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Republic of the Philippines

SUPREME COURT
Manila

SATURNINO C. OCAMPO, TRINIDAD


H. REPUNO, BONIFACIO P. ILAGAN,
MARIA CAROLINA P. ARAULLO, M.D.,
SAMAHAN
NG
EX-DETAINEES
LABAN SA DETENSYON AT ARESTO
(SELDA) represented by ANGELINA
BISUNA,
CARMENCITA
M.
FLORENTINO,
RODOLFO
DEL
ROSARIO,
FELIX
C.
DALISAY,
DANILO M. DELA FUENTE,
Petitioners,

-versus-

G.R. NO.

FOR: CONTEMPT

REAR
ADMIRAL
ERNESTO
C.
ENRIQUEZ (in his capacity as the
Deputy Chief of Staff for Reservist
and Retiree Affairs, Armed Forces of
the Philippines), The Grave Services
Unit
(Philippine
Army)
and
GENERAL RICARDO R. VISAYA (in
his capacity as the Chief of Staff,
Armed Forces of the Philippines),
DEFENSE
SECRETARY
DELFIN
LORENZANA,
and
HEIRS
OF
FERDINAND
E.
MARCOS,
SR.
represented by his surviving spouse
Imelda Romualdez Marcos and
legitimate children Imee, Irene and
Ferdinand Jr.

Respondents.
x------------------------------------------------------------x

PETITION FOR CONTEMPT OF COURT


PETITIONERS,
following:

through

Counsel,

respectfully

state

the

NATURE OF THE CASE


1.
This is a Petition under Rule 71 of the Rules of Court to
cite Respondents for Indirect Contempt for their wanton and wilful
acts which constitute disregard, disrespect and disobedience to the
rules and to the dignity of the Honorable Court.
PARTIES
2.
PETITIONERS and RESPONDENTS (aside from the
legitimate children of the late dictator Ferdinand Edralin Marcos) are
the same parties in G.R. No. 225973, the first case to be filed before
the Honorable Court seeking to enjoin the planned burial of
Ferdinand E. Marcos, Sr. at the Libingan ng mga Bayani.
STATEMENT OF RELEVANT FACTS
3.
On 15 August 2016, Petitioners filed before the Supreme
Court En Banc a Petition for Certiorari and Prohibition with
Application for Temporary Restraining Order and/or Writ of
Preliminary Injunction to stop the planned burial of the late dictator at
the Libingan ng mga Bayani. The case was docketed as G.R. No.
225973.
4.
remedy.

Five other Petitions were filed basically seeking the same

5.
On 23 August 2016, the Honorable Court issued a Status
Quo Ante Order for twenty (20) days prohibiting all parties from
burying the dictator Marcos, Sr. at the Libingan ng mga Bayani.
6.
Oral arguments were held on 31 August 2016 and 07
September 2016.
7.
After the oral arguments, the Honorable Court extended
the Status Quo Ante Order until 18 October 2016 and again until 08
November 2016.

8.
On 08 November 2016, the Honorable Court rendered a
Decision in the said case, the dispositive portion of which reads:
WHEREFORE, PREMISES CONSIDERED, the
petitions are DISMISSED. Necessarily, the Status
Quo Ante Order is hereby LIFTED.
9.
The dispositive portion of the Decision did not indicate
that the same is immediately executory.
10. On 11 November 2016, Petitioners filed with the
Honorable Court an Extremely Urgent Motion to Hold in Abeyance
the Interment of the Late Dictator, Human Rights Violator and
Plunderer Ferdinand Marcos Sr. In the Libingan ng mga Byani
Pending the Resolution of Petitioners Motion for Reconsideration and
the Finality of the Decision. To date, Petitioners are unaware of any
official action on the same.
11. On 13 November 2016, Petitioners Counsel learned that
its office received a copy of the Decision on 11 November 2016.
Hence, under the Rules of Court and the Internal Rules of the
Supreme Court (A.M. No. 10-4-20-SC), Petitioners have fifteen (15)
days from receipt of their copy of the Decision, or until the 26th of
November 2016 within which to move for the reconsideration of the
said Decision.
12. The assailed Supreme Court decision is, therefore, not
yet final and executory as the period of fifteen days provided under
both Rules has not yet elapsed.
13.
At mid-morning of 18 November 2016, information and
reports were running fast that the late dictator, human rights violator
and plunderer is about to be buried at noon of the same date. It was
only late in the morning that the National Capital Regional Police
Offices (NCRPO) Chief Superintendent Oscar Albayalde made an
official announcement confirming such information.
14. At around past 11:30 in the morning, the media reported
that the remains of the late dictator, flown from Laoag, Ilocos Norte,
arrived at the Libingan ng mga Bayan. Burial rites were conducted
shortly thereafter.
15. Considering the initial media blackout, the Filipino people
was kept in the dark as to the actual burial and the rites given to the
late dictator. However, Respondent Imee Marcos posted a same-day-

edit video1 showing that indeed burial rites with full military honors
were held for the late dictator.
16. The other circumstances of the burial which were later
disclosed and the public statements of Respondents can very well be
taken judicial notice of this Honorable Court, including the temporary
news blackout, initial denials, honor guards, 21-gun salute, taps,
flower confetti shower, tight security and elaborate transportation
arrangements, and the pomp and pageantry.
17. These accoutrements necessarily requiring expenditure of
public funds and resources could never be regarded as private and
simple as claimed by Armed Forces of the Philippines spokesperson
Brig. Gen. Restituto Padilla, among others.
CAUSE OF ACTION
THE HASTY, SHADY AND TRICKY BURIAL OF THE REMAINS OF
THE LATE DICTATOR AT THE LIBINGAN NG MGA BAYANI
DURING THE PENDENCY OF THE CASE CONSTITUTES
CONTEMPT OF COURT
18. True to his character proven abundantly even by this
Honorable Court in previous rulings, Marcos, Sr.s burial at the
Libingan ng mga Bayani was made deceitfully and dishonestly
without any moral compunction. When the official announcement and
confimation was made, the nation was in shock and disbelief over
such bizarre scheme.
19. The cunning and brazen disregard and mockery by the
Marcos family and the public Respondents of the legal process is
evident in the manner by which the burial was conducted.
20.

Contempt of court has been defined as:


a willful disregard or disobedience of a public
authority. In its broad sense, contempt is a
disregard of, or disobedience to, the rules or
orders of a legislative or judicial body or an
interruption of its proceedings by disorderly
behavior or insolent language in its presence or
so near thereto as to disturb its proceedings or
to impair the respect due to such a body. In its
restricted and more usual sense, contempt

http://www.rappler.com/nation/152840-marcos-hero-burial-video-same-day-edit
4

comprehends a despising of the authority,


justice, or dignity of a court. The phrase
contempt of court is generic, embracing within
its legal signification a variety of different acts.2
21. Under Section 3, Rule 71 of the Rules of Court, a person
may be held liable for indirect contempt for the following acts:
xxx
(a) Misbehavior of an officer of a court in the
performance of his official duties or in his official
transactions;
(b) Disobedience of or resistance to a lawful writ,
process, order, or judgment of a court, including the
act of a person who, after being dispossessed or
ejected from any real property by the judgment or
process of any court of competent jurisdiction,
enters or attempts or induces another to enter into
or upon such real property, for the purpose of
executing acts of ownership or possession, or in
any manner disturbs the possession given to the
person adjudged to be entitled thereto;
(c) Any abuse of or any unlawful interference with
the processes or proceedings of a court not
constituting direct contempt under section 1 of this
Rule;
(d) Any improper conduct tending, directly or
indirectly, to impede, obstruct, or degrade the
administration of justice;
(e) Assuming to be an attorney or an officer of a
court, and acting as such without authority;
(f) Failure to obey a subpoena duly served;
(g) The rescue, or attempted rescue, of a person or
property in the custody of an officer by virtue of an
order or process of a court held by him.
xxx
Lorenzo Shipping vs Distribution Management Association of the Philippines
G.R. No. 155849 August 31, 2011.
2

22.
Rule 71.

The acts of Respondents plainly fall under Section 3(d) of

23. Public Respondents were well aware of the judicial


process and yet trifled with the same in shameless and utter bad faith
when they obviously connived with the Marcos family in planning the
lightning burial and with impunity consistent with the Marcos
blueprint with stealth and deception to jump the gun on this
Honorable Court, the nation and the world.
24. The hasty, shady and tricky Marcos burial or interment at
the LMNB violates doctrines of law that are not only clearly
established in the Philippine legal system but are also so elementary.
In doing so, the Respondents could not have but acted in evident bad
faith and contempt of this Courts jurisdiction.
25. Further, for this Court to let these violations pass is to
once again exempt the Respondents from culpability and thereby
entrench in the Philippines that certified telltale of a failed State an
oligarchic (because the rule of law is once dictated by the politial and
economic oligarchs), transactional (because the burial was meant to
accommodate the Marcos family for past favors) and conflicted
(because the hasty and precipitate burial has led to inconsistencies in
the jurisprudence of this Court if only to patronize the Marcos family
and pander to their whimsical exercise of their resurging powers)
rule of law.
26. First, the Respondents flouted the doctrine of law that the
period to file a motion for reconsideration stayed the immediate
execution of this Courts Decision in the present case.
27. It should well be noted that the Decision in the main case
has yet to become final and executory. More specially so that under
the circumstances, in the case of the instant Petitioners, they have
until the 26th of November 2016 within which to file a Motion for
Reconsideration of the aforesaid Decision, a legal remedy that they
formally manifested to do so, in abundante cautela, in their
Extremely Urgent Motion to Hold in Abeyance of 11 November
2016 .
28. It has been established that a judgment becomes final
and executory by operation of law.
Finality of judgment
becomes a fact upon the lapse of the reglementary period to
appeal if no appeal is perfected.3

City of Manila vs Court of Appeals G.R. No. 100626 November 29, 1991.
6

29. Tung Ho Steel Enterprises Corporation vs Ting Guan


Trading Corporation4 is categorical:
Significantly, the rule that a timely motion for
reconsideration stays the execution of the
assailed judgment is in accordance with Rule 51,
Section 10 (Rules governing the CA proceedings)
which provides that "entry of judgments may only be
had if there is no appeal or motion for
reconsideration timely filed. The date when the
judgment or final resolution becomes executory
shall be deemed as the date of its entry."
Incidentally, this procedure also governs before
Supreme Court proceedings. Following these
rules, therefore, the pendency of Tung Ho's MR with
the CA made the entry of the judgment of the Court
in the Ting Guan petition premature and
inefficacious for not being final and executory.5
(emphasis added)
30. In Investments, Inc. vs Court of Appeals,6 the
Honorable Court declared that,
a "final judgment" in the sense just described
becomes final "upon expiration of the period to
appeal therefrom if no appeal has been duly
perfected" or, an appeal therefrom having been
taken, the judgment of the appellate tribunal in
turn becomes final and the records of the case
are returned to the Court of origin. The "final"
judgment is then correctly categorized as a
"final and executory judgment" in respect to
which, as the law explicitly provides, "execution
G.R. No. 182153 April 7, 2014.
See also Neeland v. Villanueva Jr. et al., A.M. No. P-99-1316, August 31, 2001.
First, even under the extant rule on the matter, he is clearly entitled to such
demand. For one, the immediate execution of the order of dismissal was
premature. There being no rule to the contrary, he was entitled to file a
motion for reconsideration, and corollarily, the suspension of the
enforcement of the order of dismissal pending resolution of his motion. For
another, the physical impossibility of effecting reinstatement for the period of
employment that was long gone by reasons not attributable to him entitles him to
restitution in the form of back salaries and other economic benefits. For,
otherwise, he would find himself unfortunately punished twice for an offense that
is properly and singularly penalized only by a fine. (emphasis added)
4
5

147 SCRA 334.


7

shall issue as a matter of right." It bears


stressing that only a final judgment or order, i.e.,
"a judgment or order that finally dispose of the
action of proceeding" can become final and
executory.
31. Section 1 Rule 15 of the Rules of Court is clear: [a]
decision or resolution of the Court may be deemed final after the
lapse of fifteen days from receipt by the parties of a copy of the
same xxx.
32. Section 1 Rule 15 as cited above should be read in
relation to Section 2 of the same Rule on Motions for Reconsideration.
Clearly, the 15-day reglementary period before the finality is for the
purpose of giving the parties to the litigation a chance to file a Motion
for Reconsideration.
33. Moreover, Rule 16 of the Internal Rules of the Supreme
Court provides that the Judicial Records Office shall enter
judgment within fifteen days from the expiration of the fifteenday reglementary period for filing a motion for reconsideration7
and that [t]he date of entry of judgment shall be the date such
decision or resolution becomes executory unless the Court
directs its immediate execution.8 (Emphases supplied.)
34. Even more categorical and to the point is Section 2 of the
said Internal Rules, to wit:
Section 2. Motion for reconsideration. A motion for
reconsideration filed within the fifteen-day period from receipt of
a copy of the decision or resolution shall stay the execution of
such decision or resolution unless, for good reasons shown, the
Court directs otherwise.
35. In fact, this Court once expressed its displeasure when a
NON-final and executory Decision was prematurely executed by an
inferior body as this Decision is still subject to its jurisdiction and
discretion and called it as contempt of court:
One final word. It was bad enough that the Court of
Appeals erred in ruling that the lease contract must
be judicially rescinded before respondent MMB, Inc.
may be evicted from the premises. It was worse that
7
8

Section 3, Rule 16, AM. No. 10-4-20-SC.


Section 1, id.
8

the Court of Appeals immediately enforced its


decision pending appeal The assertion that "it is
of public knowledge" that the Supreme Court is
clogged with cases that may take time to decide
mocks the integrity and derides the competence
of this Court. The remark erodes and
undermines the people's trust and confidence in
the judiciary, ironically coming from one of its
subordinate courts. This is an assault on the
Supreme Court that borders on contempt; we
cannot permit such attack to pass without sanction.
This we cannot countenance. Litigants, lawyers and
judges share the responsibility of unclogging the
dockets of the judiciary. No lower court justice or
judge may deride, chastise or chide the
Supreme Court even speaking "with due respect"
in his ponencia. In fact, it is the duty of lower courts
to obey the decisions of the Supreme Court and
render obeisance to its status as the apex of the
hierarchy of courts. "A becoming modesty of inferior
courts demands conscious realization of the
position that they occupy in the interrelation and
operation of the integrated judicial system of the
nation." "There is only one Supreme Court from
whose decision all other courts should take their
bearings" so spoke Justice J. B. L. Reyes. We
echo this golden nugget of advice. x x x By the
mere fact of the filing of the petition, the finality
of the Court of Appeals' decision was stayed,
and there could be no entry of judgment therein,
and, hence, no premature execution could be
had. (emphasis added)9
36. The point is, if this Court can demand other courts
compliance with this doctrine of law,10 it should also demand its own
Heirs of Reyes et al. v. Court of Appeals et al., G.R. Nos. 135180-81 & 13542526, August 16, 2000.
10
JP Latex Technology Inc. v. Ballons Granger Baloons Inc. et al., G.R. No.
177121, March 16, 2009. In the instant case, petitioner filed a motion for
reconsideration of the RTC decision. The records of the case show that the
motion had not been acted upon by the RTC before it ruled on the motion for
execution "pending appeal". That being the case, the pendency of the motion
for reconsideration has prevented the period to appeal from even
commencing. The period within which a party may move for an execution
pending appeal of the trial court's decision has not yet also started. Where
there is a pending motion for reconsideration of the RTC decision, an order
execution pending appeal is improper and premature. The pendency of the
motion for reconsideration legally precludes execution of the RTC decision
9

compliance with this doctrine.


37. Hence, it is very clear, that unless the Honorable Court
directs its immediate execution, a decision or resolution of the
Honorable Court shall only be executory upon the date of its
entry in the book of judgments.
38. The hasty, shady and tricky burial of the dictator Marcos,
Sr. at the Libingan ng mga Bayani despite the existence of the right,
under the Rules, of the Petitioners to move for the reconsideration of
the Decision within 15 days from notice obstructs and degrades the
Honorable Court and is contemptuous in itself. Such premeditated
contumacious acts of the Respondents undermined the authority of
the Court, emasculated its powers, attempted to pre-empt its
judgment, and mocked well-entrenched rules of procedure in violation
of due process and of public interest and ultimately justice.
39. The fact that the Status Quo Ante Order has been lifted
does not give the Respondents the right to automatically or
immediately bury the remains of Marcos, Sr. at the Libingan without

because the motion serves as the movant's vehicle to point out the
findings and conclusions of the decision which, in his view, are not
supported by law or the evidence and, therefore, gives the trial judge the
occasion to reverse himself. In the event that the trial judge finds the motion for
reconsideration meritorious, he can of course reverse the decision. In the
absence of an appeal from the decision, as the motion for reconsideration is
still unresolved, the execution ordered by the RTC cannot be properly
considered as execution pending appeal. All references to the assailed order
as an order of execution "pending appeal" are mislabeled. The need to resolve
first, or better still deny, petitioner's motion for reconsideration before the
RTC could grant the discretionary execution becomes more imperative in
the light of the rule that executions pending appeal are frowned upon.
Without preempting the resolution of petitioner's motion for
reconsideration one way or the other, a perusal thereof shows that
petitioner had raised questions and issues which were not thoroughly
discussed and passed upon in the RTC decision. The RTC should have
resolved these issues first before allowing the discretionary execution of
its judgment if only to preclude any speculation that the order of execution
"pending appeal" was issued in haste. Said failure constitutes grave abuse of
discretion amounting to lack or excess of jurisdiction on the part of the RTC judge.
x x x The good reasons allowing execution pending appeal must constitute
superior circumstances demanding urgency that will outweigh the injuries or
damages to the adverse party if the decision is reversed. (emphasis added);
Rizal Security and Protective Services v. Maraan, G.R. No. 124915, February 18,
2008. Without receipt by the petitioners of the notice and copy of the Order
dated 24 January 1996, the same has not yet become final and executory and
the Writ of Execution issued pursuant thereto on 12 March 1996 was
premature and without legal basis. This renders the Writ of Execution fatally
defective and, thus, null. (emphasis added)
10

the decision having attained finality.11 It is our humble but firm


position that the lifting of the Status Quo Ante Order ordinarily
issued pending the issuance of a Decision or Resolution does not
make the subject Decision ipso facto nor ipso jure final and executory.
40.

In Lee vs CA,12 the Honorable Court held that


Furthermore, notwithstanding the stand of both
parties, the fact remains that the Decision of the
Court of Appeals annulling the grant of preliminary
injunction in favor of petitioners has not yet
become final on 14 December 2000. In fact, such
Decision has not yet become final and
executory even on the very date of this Decision,
in view of petitioners appeal with us under Rule 45
of the 1997 Rules of Civil Procedure. The
preliminary injunction, therefore, issued by the
trial court remains valid until the Decision of the
Court of Appeals annulling the same attains
finality, and violation thereof constitutes indirect
contempt which, however, requires either a formal
charge or a verified petition.

41. The seemingly contrary rulings in Pacific Banking


Corporation Employees Organization v. Court of Appeals et al., G.R.
No. 109373, October 13, 1995, and Kida et al. v. Senate of the
Philippines et al., G.R. No. 196271, February 28, 2012, do not apply
to the instant case. The precipitate and hasty decision to bury the
dictator Marcos in the LNMB was not President Dutertes decision
per se as the decisions involved in the aforementioned cases. The
Respondents have absolved the President of this event. Just for
purposes of seeking accountability from the Respondents and for this
purpose alone, let President Duterte and his men live in their own
world that they knew nothing of this event and did not sanction it, and
having been a non-party to it, obviously, Pacific Banking Corporation
Employees Organization v. Court of Appeals et al., supra, and Kida et
al. v. Senate of the Philippines et al., supra, are irrelevant to the case
at bar.
42. Second, the Respondents violated what this Court has
long been teaching law students to commit to memory and heart: No
one may be permitted to take the law into his own hands. No one,
By parity of reasoning, pls see Datu Sukarno Samad vs. Comelec et. al. G.R.
No. 107854 where the Court held that the lifting of the TRO is part of the
decision and like the rest thereof could be the subject of a motion for
reconsideration.
12
G.R. No. 147191 July 27, 2006.
11

11

much less the party immediately concerned, should have the final say
on the validity or lack of it of one's course of conduct. Centuries of
reliance on the judicial process repel such a notion.13 In the case at
bar, the Marcos family in connivance with the States security forces
the Philippine National Police and the Armed Forces of the
Philippines took the law into their own hands by judging for and by
themselves whether the former President as Dictator and Butcher is
worthy of burial at the LNMB. As a result, the Respondents shortcircuited the process and disregarded and disrespected the pending
special civil actions in this Court.
43. Third, the Respondents violated the doctrine of law
against forum shopping. While the special civil actions are still
pending in this Court because the period to file a motion for
reconsideration of this Courts assailed Decision has not yet lapsed
the Marcos family connived with the State security forces to topple
and subvert the rule of law in this country. In other words, even as a
remedy is still extant at this Court, the Marcos family resorted to other
venues and other remedies, both administrative and executive in
character, to obtain the ultimate result they want to achieve. This is
textual and purposive forum-shopping.
44. As explained in Grace Park International Corporation
vs Eastwest Banking Corporation,14 there is forum-shopping
when party asks different courts and/or administrative agencies to
rule on the same or related causes and/or grant the same or
substantially the same reliefs, in the process creating the possibility of
conflicting decisions being rendered by the different fora upon the
same issues.15 Here, the Respondents resorted to both this Court
and the administrative agencies in charge of the LMNB, and on the
basis of the textual reading of the definition of forum-shopping, there
is forum-shopping.
45. Purposively,
as
mentioned
in
Disini
vs
16
Sandiganbayan, there is forum-shopping when there is trifling with
the courts and their processes and the possibility of conflicting
decisions being rendered by two courts and opening the system to
the possibility of manipulation.
46. In the case at bar, by conniving with the State security
forces and the civilian administrators of the LNMB, while the Petitions
on the Marcos burial in the LNMB are still pending with this Court, the
Marcos family and their cohorts, herein Public Respondents as well
Philippine Association of Free Labor Unions v. Salvador et al., G.R. No. L29471, September 28, 1968.
14
G.R. No. 210606 July 27, 2016.
15
Emphasis added.
16
G.R. No. 175730 July 5, 2010.
13

12

as all those who attended the sordid event -- unfairly doubled their
chances of securing as in fact they have secured their goal of burying
Mr. Marcos in the LNMB. Indeed, [t] his misdeed amounts to a
wagering on the result of the Respondents twin devious strategies,
and shows not only their lack of faith in this Court in its evenhanded
administration of law but also their expression of disrespect if not
ridicule for our judicial process and orderly procedure.17
47. If these rules and precedents are faithfully observed in all
other cases in judicial and even quasi-judicial bodies, then with
greater reason should they be respected in a case of such
transcendental importance and of far-reaching repercussions such as
this. Otherwise, it will send the confusing and perilous signal that
henceforth all decisions or judgments that are not yet final and
executory can now be immediately executed and pre-empted
peremptorily by the unilateral act of the winning party even without
waiting for the mandatory period to file a motion for reconsideration or
appeal, as the case may be.
48. The Marcoses have thus violated established and
elementary doctrines of law in the process of employing
contemptuous tactics bordering on insolence.
49. Ironically, even this Court was also a victim of the Marcos
dictatorship during Martial Law. Hence, the Honorable Court Itself
stood its ground in the case of Galman vs Sandiganbayan18 where
It invoked Its institutional integrity as a court of law, justice and equity,
hence:
The Supreme Court cannot permit such a sham
trial and verdict and travesty of justice to stand
unrectified. The courts of the land under its
aegis are courts of law and justice and equity.
They would have no reason to exist if they were
allowed to be used as mere tools of injustice,
deception and duplicity to subvert and suppress
the truth, instead of repositories of judicial
power whose judges are sworn and committed
to render impartial justice to all alike who seek
the enforcement or protection of a right or the
prevention or redress of a wrong, without fear or
favor and removed from the pressures of
politics and prejudice. More so, in the case at
bar where the people and the world are entitled
17
18

Disini v. Sandiganbayan et al., supra.


G.R. No. 72670 September 12, 1986.
13

to know the truth, and the integrity of our


judicial system is at stake.
50. Cunning is such a subtle adjective that describes the
manner by which Ferdinand E. Marcos, Sr. the Dictator was buried
last 18 November 2016. The penalties under the Rules of Court for
contempt is not and will never be enough to pay for the grave
injustice this dastardly and cowardly act has caused to the Filipino
people and history.
51. The Respondents may have successfully buried
Ferdinand E. Marcos, Sr. at the Libingan ng mga Bayani for
the meantime, but the tyrant can never rest in peace. For at
six feet under and even deeper, the ground will move, shake
and rattle with the indignant cry of the Filipino people, with
the words that will exorcise whatever is interred in there and
forever immortalize his character: Marcos, Hitler, Diktador,
Tuta!

PRAYER
WHEREFORE, premises considered, it is respectfully prayed of
the Honorable Court that the instant Petition be GRANTED and that
the Honorable Court:
(1)find the Respondents GUILTY of indirect contempt of court;
(2) impose a FINE and require the RESTITUTION of all public
funds used in the burial; and
(3) DETAIN the Respondents until they have satisfactorily
cleansed themselves of the contemptuous act or until such
further orders of the Court.
Other reliefs, just and equitable, are likewise prayed for, without
prejudice to the prayers Petitioners will ask in their Motion for
Reconsideration in G.R. No. 225973 .
RESPECTFULLY SUBMITTED, 21 November 2016, Quezon
City for the City of Manila.

14

NATIONAL UNION OF PEOPLES LAWYERS (NUPL)


Counsel for the Petitioners
3/F Erythrina Building
No. 1 Matatag cor. Maaralin Sts., Central District, Quezon City
Telefax No. (632) 920 6660
Email: nupl2007@gmail.com
By

EDRE U. OLALIA
IBP No.1026436-1/25/16-RSM
PTR No. 2353568C- 1/21/16- Quezon City
Roll of Attorneys No. 36971
MCLE Compliance No. V-0019457 - 04/22/2016

JULIAN F. OLIVA, JR.


IBP No.1026438-1/25/16- RSM
PTR No. 2353570C- 1/21/16- Quezon City
Roll of Attorneys No. 35870
MCLE Compliance No. V-0019459 04/22/2016

EPHRAIM B. CORTEZ
IBP No. 1026437 - 1/25/16 Isabela
PTR No. 2353569C - 1/21/16- Quezon City
Roll of Attorneys No. 41366
MCLE Compliance No. V-0019328 - 04/22/2016

MINERVA F. LOPEZ
IBP LR No. 011325 - 01/04/13- Pangasinan
PTR No. 2131515 01/04/16 - Quezon City
Roll of Attorneys No. 60637
MCLE Compliance No. V -0016666 - 04/4/16

15

MARIA AGATHA A. MIJARES


IBP No. 1024061 1/11/16 Quezon City
PTR No. 2354842 1/25/16 Quezon City
Roll of Attorneys No. 61705
MCLE Comapliance No. V-0016634 4/4/16

JOSALEE S. DEINLA
IBP No.1026439-1/25/16/ Quezon City
PTR No. 2353571C- 1/21/16- Quezon City
Roll of Attorneys No. 64967
MCLE Compliance No. V-0019343 - 04/22/2016

ODINA E. BATNAG
PRT No. 2323687/Jan. 18, 2016-Quezon City
IBP No. 1027072 I 1 Feb 2016 I Baguio-Benguet
Roll of Attorneys No. 64286
MCLE Compliance No. V-0011885 11/11/2015

FRANK LLOYD B. TIONGSON


IBP No. 1027373 02/04/16 - Quezon City
PTR No. 2242493C 01/12/16 Quzon City
Roll of Attorneys No. 64966
MCLE Compliance No. V-0021956 / 06-07-16

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Copy furnished:
OFFICE OF THE SOLICITOR GENERAL
134 Amorsolo St.,
Salcedo Village, Makati City
REAR ADMIRAL ERNESTO C. ENRIQUEZ
Deputy Chief of Staff for Reservist and Retiree Affairs
Armed Forces of the Philippines Reserve Command
Camp Aguinaldo, Quezon City
GENERAL RICARDO R. VISAYA
AFP Chief of Staff
Camp Aguinaldo
Quezon City
HON. DELFIN N. LORENZANA
Secretary of National Defense
Camp Aguinaldo
Quezon City
REP. IMELDA R. MARCOS
Room218 North Wing
House of Representatives
IBP Road, Quezon City

EXPLANATION
Copies of this Petition were sent to the parties through registered mail
due to time and personnel constraints.
MINERVA F. LOPEZ

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