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ROTARY INTERNATIONAL

DISTRICT 3780

May 28, 2013

JOHN HEWKO
General Secretary Rotary International One Rotary Center, 1560 Sherman Avenue, Evanston, IL, USA Thru : Ms. Joy Walker
Manager, Club & District Support South Pacific & Philippines Office Rotary International, Parramata, NSW Australia

SUBJECT : REPLY To Election Complaint by RC Pag-Asa, RI District 3780 Dear General Secretary Hewko: In connection with the above subject complaint and as per letter (email) dated May 21, 2013 from Ms. Joy Walker, requesting for a detailed reply to the same, the undersigned District Govenor (DG), with the Members of the District Credentials Committee, hereby submit the following, by way of our reply to the allegations raised by the complaining party, to wit: 1. Rotary International District 3780 selects its District Governor-Nominee (DGN) by a nominating committee procedure in accordance with Section 13.0120.1 of the RI By-laws. The selection process, this Rotary Year 2012-13, under the leadership of the undersigned District Governor, and district officers, was conducted in strict and faithful compliance with our District 3780 Terms of Reference (TOR), duly approved and adopted by the clubs last District Conference 2012, and consistent with the provisions of the R.I. By-laws and Code of Policies. 2. Validity of the D-3780 Terms of Reference. The subject TOR, which being assailed by complainant, was duly approved and adopted by a majority of the Rotary Clubs in the District, through their respective electors, during the 2012 District Conference (DisCon 2012), held at the Tagaytay Vista Hotel, Tagaytay City, last April 21, 2012. A Certification to this effect, signed by then DG Jess Cifra, and then District Secretary Jesse Tanchangco, is herewith attached. Hence, it is a valid document and its provisions duly applicable to the selection process for DGN. (Annex A, Reply) 2.1.Even complainant, RC Pag-asa, through its PP Oca Karaan, actively participated in the plenary session during DisCon 2012, in Tagaytay, where they were able to express their position/ objection to the same TOR, and

other district resolutions presented therein. During the same plenary session, the same TOR was approved and adopted by the majority. 2.2.During the recent District Conference (DisCon) 2013, held in Camp John Hay, Baguio City, the same complainant, RC Pag-asa, thru the same PP Oca Karaan, again participated and raised the same question against the TOR. After due discussion, the plenary voted to sustain the validity of the TOR, to govern the selection process for DGN. (The objection of RC Pag -asa was overruled). This was admitted by Complainant in Par.1a.4.b, Complaint. 2.3.RC Pag-Asa, herein complainant, after participating (without question) in the selection process, provided under the same TOR, can no longer assail its validity or applicabilityjust because their suggested candidate lost in the nomination process. Hence, complainant should be estopped from further questioning or assailing the validity or applicability of the subject TOR, which they have accepted and complied with in the first place. 2.4.Minor inconsistenciesgrammatical, clerical or typographical errorsin the text or wordings of the same TOR, will NOT invalidate, nor render inoperative the same TOR. Contrary to the allegation of complainant ( Par.1.a.3.-blatant discrepancies, that would make it unintelligible and irrelevantxxx), such are minor discrepancies which do not destroy or diminish the over-all meaning, applicability of the other provisions of the document. In other words, the whole TOR can still be logically and intelligently interpreted by any Rotarian by simple common sense. 2.5.Based on the foregoing, there should be no dispute as to the validity and applicability of the District 3780 Terms of Reference (TOR), as the governing rules for the selection process for DGN in our District. 2.6.On this particular issue or allegation, the subject Complaint is misleading and based of false statement of facts, and / or erroneous reasoning. 3. Under Article IV, Sec. 2 6, of the same Terms of Reference (TOR), the following Committees were established to undertake and conduct the process of selection or election of the District Governor Nominee (DGN)
Section 2 The Nominating Committee shall seek out and select the best qualified Rotarian for nomination as District Governor. It shall have a total of thirteen (13) members. It shall be chaired by the Immediate Past District Governor. If the Immediate Past District Governor cannot assume the post of Chairman of the Nominating Committee, the District Governor shall appoint another Past District Governor as the Chairman of the Nominating Committee. Section 3 The Elections Procedures Committee shall provide guidance, support and supervision to the Credentials Committee and the Balloting Committee. The Committee shall
REPLY to the Election Complaint of RC Pag-Asa, R.I. D-3780

be comprising of the Chairpersons of the Credentials Committee and the Balloting Committee. It shall be chaired by a Past District Governor. Section 4 The Credentials Committee shall supervise the selection of the members of the Nominating Committee and shall examine the qualifications of the proposed members to the Nominating Committee. It shall examine and establish if a Club Certificate has been timely submitted and is valid. It shall resolve all matters pertaining to the validity of a Club Decision. It shall consist of three members and shall be chaired by a Past President Section 5 The Balloting Committee shall supervise the conduct of all balloting exercises in the event of a valid challenge to the choice of the Nominating Committee for District Governor Nominee. It shall resolve all issues regarding the validity of ballots or matters regarding the procedures. The Balloting Committee shall comprise of three members and shall be chaired by a Past President. Section 6 The District Legal Committee shall act as the Legal Counsel of the Committee on Elections Procedures and the Committees on Credentials and Balloting. It shall be chaired by the District Legal Counsel.

4. The entire selection process, under the District 3780 TOR, was conducted by undersigned district officers, with utmost good faith, fairness and integrity. All district officers concerned, the members of the District Election Procedures Committee, and the Credentials Committee, acted in the highest degree of diligence and integrity, always faithful to Rotarys Guiding Principles and Code of Conduct. (Annex B, C, D,E, F, G, J, S, Reply) 3.1.The Members to the Election Procedures Committee, the Credentials Committee, the Balloting Committee, and the Legal Committee, were all appointed by the undersigned District Governor, last July 1 st, 2012, based on their proven record and reputation for probity, integrity and independence. Each of the members are experienced Rotary leaders, who are well respected by our fellow Rotarians in District 3780. Their qualifications and excellent reputation leaves no room to doubt their motives in conducting this years selection process. 3.2.Each of the Members of the above listed Committees, particularly the Credentials Committee, were all trained and appraised for their duties and responsibilities, even prior to the period of selection. Most of them have already served in the same Committee in the previous Rotary years. In other words, they know their job well, and all the necessary experience to safeguard the process even against all possible irregularities that can be committed by unscrupulous parties. 3.3.The Members of the Elections Procedures Committee, Credentials Committee, Balloting Committee, and Legal Committee are :

REPLY to the Election Complaint of RC Pag-Asa, R.I. D-3780

Elections Procedure Committee Chairman : Past District Governor Nemesio Nemie Peralta , RC Diliman Members: Lt. Gov. Angel Gahol, Chair Credentials Committee Lt. Gov. Dwight Ramos, ChairBalloting Committee PP Luis Louie M.C. Pangulayan, ChairLegal Committee Credentials Committee Chairman: Lt. Gov. Angel Gahol, RC Neopolitan Fairview PDS Jesse Tanchangco, Vice ChairCredentials Committee RC Loyola Heights AG Rebecca Becca Dela Cruz, MemberCredentials Comm RC Batasan Hills Balloting Committee Chairman: Lt. Gov. Dwight Ramos, RC Quezon City PDS Jesse Tanchangco, Vice ChairBalloting Comm RC Loyola AG Cristina Cristy Dagdag, MemberBalloting Comm RC Quezon City Circle AG Eliza Baby Allado, MemberBalloting Comm RC New Manila Heights Legal Committee Chairman: PP Luis Louie M.C. Pangulayan, ChairLegal Comm RC San Francisco Del Monte COS Arnold Arnold Guerrero, Vice ChairLegal Comm RC SFDM SDDS Eric Santos, MemberLegal Comm RCCommonwealth AG Tom Guno, MemberLegal Comm RC Ayala Heights 3.4. Complaint stated NO specific act or actions committed by any one of the above listed members/ district officers which constitute a clear, specific violation of the Terms of Reference, or the R.I. By-Laws, or Code of
REPLY to the Election Complaint of RC Pag-Asa, R.I. D-3780

Policies. Except for sweeping generalizations, and vague accusations, no clear and convincing proof was ever mentioned, or submitted by complainant, against any of the above Members of the Committee, to establish any guilt or wrongdoing personally committed by anyone, or all of them. 3.5. Again, on this particular issue/s or allegation/s (Par. 1, 2, 3, and subheadings), the subject Complaint is misleading and based on false statements of fact, and/or malicious, baseless accusations, unsupported by clear and convincing proof. 5. Re: Alleged Letters Sent (Annex 5, 13,14,Par. 3.D, 3.F, 3.G. & 3.g1.) by RC Pag-Asa to the Office of the District Governor. We take exception to the false statement made by complainant in Par.1.a.4. of the Complaint with stated that : The governor did not bother to correct such defects and still willfully applied such defective TOR in the election processxxx. This is simply false. 5.1. After receipt of the very first letter dated 12 Feb 2013 ( Annex 13, Complaint), the undersigned District Governor, immediately contacted complainant Club President Lorenzo Dizon, and verbally communicated to him that the suggestions contained in the letter will be well taken. The undersigned also made it clear to him that no formal, written reply will be sent to the club. Each time complainant sent a letter, a verbal acknowledgement of the letter was made to Pres. Dizon. In fact, it was even announced in the Presidents meeting last February 27, 2013, at the Sangkalan, with a request that the parties to the process observe the election rules / prohibition against campaigning. 5.2. The undersigned DG distributed copies of the RI election guidelines, and also sent the same via email to all clubs and club presidents and officers. It was clearly explained to all the club presidents that the selection process must be conducted in a dignified manner, and in strict compliance with the prohibition against campaigning and electioneering. 5.3. On February 27, 2013, held at Sangkalan Resto, the undersigned DG publicly acknowledged having received the letter from RC Pag-Asa (dated 12 Feb 2013). Moreover, the undersigned DG announced to all the club presidents that he will recommend to the Credentials Committee to adopt their (RC Pag-asa) suggestion to use ping-pong balls and a tambiolo (i.e. gadget for raffle) in the selection of members to the Nominating Committee. 5.4. In same meetings, the undersigned DG made it clear to complainant club president Dizon that no formal letters will be issued in response to
REPLY to the Election Complaint of RC Pag-Asa, R.I. D-3780

their letter, inasmuch as the suggestion is already adopted and publicly announced. Moreover, the undersigned DG expressed his intention not to be drawn into a series of exchange of letters with anybody including herein complainant club president. This is simply because the matters raised in each of their letters are such that they can be readily resolved without need of formalities. 5.5. For example, re: Par.3.F (Letter of 4 Feb 2013, Annex 14), undersigned DG simply replied and explained verbally that the qualification of good moral character was simply adopted from the Memo of previous DGs on the same subject. And, it should not pose as a serious dispute in this process. In other words, its a non-issue to begin with. (i.e. what so wrong with good moral character?) 5.6. Re: Par 3.G, (Annex 5), again it was verbally explained to them that the so-called discrepancies do not invalidate the entire document because they are minor typo or clerical error. It can not render the whole document inoperative or not applicable because the other provisions are clear and unequivocal in their literal meaning. It was also suggested to them that they file the necessary resolution with the coming District Legislative Assembly 2013to correct the errors or discrepancies, albeit minor. Complainant never did so. If it was such a big deal why did RC Pag-Asa or its president file any timely club resolution proposing to correct the alleged discrepancies? 6. Contrary to the allegation under Par. 2B, b.1 b.5, of the complaint, and with due respect, the presence or absence of a ballot box, by itself, do not invalidate the entire process of selecting the members of the Nominating Committee. The truth of the matter is that the envelopes containing the proposed names / members of the Nominating Committeesubmitted by the Clubswere at all times placed under secure lock and key, under the custody of the undersigned DG, and his staff. All necessary steps to safeguard the same documents were duly implemented. 6.1. In fact, herein complainant, RC Pag-Asa, together with RC Cubao East, who also submitted a suggested candidate for DGN, were both invited and/or requested, privately and publicly during the District Conference 2013, to conduct an audit of the total number of envelopes in our custody vis--vis the number of clubs who actually submittedto ascertain the accuracy of the number of envelopes involved. Both Clubs never responded to this invitation/ request. 6.2. To date, the same envelopes containing the names of the proposed members to the Nominating Committee are still in the ballot box, under

REPLY to the Election Complaint of RC Pag-Asa, R.I. D-3780

lock and key, and readily available for the review of any party, especially RC Pag-Asa. 6.3. Again, on this particular issue/s or allegation/s (Par. 2B and subheadings), the subject Complaint is misleading and based on false statements of fact, and/or malicious, baseless accusations, unsupported by clear and convincing proof. 7. Mandate and Authority of the Credentials Committee under the District TOR was clear and unequivocal. Article VIII of the same TOR clearly and expressly authorized the Credentials Committee to resolve any and all matters pertaining to the challenge to the choice of the Nominating Committee. Thus, contrary to the allegations in the complaint, the undersigned DG could not have possibly interfered or influenced the process of evaluation by the Credentials Committee, to wit:
ARTICLE VIII VALIDITY OF CHALLENGE AND CONCURRENCE Any and all matters regarding the challenge to the choice of the Nominating Committee and the concurrence to a challenge shall be resolved by the Credentials Committee based on the provisions of the Manual of Procedure, the Constitution, the By-Laws and the Code of Policies of Rotary International, and the Terms of Reference of RI District 3780.

8. Pursuant to the above quoted Article of the TOR, the Credentials Committee conducted its evaluation & validation of club resolutions, based Guidelines previously published and accepted by all the Clubs. The same Guidelines were consistent with the TOR, the R.I. By-Laws, Policies, and even R.I. pilot programs. A copy of the same Guidelines are herewith attached as Annex H, Reply. 8.1. The District Terms of Reference (TOR) authorized the Credentials Committee to resolve any and all matters regarding the challenge. Hence, it is empowered to provide guidelines in evaluation and/or validation of concurring club resolutions submitted. 8.2. The same guidelines previously issued by the Credentials Committee were consistent with the RI By-laws, and even with current R.I. Pilot Programs in other districts in India. They were issued in the best interest of the district and for the common good. 8.3. No protest, objection or question was made or raised by complainant RC Pag-Asa, or any of the concurring clubs herein, on the same

REPLY to the Election Complaint of RC Pag-Asa, R.I. D-3780

guidelines at the time it was released or published, until the last day set for submission. 8.4. In fact, the undersigned DG even asked complainant club president, in a phone conversation, whether the latter had read and understood the same guidelines of the Credentials Committee. Pres. Dizon answered in the affirmative. 8.5. The Credentials Committee conducted their evaluation of the club concurrences independently, and arrived at their decision / report, without any participation on the part of the undersigned DG. 8.6. When the Credentials Committee, thereafter, applied the same guidelines in their evaluation of club resolutions submitted, six (6) of the twelve (12) clubs were deemed not to have complied, and thus, their concurring resolutions to the challenge was considered as not valid in accordance with the guidelines, the TOR and the RI By-laws. 8.7. Again, after accepting the terms of the Guidelines, and submitting their club concurrences based on the same guidelines, the same complainant club, and all the other seven (7) concurring with this complaint, would now turn around and assail the very same process they agreed to followas if a serious violation was committed against themsimply because the outcome was not favorable to them. 8.8. Such actions betray their immaturity and irrational behavior so unbecoming of Rotarians, to say the least. 8.9. When the outcome of the selection or evaluation process did not favor herein complainants, they resort to attacking the very process they agreed to participate in, question the motives of well meaning district officers, and even malign the character of the highest officer of Rotary International in District 3780. 9. Complainant RC Pag-Asa, and its candidate should be estopped from questioning the validity of the rules and the officers who conducted the entire selection process. After they freely and voluntarily participated in this process, accepted the TOR, they can no longer question, nor be allowed to question or raise any valid issue against the very rules and process they have acquiesced to, in the very first placejust because the outcome did not favor them. In other words, if their candidate was selected, they would not have raised any issue at all. 9.1. It appears that the only motive behind this election complaint is for complainant club, its candidate and a few of their supporters, to assign
REPLY to the Election Complaint of RC Pag-Asa, R.I. D-3780

blame, vent their anger or frustration because of their defeat in this process. 10. The Credentials Committee did not violate the Rule on Club with Past Due Financial Obligations to R.I. Manual of Procedure, Page 9. Contrary to Par. 1.B, of the complaint, there was NO violation committed by the Credentials Committee when it issued the Guidelines On the Submission Of Concurrences by Clubs dated April 23, 2013, which stated that only functioning clubs may submit their concurrences. 10.1. On April 23, 2013, the Credentials Committee issued a document entitled, Guidelines on the Submission of Concurrences by the Clubs with the approval and upon the authority of the District Governor, and the TOR. 10.2. The same Guidelines were sent via email and acknowledged by all clubs concerned. A copy of the same guidelines is herewith attached as Annex _, and also provided by complainant as their Annex 6. ` 10.3. It was clearly stated by the same Guidelines that : Only functioning Rotary Clubs, as defined by the RI Board (refer to page 23 MOP), may submit their concurrence with the challenging resolution filed by RC Pag-asa. A functioning club is one that is able to: a) pay its per capita dues to R.I. without outside assistance.xxx 10.4. The above quoted proviso is a reasonable requirement or qualification for a club to be qualified to submit a concurrence. The Credentials Committee committed NO violation contrary to the TOR, the R.I. Bylaws and Code of Policies. 10.5. In providing such a qualification, the Credentials Committee did not set a deadline for payment of SAR and subscription to the Philippine Rotary Magazine on March 31, 2013contrary to Par. 1.B, b.1- b.8, of Complaint. 10.6. In so doing, the Credential Committee merely implemented the definition of a functioning club made by the R.I. Board. Accordingly, the Committee will only accept or consider as valid, club resolutions from those Rotary Clubs who comply with the definition of a functioning club. Thus, a Club with unpaid, overdue financial obligations to R.I., as of the last day for submission of concurrences (May 2, 2013), can NOT be deemed qualified (or a functioning club / in good standing) to submit a concurring resolution to the challenge. The Committee has no recourse

REPLY to the Election Complaint of RC Pag-Asa, R.I. D-3780

but to consider any resolution / certificate by that Club (with unpaid R.I. dues), as not valid. 10.7. It must be emphasized that the Credentials Committee never declared any Rotary Club as terminated and/or even non-functioning because that power solely belongs to the R.I. Board. 10.8. The Committee merely stated that the Rotary Club was not qualified to submit a concurring resolutionsimply because, at that point in time, it has not complied, nor can it be described, as a functioning clubas defined under page 23 of the MOP. Because it has not yet fully paid its financial obligations to R.I., it is a club that is not able to pay its per capita dues to R.I. and district without outside assistance. Hence, it can not be considered or described as a functioning club (as of that date) for the purpose of submitting a club concurrence. Its club resolution / certificate can NOT be validated, accepted, or counted by the Committee, for purposes of the challenge. 10.9. The Credentials Committee, thus acted correctly when it did not accept or consider as valid, the club concurrences (submitted in form of club certificates) of the following Rotary Clubs which had unpaid, overdue financial obligations to Rotary International as of March 31, 2013 (which was eventually relaxed to the R.I. records as of May 2, 2013, the last day for submission): RC New Manila West (unpaid USD1,358.53); RC Midtown Diliman (unpaid USD 571.00); RC Prima Vida Cubao (unpaid USD 444.00). 10.10. It is only fair and reasonable to expect that any Rotary Club, in any district for that matter, which seeks to participate in any concurrence or challenge, must have duly settled any or all its financial obligations to R.I. or district. 11. The same Guidelines (Annex H, Reply), above quoted, issued by the Credentials Committee, which require that Clubs be in good standing, or have no outstanding, overdue obligations, in order to submit a concurrence, is also consistent with current Rotary International Pilot Programs, or practices in other R.I. Districts in India. R.I. Districts 3202, D-3180, D-3140, D-3450, all have very similar requirements for clubs to submit or participate in concurrences to challenge. 11.1. This means that the requirements provided in the same Guidelines have similarity or precedents in other Rotary Districts. (please refer to Annex Q, Reply)

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12. The undersigned DG, in effect, merely announced the Report of the Credentials Committee as to the validity or invalidity of the club concurrences. However, prior to this, the undersigned DG also conducted a very detailed review with the members of the Committee, asking them searching questions to ascertain the accuracy and veracity of the factual and legal bases for their reported findings and conclusion. 12.1. After a very careful review of the same Credentials Committee findings, the undersigned DG found no cogent reason to modify, or set aside their findings of fact and conclusion. It was consistent with the Guidelines, the TOR, the RI By-Laws and policies. Hence, the proper announcement was made to all the Clubs in the District. 13. Re: RC New Manila West Basis for Invalidation of Club Resolution. Under Sec.2.1. of the Guidelines previously issued by the Credentials Committee, stated among others, that: the Credentials Committee shall the right to verify from the establishment concerned, or from the Assistant Governor, AGR, or from any club or district officer concerned, as to whether a meeting was actually held, with a quorum present, on the date and venue stated in the Club certificatexxx 13.1. Pursuant to the same Sec.2.1., the members of the Credentials Committee actually inquired from the Assistant Governor assigned to RC New Manila West, AG Ernie Paranis, as to whether a regular club meeting, with quorum was actually held or conducted by RC New Manila West. (Annex M, Reply) 13.2. The statement of AG Ernie Paranis was clear and unequivocal that there was only eight (8) out of 39 members present during the same meeting. Hence, there was no quorum during the said date and venue. Based on this, it was established by the Committee that RC New Manila West had submitted a false club certificate contrary to the RI By-Laws. 13.3. Moreover, the simple fact that RC New Manila West had an outstanding, overdue, unpaid obligation to RI, rendered it not qualified as a functioning club (under the Guidelines for Submission of Concurrences), and thus, its club concurrence could not be deemed or accepted as valid. 13.4. It must be emphasized that the undersigned DG never asked the Assistant Governors to spy on and monitor the meeting with the intention to intimidate. Such an accusation is false and simply betrays the utter contempt and hostility of herein complainant toward its own District officers.

REPLY to the Election Complaint of RC Pag-Asa, R.I. D-3780

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14. Re: RC West Triangle Basis for Invalidation of Club Resolution. Pursuant to the same Sec.2.1., above quoted the members of the Credentials Committee also inquired from the Assistant Governor assigned to RC West Triangle, AG Fulgencio Fol Rana, who is also Lt.Gov. -designate for next RY. 14.1. Based on the statement submitted by AG Fol Rana, it appeared that the club president of RC West Triangle did not even conduct a regular meeting in accordance with the standard club constitution & by-laws. Thus, there was NO quorum and also NO regular meeting at all. (Annex N,Reply) 14.2. From the same statement of AG Fol Rana, it was rather clear that: a) RC West Triangle did not even meet at their usual venue or room at the the Rotary Center. Instead, the club president (and 2 other members) simply stayed at the cafeteria/ restaurant throughout the evening and occupying only one table; b) The club president never formally called the meeting to order and presided over the business of the club; c) Throughout the same evening, there were only at most three (3) members out of 14 present, which did not constitute a quorum. 14.3. The statement of AG Fol Rana was further confirmed by the eyewitness account of another Assistant Governor, Adel Corpuz, who corroborated the factual statements of AG Fol Rana. Thus, there was no doubt in the mind of the members of the Credentials Committee that the club certificate submitted by RC West Triangle was a false statement and an invalid concurrencecontrary to Sec. 13.020.9.of the R.I. By-Laws. (Annex O,Reply) 14.4. It was duly established by substantial evidence that there was no regular meeting conducted by the club president, and much less, no quorum of members was present, to discuss and vote upon the resolution. 14.5. Under Sec. 2., of the Terms of Reference (TOR): xxxthe Club should have arrived at an agreement during a regular meeting of the Club. Agreements during informal meetings do not constitute a valid expression of a Rotary Club. A Club meeting is a regular meeting of if it is done on the date, time and place as registered with Rotary International. xxxA quorum should be present during the regular meeting. 14.6. Again, we stress that the Assistant Governors concerned were merely performing their assigned task. The undersigned DG never asked the Assistant Governors to spy on and monitor the meeting with the
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intention to intimidate. Such an accusation is false and simply betrays the utter contempt and hostility of herein complainant toward its own District officers. 15. Re: RC Prima Vida Cubao Basis for Invalidation of Club Resolution. According the Report / Minutes of the Meeting of the Credentials Committee, RC Prima Vida had an outstanding, overdue obligation to RI in the amount of USD 444.00. And, on the face of their club certificate, there was an inconsistency in the reported day of meeting per District record (Thursday), and the date of the meeting (Tuesday) appearing on the same club certificate. Finally, upon closer review of the club certificate submitted, it appears that the club secretary failed to submit the proper identification document where the signature of the officer concerned is clear shownagain in violation of Sec.1, Article III, of the TOR. 15.1 The overdue and unpaid obligation to R.I. on part of RC Prima Vida Cubao rendered it not qualified as a functioning club, and thus, its club concurrence could not be deemed or accepted as valid. 15.2. It was established that the Club meeting day (Tuesday) stated in the certificate was not the same as per Official record of the district (or R.I.) which was Thursday. This is contrary to Article 1, Sec. 2 of the TOR xxxthe Club should have arrived at an agreement during a regular meeting of the Club. Agreements during informal meetings do not constitute a valid expression of a Rotary Club. A Club meeting is a regular meeting of if it is done on the date, time and place as registered with Rotary International. xxxA quorum should be present during the regular meeting. 15.3. An identification document (ID) with NO signature was submitted by the club secretary, contrary to the TOR. (Annex P, Reply) Upon closer examination, the club secretary, Fatima Socorro Sison, submitted a Philippine Passport which do not bear a sample signature (as required by the TOR). In an obvious attempt to circumvent the same proviso, a handwritten signature was superimposed on the photocopy of the document which now rendered the same impossible to authenticatecontrary to Sec. 1. Article III, of the TOR 16. Re: RC Midtown Diliman Basis for Invalidation of Club Resolution. Pursuant to the same Sec. 2.1. of the Guidelines, the Credentials Committee had established from the official records that RC Midtown Diliman had NO subscription to the Philippine Rotary Magazine (PRM), or the Rotarian, at that point, and also had an overdue, unpaid obligation to RI in the amount of USD 571.00. This rendered it not qualified as a functioning club, and thus, its club concurrence could not be deemed or accepted as valid.

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17. Re: RC Philam & RC Global Kalinga Basis for Invalidation of Club Resolution/s. It was rather clear from the Guidelines that only clubs certificates of functioning clubs which have been in existence for at least one (1) year at he beginning of RY 2012-13, will be considered. This proviso is based on Sec. 13.20.9, Concurrences to Challenge- xxxOnly challenges which have been concurred to by at least five (5) other clubs which have been in existence for at least one (1) year as of the beginning of that yearxxx. 17.1. These two (2) clubs have been in existence for less than one (1) year at the beginning of the current RY. Hence, they were either ill-advised, or failed to read the above quoted Guidelines or R.I. By-Laws, since they should not have submitted any concurrence in the first place. 18. There was Simply Not Enough Concurrence to Support a Valid Challenge. Considering the fact that only six (6) clubs were able to submit valid concurrences, which was below the required minimum number of ten (10) or 10% of the total number of clubs (102), it now stands to reason that the challenge resolution of RC Pag-Asa can not be considered valid. Hence, the selection process ended at this point. 18.1. Again, Sec. 13.20.9. Concurrence to Challenge.xxxxxxOnly challenges which have been concurred to by at least five (5) other clubs which have been in existence for at least one (1) year as of the beginning of that year, or 10 percent of the total number of clubs as at the beginning of that year in the district which have been in existence for at least one year as of the beginning of that year, whichever is higher, and only when such resolutions by the club were adopted at a regular meeting in accordance with the club by-laws as determined by the governor shall be considered valid. 19. Under the circumstances, in the clear absence of a valid challenge, it was the duty and responsibility of the undersigned District Governor, under the R.I.By-Laws, to declare the choice of the Nominating Committee, PP Reynaldo Rey David, as the District Governor-Nominee for RY 2015-16. 19.1.This is based on Sec. 13.20.12 of the R.I. By-Laws which state: Where no valid challenging nomination is received, the governor shall declare the candidate of the district nominating committee as governor-nominee. The governor shall notify all clubs in the district within 15 days. 19.2. Based on the foregoing, the district governor has no other recourse, or option but to declare the candidate of the DNC as the DGN. There is no other proceeding, or any other course of action that is required of him. It is

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mandatory on the part of the District Governor to make that declaration based on the same Sec. 13.20.12. 19.3. Contrary to the allegation of the complaint under Par. 2, 2.A, due process was observed through every step, and the declaration made was solely in accordance with Sec.13.20.12. 20. The Report of the Credentials Committee was made readily available to any Rotarian or Club who requested for a copy. (Annex I, Reply) All the clubs which submitted a concurring club certificate were all informed and provided a copy of the Report. There was never any intention or attempt to conceal or hide the Report of the Credentials Committee from anyone. 20.1. On the very same day that the Notice / announcement was made via email, all enquiries were readily answered either via telephone, or email. An email notice was also issued to announce that copies of the Credential Committee Report were readily available, upon request, at the District Office. (Annex K, Reply) 20.2. The undersigned, upon reading an email message from RC Global Kalinga president, Jack Wong, immediately called up the latter to explain why his clubs concurrence could not be considered valid. It was a very amicable conversation. 20.3. Later, on May 9 th, the Credentials Committee issued an email notice (Annex L, Reply) (also attached to complaint as Annex 7), explaining the entire process, and which also stated that the copy of the Report was not emailed together with the announcement because the detailed findings may place some of the concurring clubs in an embarrassing situation, which was also a concern expressed by our committee. 20.4. The complainant and the other concurring clubs failed to appreciate the fact that it was our honest intention not to publicize, or broadcast via email, any matter, particularly the Report of the Credentials Committee, which may cause any club or Rotarian any embarrassment, humiliation, or to put anyone in a negative light. We simply thought it was prudent not to broadcast the contents of the Report to safeguard the privacy and confidentiality of the clubs and Rotarians concerned, and simply make them available to any Rotarian at the District Office. 20.5. Ironically, this was grossly misinterpreted by the complaining clubs and even twisted the facts, making it an issue in this complaint, albeit a

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false one. Thus, the statements in Par. 2.A, 2a.2., 2.a.4.,2.a.5.,2.a.6., and 2.a.6.1.are all false and misleading.

2.a.3,

20.6. Likewise, contrary to the allegation in Par.3.B, the clubs with invalid concurrences were identified through the Report of the Credentials Committee, copies of which were sent to all the clubs concerned, and made available to any interested Rotarian in the district. Hence, there was no abuse of authority, negligence in this matter. 21. All the district officers acted consistent with Rotarys Code of Conduct and the tenets of the 4-Way Test. We have all maintained cordial relations with all Rotarians, from all the Clubs, including the complainants herein. To date, there had been no untoward / violent incidents involving any of the district officers. 22. With due respect, we take exception to complainants sweeping, imaginary accusation and false statement (last two paragraphs of complaint) that: 22.1.CP Gloriosa Valarao has always been a victim of black propaganda perpetuated by a so-called MAFIA in our district. This small group of Rotarians wants to control the district for their own vested interest. They have already lined up as early as now the next Rotarian they will support as candidate for DGN and subsequent candidates in the futurexxxThey have always manipulated the election process.xxxetc. 22.2. Such statement, clearly unsupported by any proof whatsoever, betrays the contempt and hostility of herein complainant, RC Pag-Asa, its club president, and their candidate Gloriosa Valarao toward their very own District 3780, and the undersigned DG. Throughout the entire Rotary year and the selection process, herein complainant RC Pag-asa (some of its members), together with some supporters have resorted to all sorts of name-calling (i.e. mafia), gossip, innuendo and similar tacticsto malign and undermine the leadership of the District, and its leaders. 22.3. If such statements were trueherein complainant should have provided and attached clear and convincing proof. In the absence of such evidence, such statement are worthless, nothing more than a malicious attempt to destroy the reputation of our District 3780an act so unbecoming of a Rotarian! 22.4. Given the kind of (hostile) statements made in this complaint, and all the malicious & baseless accusations of herein complainant, RC Pag-Asa, and their candidate Gloriosa Valarao we submit this to be the best evidence why such candidate and club will never earn the respect, trust
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and confidence of our District 3780. Their shameful actuations and language have no place in Rotary, and they can not be worthy of being considered as Rotarians. 23. Herein complainant, RC Pag-Asa, and its officers should take a good at themselves before passing judgment and hurling accusations on othersas if they are not guilty of any wrongdoing themselves. 23.1. Candidate Gloriosa Valarao, under whose behalf this complaint was filed, is a perennial candidate for the same position. This is her 5 th time to run but has never won the vote of the Nominating Committee. Sadly, she, together with her club & other supporters, have blamed everyone for their repeated defeat except themselves. Her repeated attempts have caused our district more harm than goodcausing deep seated divisions, and intense partisanship. Her seeming obsession for the position has caused her to even undertake unethical acts, in violation of R.I. By-Laws. 23.2. Previously, a report was submitted via email last 24 April 2013, by the undersigned DG Penny Policarpio, to Ms. Joy Walker, Manager, Club & District Support, South Pacific & Philippines Office, a copy of which is herewith attached as Annex R, R-1, R-2, R-3, Reply, attaching therein documents which establish or prove the unethical conduct committed by Gloriosa Valarao and Salvador Viaricontrary to the R.I. By-Law and Code of Policies. 23.3. A separate Report and Complaint against Ms. Valarao will be submitted to the General Secretary, stating therein her serious violationsfor proper action and in order to avoid any repetition of this wrongdoings. Summary and Conclusion 24. In sum, all the foregoing statements have adequately answered all the pertinent issues, questions and allegations raised by the complaint, specifically 24.1. Was the TOR valid and applicable to the subject selection process? -Yes, it is was duly approved and adoptedas certified by DG Jess Cifra & DS Jesse Tanchangco. This is a fact was established and is undisputed. 24.2. Was the Elections Procedure Committee and/or Credentials Committee correct in applying and implementing the provisions of the TOR?

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- Yes, both Committees were correct in relying on the provisions of the TOR, a validly approved document and applicable to govern the conduct of the selection process. 24.3. Was there any specific act committed by the undersigned District Governor and and of the Members of the Elections Procedures Committee which may be considered as irregular, abusive and contrary to the provisions of the TOR, or the published Guidelines on Submission of Concurrence by Clubs? - No, there was no specific action, or acts committed by any member of the same committees that may be considered as irregular , abusive, or not complying with the provisions of the TOR, the Guidelines, or R.I. By-Laws. No specific acts were mentioned in the complaint other than sweeping generalizations, vague accusations which are not even supported by clear & convincing evidenceto establish the truth thereof. - There were NO deviations from the TOR, R.I. By-Laws and policies committed by the Committees involved. 24.4. Was there any factual or lawful bases in the findings reported by the Credentials Committee that the club concurrences (in the form of club certificates) submitted by six (6) of the twelve (12) were Not Valid? - Yes, the Report of the Credentials Committee, stating its evaluation and findings, were duly supported by factual evidencein the form of eye-witness testimony, official records, and verified factsand all consistent with the Guidelines, and the R.I. By-Laws. 24.5. Was the Credentials Committee correct in its evaluation or conclusion? - Yes, the Credentials Committee was correct in its evaluation or conclusions as to the valid and invalid concurrences. No error was established or proven by the complainant. 24.6. Was there any clear and convincing proof or reason to invalidate, reverse, or modify the findings / conclusion of the Credentials Committee? -No, there is no clear and convincing proof or reason to invalidate, reverse, or modify the Report and Decision of the Credentials Committee.

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24.7. Was there any specific proof or evidence submitted to establish that candidate CP Gloriosa Valarao was a victim of black propaganda, or that there is a mafia or a group manipulating the district elections (as contained in the last paragraph of the complaint)? -Sad to say, there was none at all. This kind of malicious, baseless statements / accusations simply reveal the contempt and deep seated hostility of complainant and their candidate toward their own District 3780, and its leadersactuations which are clearly uncalled for and so unbecoming of Rotarians. 24.8. Was there any specific act or actions committed by the undersigned DG that could be interpreted as an abuse of authority, arrogant, and in violation of the 4-Way Test? - What has been stated in this Reply is the whole truth about this matter, and in fairness and with respect to all concerned. Through every step of the process of selection, the undersigned was guided only by the provisions of the TOR, the R.I. By-laws, and the Code of Policies. Every action taken by the undersigned was always consistent with and in accordance with the applicable provision of the TOR, the By-Laws and Code of Policies. - Unfortunately, the entire complaint submitted by RC Pag-asa fails to state any specific actions which can be interpreted as an abuse of authority, or even arrogance, considering that we never even had any personal or face-to-face meetings or conference concerning this matter. - In the end, all the acts of the undersigned DG were simply in compliance with what was required of his Office, under the TOR, the ByLaws and the Code of Policiesall in good faith and to the best of his abilities, under the circumstances prevailing at that time. In view of the foregoing, it is most respectfully requested that the subject election complaint of RC Pag-Asa be immediately DISMISSED, for being baseless, its allegations unsupported by any clear & convincing proof of any violations committed by the undersigned DG, or any of the district officers concerned. Clearly, this complaint is borne out a misunderstanding or misapprehension of the applicable Rulesthe Terms of Reference, the R.I. By-laws and the Code of Policies. After having participated in the process, herein complainant would now turn around and assail the very same rules it had complied with, and accuse the officers concernedonly because the outcome was not favorable to them. Worse, it is motivated by ill-will and a deep seated

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hostility toward the officers of the district designed only to place the district and the undersigned District Governor in a negative light. After a very successful year of significant achievements, our fellow Rotarians of District 3780 would like to simply move on and prepare for the new Rotary year. Yours in Rotary Service,

RUFINO L. POLICARPIO III District Governor, RY 2012-13

With our Conformity: PDG Nemesio Nemie Peralta Chairman, Elections Procedure Committee LG Angel Angel Gahol Chairman, Credentials Committee

PDG Jesus Jessie Tanchangco Vice-Chairman, Credentials Committee

AG Rebecca Becca dela Cruz Member, Credentials Committee

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