de Manila University - Loyola Schools. Respondent Gabriel Ignacio P. Alejo is the incumbent Vice President of the Sanggunian, currently a candidate for the Presidency of the Sanggunian, and is being sued in his official capacity as Vice President of the Sanggunian. He may be served with summons and other processes at the Office of the Vice President, Room 200, Manuel V. Pangilinan Center for Student Leadership, Ateneo de Manila University - Loyola Schools. GENERAL ALLEGATIONS Respondent, in his capacity as Chair of the CCR, unlawfully expedited the inclusion of the plebiscite in the ballot of the 2012 Sanggunian General Elections without the proper authority to do so, grossly neglecting his duty, and betraying the public trust.

GROUNDS FOR IMPEACHMENT Respondent neglected his duty in the following manner: ARTICLE I RESPONDENT NEGLECTED HIS DUTY WHEN HE PERSONALLY ORDERED THE COMMISSION ON ELECTIONS TO INCLUDE THE PLEBISCITE IN THE BALLOT OF THE 2012 SANGGUNIAN GENERAL ELECTIONS WITHOUT THE AUTHORITY TO DO SO, AND WITHOUT OFFICIAL APPROVAL OF THE ENTIRE CCR AND THE SANGGUNIAN CENTRAL BOARD. DISCUSSION OF THE GROUNDS OF IMPEACHMENT I. RESPONDENT NEGLECTED HIS DUTY WHEN HE PERSONALLY ORDERED THE COMMISSION ON ELECTIONS TO INCLUDE THE PLEBISCITE IN THE BALLOT OF THE 2012 SANGGUNIAN GENERAL ELECTIONS WITHOUT THE OFFICIAL APPROVAL OF THE ENTIRE CCR AND THE SANGGUNIAN CENTRAL BOARD. 1.1. Paragraph 2, Section 43 of the Sanggunian CB CIP states thus: The Committee Chair is not mandated to report at weekly central board meetings, only when a decision, stand, or call to action has to be made. Respondent clearly did not report to the Central Board when the decision to include the plebiscite in the ballot was made. Given that some of the Complainants are members of the Central Board, they will attest that there was no clear decision presented to them in any official meeting, informing them that the decision made was to include the plebiscite in the ballot. 1.2. Respondent clearly violated the terms of his Leave of Absence and grossly neglected his duty as the Vice President when he decided to include the plebiscite in the ballot while it was still the official campaign period of the 2012 Sanggunian General Elections. Though the format provided by Annex A of the Sanggunian CB CIP, provides that any officer may still fulfill student council endeavours if there is immediate need, the plebiscite could not have been an endeavour of immediate need, since the debates regarding amendments had not yet been concluded by the Central Board and the matter of the plebiscite had not yet been deliberated or decided upon by the same. 1.3. Section 46 of the CB CIP clearly states that: A committee may initiate investigations on a proposed action even before approval of the Board. Only fact-finding activities may be performed without the Boards consent. This is to expedite the decision making process. The succeeding Section reads in part:

...Based on the result of the public hearings or committee discussions, the Committee may decide to draft a stand or resolution regarding the issue. If the committee decides to pursue other forms of action, it transmits a report to the Plenary presiding officer informing the Plenary of its plans which will then be executed by the School Boards. The Committee is given within two (2) weeks to submit a proposed plan of action to the Board. Section 48 of the CB CIP reads in full that: The Committee shall present the proposed plan of action to the Board. There shall be an allotted time for discussion for the plan of action. After the discussion, it shall be put to vote following Section 37. The proposal may be initially be approved in substance and the final form shall be formulated by the committee. Failing to pass this vote defeats the measure. Testimony from a member of the CCR, indicates that no committee action was planned within the span of the two weeks allotted before presentation of a proposed action. The last official meeting of the Central Board was held on the 20th of January, 2012. Minutes of the meeting indicate that following a motion by Dan Remo, a final review of the proposed amendments to the Constitution was made. No further meeting of the Central Board occurred. Despite this fact, and the clear indication that any and all action by the Committee, besides that of a fact-finding nature, must be discussed and put to a vote by the Central Board, the plebiscite continued. 1.4 Without the prior consent of the CB and his Committee, Respondent proceeded to discuss the proposed action on the Constitutional Amendment with the COMELEC. 1.5 That the plebiscite continued without the prior knowledge or consent of the Central Board violates Sections 46 through 48 of the CB CIP. Respondent in his capacity as CCR Chair personally directed the action, with the concurrence of the COMELEC. Section 97 of the CB CIP reads in full that: Because following this code is considered part of the duties of the officer, willful and repetitive violations of this code shall be considered neglect of duty, which is an impeachable offense.

RESOLUTION AND PRAYER WHEREFORE, pursuant to the procedure laid out in Section 19, Article II of the Sanggunian Constitution, the undersigned complainants, as students of the Ateneo de Manila University - Loyola Schools, hereby file the impeachment complaint against Respondent Vice President Gabriel Ignacio P. Alejo. Thereafter, undersigned Complainants respectfully pray that the Honorable Magistrates of the Student Judicial Court conduct trial forthwith and thereafter, render a judgment of conviction against Respondent Vice President Gabriel Ignacio P. Alejo. Other reliefs, just and equitable, are also prayed for. Quezon City, Metro Manila, February 19, 2012.

THE UNDERSIGNED, Miguel Paolo P. Rivera Lead Prosecutor Premier, Christian Union for Socialist and Democratic Advancement (Crusada) James Victor V. Roman Prosecutor De facto President, Crusada Artkario Bian L. Villanueva Prosecutor Secretary-General, Crusada Ana Maria B. Raymundo School of Social Sciences Chairperson Lance Andrew D. Viado School of Humanities Chairperson Raphael Niccolo L. Martinez 1st Year School of Social Sciences Central Board Representative Daniel Antonio S. Remo 2nd Year School of Social Sciences Central Board Representative Felix Raphael G. Mintu 2nd Year School of Humanities Central Board Representative Alvin Jonathan P. Yllana 3rd Year School of Management Central Board Representative Antonio Rafael N. Elicao 3rd Year School of Humanities Central Board Representative John Luigi R. Villamin 3rd Year School of Humanities Executive Officer Maria Antonia Giannina L. Potenciano 3rd Year School of Social Sciences Executive Officer Regine Stephanie B. Guevara Sanggunian Department of External Affairs Chairperson