SEN. ANTONIO “SONNY” F. TRILLANES IV, Petitioner, -versus- HON. SALVADOR c MEDIALDEA, in his capacity es Executive Secretary, HON. DELFIN N. LORENZANA, in his capacity as Secretary of National Defense, HON. EDUARDO M. ANO, in his capacity as Secretary of Interior and Local Government, HON. MENARDO I. GUEVARRA, in his capacity as Secretary of Justice, GEN. CARLITO G, GALVEZ, JR., in his capacity as Chief of Staff, Armed Forces of the Philippines, P/Dir. Gen. OSCAR D. ALBAYALDE, in his capacity as Chief of the Philippine National Police and all persons acting for and in their behalf and/or under their direction, Respondents. REPUBLIC OF THE PHILIPPINES SUPREME COURT MANILA 241494 SP CASE NO. FOR: CERTIORARI, PROHI- BITION AND INJUNCTION WITH APPLICATION FOR THE ISSUANCE OF A WRIT OF PRELIMINARY INJUNC- TION AND/OR TEMPORARY RESTRAINING ORDER (TRO). PETITION FOR CERTIORARI, PROHIBITION AND INJUNCTION (WITH APPLICATION FOR THE ISSUANCE OF A WRIT OF PRELIMINARY INJUNCTION AND/OR TEMPORARY RESTRAINING ORDER] MRA RESTRAINING ORDER] _ PETITIONER SEN. ANTONIO “SONNY” F. TRILLANES Iv, by and through the under counsel, unto the Honorable Supreme Court most respectfully: STATES -i. NATURE AND BASIS OF THE PETITION 1.1 The instant case is Petition for Certiorari, Prohibition and Injunction, filed under Article VII, Section 1 of the 1987 Constitution, which expressly provides: “Section 1. Judicial power shall be vested in one Supreme Court and in such other courts as may be established by law. “Judicial power includes the duty of Uf the courts of justice to sei a controversies involving rights which are legally demandable and enforceable, and to_ determine whether or not there has been _a_grave abuse of discretion amountini to_lack or excess of jurisdiction on the part of any branch or instrumentality of Government.” [Emphasis] 1.2 Petitioner most respectfully invokes the jurisdiction of the Honorable Supreme Court, to restrain, prohibit and/or nullify the act of the Executive Department, acting through the Respondents named herein, to whimsically and arbitrarily revoke the amnesty granted to the Petitioner under PROCLAMATION NO. 75, series of 2010, signed by former President HON. BENIGNO S. AQUINO III as concurred by the CONGRESS OF THE PHILIPPINES through CONCURRENT RESOLUTION NO. 4, and to arbitrarily, illegally and whimsically arrest the Petitioner sans any warrant and/or any lawful basis, in gross and utter violation of the Constitution, wren all of the previous cases filed against Petitioner have been dismissed already by the respective courts where the same were Previously pending. 1.3 Petitioner likewise most respectfully urgently applies with the Honorable Court and prays for the immediate issuance of the provisional remedies of Writ of Preliminary Injunction and/or Temporary Restraining Order (TRO) in the case, to restrain, enjoin and/or prevent the Respondents, and all other Persons acting in their behalf and/or under their orders, from implementing the arbitrary, whimsical and capricious order of arresting the Petitioner contained in PROCLAMATION NO. 527, SERIES OF 2018, without any warrant and/or any fending cases against him, as will be discussed below.2. PETITIONER MOST RESPECTFULLY SUBMITS THAT DIRECT RECOURSE TO THE HONORABLE SUPREME COURT UNDER THE CIRCUMSTANCES IS JUSTIFIED BECAUSE: A. THE CASE INVOLVES GENUINE ISSUES OF CONSTITUTIONA- LITY OF THE ACTIONS OF THE EXECUTIVE DEPARMENT THAT MUST BE ADDRESSED AT THE MOST IMMEDIATE TIME; B. THE INSTANT CASE APPEARS TO BE A VERY NOVEL CASE OF FIRST IMPRESSION; AND Cc. THE ISSUES OF CONSTITU- TIONALITY RAISED IN THE CASE ARE CLEARLY BETTER DECIDED BY THE HONORABLE SUPREME COURT. 2.1 Petitioner has been compelled to most respectfully invoke the Honorable Supreme Court's role to interpret the Constitution and to act in order to protect constitutional rights of the Petitioner, as the same becomes very exigent and/or important, as will be shown below. 2.2 As of the filing of this Petition, Petitioner has been compelled and constrained to stéy at the Senate Building since 04 September 2018 to prevent his illegal arrest by scores, if not hundreds, of policemen and soldiers sent by the Respondents to arrest and take him into custody despite of the fact that there is no lawful warrant for his arrest and no lawful cause or basis for his arrest. 2.3 To be sure, Petitioner is not unaware of the doctrine of hierarchy of courts. However, as held by the Supreme Court in Roque v. COMELEC (2009), the doctrine of hierarchy of courts is not an iron-clad rule, eee * Roque, Jr., et al. v. COMELEC, et al., 615 Phil. 129, 201 (2009) [Per J. Velasco, Jr., En Banc].2.4 As clearly stated in a number of cases, the Honorable Supreme Court has "full discretionary power to take cognizance and assume jurisdiction [over] special civil actions for certiorari... filed directly with it for exceptionally ompelling reasons? or if warranted by je na of thi issues clearly and specifically raised in the petition." 2.5 As specifically provided below, the Honorable Supreme Court has provided specific exceptions to the doctrine of hierarchy of courts, thus: [Dlirect_resort_to this court is allowed when there are genuine issues of constitutionality that must be addressed at the most immediate time. A direct resort to this court includes availing of the remedies of certiorari and prohibition to assail the constitutionality of actions of both legislative and executive branches of the government.4 [Emphasis supplied] 2.6 Petitioner most respectfully submits that the issues of Constitutionality being raised in this petition, as well as the urgency of the need of addressing the same because of the imminent and threatened violation of the constitutional rights of the Petitioner, would qualify as exceptionally compelling reasons which would justify direct resort to the Honorable Supreme Court. 2.7 Among others, the instant Petition raises a genuine issue of constitutionality, Particularly on whether or not the President, acting on its own, can unilaterally revoke the amnesty granted to the Petitioner with the concurrence of the members of both houses of Congress. 2.8 Another constitutional issue raised in the Petition is whether or not the President can lawfully issue an order to arrest a civilian like Petitioner despite o° the fact the: there appears to be ?ld., citing Chavez v. National Housing Authority, 557 Phil, 29, 721 1107) (Per J. Velasco, Jr., En Banc]. * Id. at 201, citing Cabarles v, Maceda, $45 Phil. 210, 224 (2007) [Per |. Quisumbing, Second Division}. * See Aquino Ill v. COMELEC,G.R, No, 189793, April 7, 2010, 617 SCRA 623, 637-638 [Per J. Perez, En Banc]; Magallona v. Ermita, G.R, No. 137167, August 16, 2011, 655 SCRA 476, 487- 488 [Per J. Carpio, En Banc].no lawful basis and/or no pending cases which would justify such arrest. 2.9 Yet another constitutional issue raised in this case is whether or not PROCLAMATION NO. 527, SERIES OF 2018, which specifically names and mentioned Petitioner as the only person affected thereby, violates the “due process” and “equal protection” clauses of the Constitution. 2.10 Apart from the fact that the instant case involves numerous genuine constitutional issues, the same likewise involves a very novel legal issues never before ruled upon by the Courts. As such, Petitioner submits that it qualifies as a case of first impression warranting direct resort to the Honorable Supreme Court. 2.11 As held by this Honorable Court in a number of cases: [Clases of first impression® warrant a_direct resort to this court. In cases of first_impression, no jurisprudence yet exists that will quide the lower courts on is matter, In Government of United fates vy. Purganan.§ this court _ too! cognizance of the case as a matter of first impression that may guide the lower courts: “In the interest of justice and to settle once and for all the important issue of bail in extradition proceedings, we deem it best to take cognizance of the present case. Such proceedings constitute _a matter of first impression over which there is, as yet, no local jurisprudence to _quide__ lower courts,"” [Emphasis supplied] 2.12 The questions raised by the Petitioner in this case are question which the Honorable Supreme Court has yet to provide substantial answers to, through jurisprudence. Thus, it is most °See Soriano v. Laguardia, 605 Phil, 43, 99 (20S) [Per J, Velasco, Jr., En Banc]; See also Mallion v. Alcantara, 536 Phil, 1049, 1053 (2006) (Per J. Azcuna, Second Division]. § 438 Phil. 417 (2002) [Per J. Panganiban, En Banc]. 7 Id. at 439.respectfully submitted that direct resort to this court should be allowed. 2.13 Finally, Petitioner submits that the constitutional issues raised here are better decided by the Honorable Supreme Court rather than the lower courts. In the case of Drilon v. Lim, this court held that: ... it will be prudent for such courts, if only out of a becoming modesty, to defer to the higher judgment of _this Court _in the ideration_of its validity, which is better determined after a thorough deliberation by a collegiate body and with the concurrence of the majority of those who participated in its discussion.® 3. THE PARTIES 3.1 Petitioner ANTONIO “SONNY” F. TRILLANES IV is of legal age, Filipino, married. He is currently an elected Senator of the Republic, with office address at Room 519, Senate Building, GSIS Financial Center, Roxas Boulevard, Pasay City, where he may be served with the processes of :his Honorable Court. 3.2 Respondent HON. SALVADOR C. MEDIALDEA (Respondent "HON. MEDIALDEA” hereinafter) is of legal age and a Filipino. He is being sued in his official capacity as the incumbent Executive Secretary of the Executive Department and may be served with summons and other legal processes through the Office of the Executive Secretary, Malacafiang Palace, Manila. 3.3 Respondent HON. DELFIN N. LORENZANA (Respondent "HON. LORENZANA” hereinafter) is of legal age anda Filipino. He is being sued in his official capacity as the Secretary of National Defense, and may be served with summons and other legal processes through his Office at the Department of National Defense (DND), Camp Emilio Aguinaldo, Quezon City. 3.4 Respondent HON. EDUARDO M. ANO (Respondent “HON, ANO” hereinafter) is of legal age and Filipino. He is being sued in his official capacity as the Secretary of the Department of Interior and Local Government (DILG), and may be served with 81d, at 140; Emphasis supplied.summons and other legal processes through his Office at the DILG Napolcom Center, EDSA cor, Quezon Avenue, Quezon City. 3.5 Respondent HON. MENARDO 1. GUEVARRA (Respondent "HON, GUEVARRA” hereinafter) is of legal age and Filipino, He is being sued in his official capacity as the Secretary of the Department of Justice (DOJ), and may be served with summons and other legal processes through his Office at the Department of Justice, DOJ Compound, Padre Faura, Manila. 3.6 Respondent GEN. CARLITO G. GALVEZ, JR. (Respondent "GEN. GALVEZ” hereinafter) is of legal age and Filipino. He is being sued in his official capacity as the Chief of Staff, Armed Forces of the Philippines (AFP), and may be served with summons and other legal processes through his Office at the General Headquarters, Armed Forces of the Philippines, Camp Emilio Aguinaldo, Quezon City. 3.7 Respondent P/DIR. GEN. OSCAR ALBAYALDE (Respondent "P/DIR. GEN. ALBAYALDE” hereinafter) s of legal age and Filipino. He is being sued in his official Capacity as the Chief of the Philippine National Police (PNP), and may be served with summons and other legal processes through his Office at the PNP Headquarters, Camp Crame, Quezon City; and - 3.8 Respondent P/DIR. ROEL B. OBUSAN (Respondent "P/DIR. OBUSAN” hereinafter) is of legal age and Filipino. He is being sued in his official capacity as the Chief of the Criminal Investigation and Detection Group (CIDG), and may be served with summons and other legal processes through his Office at the CIDG National Headquarters, Camp Crame, Quezon City. 4. ANTECEDENT FACTS 4.1 On 24 November 2010, then President HON. BENIGNO S. AQUINO III, issued PROCLAMATION NO. 75, SERIES OF 2010, the title of which reads as follows, to wit: “PROCLAMATION NO.75” “GRANTING AMNESTY TO ACTIVE AND FORMER PERSONNEL OF THE ARMED FORCES OF THE PHILIPPINES, PHILIPPINE NATIONAL POLICE AND THEIR SUPPORTERS WHO MAYHAVE COMMITTED CRIMES PUNISHABLE UNDER THE REVISED PENAL CODE, THE ARTICLES OF WAR AND OTHER LAWS IN CONNECTION WITH THE OAKWOOD MUTINY, THE MARINES STAND-OFF AND THE PENINSULA MANILA HOTEL INCIDENT.” A copy of PROCLAMATION NO. 75, SERIES OF 2010, as officially published in the Official Gazette, is hereto appended and made an integral part hereof as ANNEX “A”. 4.2 As can be seen from the text of the said presidential proclamation, the same intended to grant amnesty to all active and former personnel of AFP and PNP as well as their supporters who have or may have committed crimes punishable under the Revised Penal Code, the Articles of War or other laws in connection with, in relation or incident to the July 27, 2003 Oakwood Mutiny, the February 2006 Marines Stand-Off and the November 29, 2007 Peninsula Manila Hotel incident who will apply therefore®. 4.3 On the basis of the said proclamation, the CONGRESS OF THE PHILIPPINES adopted CONCURRENT RESOLUTION NO. 4, the caption of which reads: “CONCURRENT RESOLUTION NO. 4” “CONCURRENT RESOLUTION CONCURRING WITH PROCLAMATION NO. 75 OF THE PRESIDENT OF THE REPUBLIC OF THE PHILIPPINES DATED 24 NOVEMBER 2010 ENTITLED: ‘GRANTING AMNESTY TO ACTIVE AND FORMER PERSONNEL OF THE ARMED FORCES OF THE PHILIPPINES, PHILIPPINE NATIONAL POLICE AND THEIR SUPPORTERS WHO MAY HAVE COMMITTED CRIMES PUNISHABLE UNDER THE REVISED PENAL CODE, THE ARTICLES OF WAR AND OTHER LAWS IN CONNECTION WITH THE OAKWOOD MUTINY, THE MARINES STAND-OFF AND THE PENINSULA MANILA HOTEL INCIDENT.” 4.4 Through the said CONCURRENT RESOLUTION, the Majority of the members of boti houses of Congress expressed * See: Section 1 (Grant of Amnesty), Proclamaticn No. 75, series of 2010, ANNEX “A” hereof.their consent and/or concurrent for PROCLAMATION NO. 75, series of 2010, of Pres, Aquino. The same was adopted by the House of Representatives and the Senate on December 13, 2010 and December 14, 2010, respectively. A duly certified true copy of the said CONCURRENT RESOLUTION NO. 4 is hereto appended and made an integral part hereof as ANNEX "B”, 4.5 On the basis of the said PROCLAMATION NO. 75, SERIES OF 2010, as concurred in by Congress, Petitioner applied with the Ad Hoc Committee created by she DND for the said purpose using the forms prescribed by the said Committee. Petitioner went to the Office of the Ad Hoc Committee at the DND in Quezon City for this purpose on 05 January 2011, where he filed his application and swore to it before the administering officer of the Ad Hoc Committee in accordance with the prescribed rules. Said event was recorded for posterity by members of the media covering the Senate and Defense Beat. 4.6 Enclosed for the ready reference of the Honorable Court is the CD containing video footages of the said event, as recorded and aired by DZRH News on 06 January 2011, ANNEX “C”, and as recorded and aired by TV 5 NEWS on 06 January 2011, ANNEX “¢-1” hereof. 4.7 Likewise enclosed for the ready reference of the Honorable Court is the printed copy of the article published on 05 January 2011 by GMA News Online rendering a full account of the event, ANNEX “D” hereof. 4.8 In view of the submission by the Petitioner of his application for amnesty duly suascribed before the administering officer of the Committee, his personal appearance before the Ad Hoc Committee of the DND and compliance with all of the requirements under PROCLAMATION NO. 75, SERIES OF 2010 and its implementing rules, the Ad Hoc Committee of the DND recommended the approval of his amnesty application. 4.9 Hence, on 21 January 2011, a CERTIFICATE OF AMNESTY was issued by then Secretary of National Defense, the HON. VOLTAIRE GAZMIN, in favor of the Petitioner attesting to the fact that he was granted amnesty for his participation/involvement in the July 27, 2003 Oakwood Mutiny and November 29, 2007 Peninsula Manila Hotel siege in Makati City pursuant to the Provisions of PROCLAMATION NO. 75, SERIES OF 2010, a duly certified true copy of which is hereto appended and made an integral part hereof as ANNEX "E”.4,10 On the basis of the approval of the amnesty application by the Ad Hoc Committee of the DND pursuant to PROCLAMATION NO. 75, SERIES OF 2010, as concurred in by CONGRESS, petitioner was allowed to take his PLEDGE OF ALLEGIANCE on 27 January 2011 before then DND Secretary VOLTAIRE T. GAZMIN, ANNEX “EF” hereof. 4.11 Thereafter, herein Petitioner filed with the appropriate MOTIONS TO DISMISS in the two (2) cases pending against him at that time relating to the July 27, 2003 Oakwood Mutiny and November 29, 2007 Peninsula Manila Hotel siege in Makati City, particularly: a) CRIM. CASE NO. 07-3126 for Rebellion pending before the REGIONAL TRIAL COURT of MAKATI - BRANCH 150; and b) CRIM. CASE NO. 03-2784 for Coup d’etat pending before the REGIONAL TRIAL COURT of MAKATI - BRANCH 148. 4.12 After due proceedings, acting on the Motions to Dismiss filed in the case, including that of the herein Petitioner, the Honorable REGIONAL TRIAL CCURT of MAKATI - BRANCH 150 issued an ORDER dated 07 September 2011 in CRIM. CASE NO. 07-3126 DISMISSING the case as against the Petitioner. A duly certified true copy of the ORDER dated 07 September 2011 issued by the Honorable Court duly signed by the HON. ELMO M. ALAMEDA, Presiding Judge, is hereto appended and made an integral part hereof as ANNEX “G”. 4.13 Likewise, after hearing and due proceedings and acting on the Motion to Dismiss filed by Petitioner, the Honorable REGIONAL TRIAL COURT of MAKATI - BRANCH 148 issued an ORDER dated 21 September 2011 in CRIM. CASE NO. 03-2784 DISMISSING the case as against the Petitioner. A duly certified true copy of the ORDER dated 21 September 2011 issued by the Honorable Court duly signed by the HON. MA. RITA A. BASCOS- SARABIA, Acting Presiding Judge, is hereto appended and made an integral part hereof as ANNEX “H”. 4.14 No motions for reconsideration were filed by the Prosecution or any other party either in CRIM. CASE NO. 07-3126 or in CRIM. CASE NO, 03-2784. Hence, both said ORDERS which 10DISMISSED the cases against Petitioner already became final and executory nearly seven (7) years ago. 4,15 For the record, the other case filed against herein Petitioner before a Military Tribunal in connection with the July 27, 2003 Oakwood Mutiny for alleged violation of Article 96 of the Articles of War (i.e., Conduct unbecoming of an officer and a gentleman), punishable by mere dismissal from the service, was already dismissed as early as in 2007 when it was deemed to be moot and academic by reason of the filing by the Petitioner of his Certificate of Candidacy for the position of Senator and his subsequent election as Senator in 2007, pursuant to Section 68!° of the Omnibus Election Code (Batas Pambansa Blg. 881). 4.16 Asa result, Petitioner was in fact formally allowed by the AFP be resign from his former position as Lieutenant Senior Grade (LTSG) of the Philippine Navy in 2007, as can be seen from enclosed duly certified true copies of the MAJOR SERVICE CLEARANCE, CERTIFICATE OF LAST PAY and GENERAL ORDER NO. 515, SERIES OF 2007, approving his IPSO FACTUM RESIGNATION, ANNEX “I”, "J" & "K", hereof, respectively. 4.17 Hence, all of the cases filed against Petitioner In connection with the July 27, 2003 Oakwood Mutiny and the November 29, 2007 Peninsula Manila Hotel incident have long been dismissed. 4.18 During the May 2016 National and Local Elections, President RODRIGO ROA DUTERTE was elected and proclaimed President. On 30 June 2016, he took his oath and assumed his Office as President. 4.19 By force of circumstances, in the performance of his duties as a Senator of the Republic and in opposing the numerous policies of the Duterte Administration which he believes are detrimental to the country and the public, foremost of which 29 Section 66 of the Omnibus Election Code (B.P, Blg. 881) expressly provides: Section. 66. Candidates holding appointive office or positions. - Any person holding a public appointive office or pposition, including active members of the Armed Forces of the Philippines, and officers and errployees in government-owned or controlled corporations, shall be considered ipso facto resigned from his office upon the filing of his certificate of candidacy. ainclude prevalence of Extra-Judicial Killings (EJKs) involving our poor countrymen incidental to the Administration’s War on Drugs, as well as the Administration's defeatists policies regarding our dealings with China particularly concerning the disputed territories in the West Philippine Sea (WPS) and the Panatag Shoal, among others, Petitioner has earned the ire of the Durtete Administration, of which he is considered to be one of the harshest critics. 4.20 Apparently unable to find any legitimate issues which they can use against the Petitioner, President RODRIGO ROA DUTERTE resorted to the desperate act of issuing PROCLAMATION NO. 572, SERIES OF 2018, the caption of which reads as follows: “PROCLAMATION NO. 572” “REVOCATION OF DEPARTMENT OF NATIONAL DEFENSE AD HOC COMMITTEE RESOLUTION NO, 2(#1) DATED JANUARY 31, 2011 INSOFAR AS IT GRANTED AMNESTY TO FORMER LTSG ANTONIO TRILLANES IV” 4.21 The basis for the alleged revocation of Department of National Defense Ad Hoc Committee Resolution No. 2(#1) was supposedly because Petitioner "did not file an Official Amnesty Application Form” and purportedly "never expressed his guilt for the crimes committed on occasion of the Oakwood Mutiny and Peninsula Manila Hote! Siege”, as can be seen from Tenth (10t) and Eleventh (11') Perambulatory Clauses of PROCLAMATION NO. 572, SERIES OF 2018. 4.22 On the basis of this claims, Pres. Duterte DECLARED and PROCLAIMED in PROCLAMATION NO. 572, SERIES OF 2018, thus: “Section 1. The grant of arinesty to former LTSG Antonio Trillanes iV under Proclamation No. 75 is declared voit! ab initio because he did not comply with the minimum requirements to qualify under the «mnesty Proclamation. “Section 2. Effects, 1, As a consequence, the Department of Justice and Court Martial 12of the Armed Forces of the Philippines are ordered to pursue all criminal _and administrative cases filed against former G Antonio Trilla: in relation to ti Oakwood _ Muti an. the nila Peninsula Incident, 2. The Armed Forces of _ the Philippines and the Philippine National Police are ort to loy all lawful means to apprehend _ former. iG Antonio _Trillanes_so_that_he can be recommitted to the detention facility where he hi: een i rated for hil to trial for the crimes he is charged with. “Section 3. Effectivity. This Proclamation shall take effect immediately. [Emphasis supplied] A copy of PROCLAMATION NO. 572, SERIES OF 2018, as officially published in the 04 September 2018 edition of the Newspaper Manila Times, is hereto appended and made an integral part hereof as ANNEX “L” hereof. 4.23 On the same day of the publication of PROCLAMATION NO. 572, SERIES OF 2018, on 04 September 2018, the Executive Department, led by Respondent HON. MEDIALDEA, as Executive Secretary, and Respondent HON. GUEVARRA, as Secretary of Justice, have attempted to implement the clearly illicit, whimsical and/or capricious provisions the subject proclamation. 4.24 Thus, the PNP and/or the CIDG under leadership of Respondents P/DIR. GEN. ALBAYALDE and CIDG Chief Respondent P/DIR. OBUSAN under the general supervision of Respondent HON. ANO, as DILG Secretary, as well as the AFP, under the leadership of the AFP Chief of Staff, Respcndent GEN. GALVEZ, under the supervision of Respondent HON. LORENZANA, as DND Secretary, no less than forty (40) officers and members of the PNP and/or CIDG, as well as scores of officers and members of the AFP, to the Senate Building in Roxas Boulevard, Pasay City, to act as arresting teams and/or to implement the provisions of PROCLAMATION NO. 572, SERIES OF 2018, by attempting to effect the arrest of Petitioner.4.25 In view of the fact that the supposed arresting teams sent by Respondents could not present any legal document to justify the supposed arrest of the Petition, apart from a copy of PROCLAMATION NO. 572, SERIES OF 2018, and particularly because of the absence of any lawful warrant of his arrest, the leadership of the Senate refused to allow them into the premises of the Senate and/or to entertain them further. 4.26 As a precautionary measure, in order to protect himself from the arbitrary, illicit and unlawful attempts of the arresting teams sent by Respondents to effect his arrest despite of the absence of _any lawful or valid warrant or order for his arrest, Petitioner, with the consent of his colleagues at the Senate and the Senate President, have decided to placed himself under the custody of the Senate President pending the filing, consideration and resolution of the instant Petition with this Honorable Court. 5. GROUNDS FOR THE PETITION Petitioner most respectfully invokes the Honorable Supreme Court’s power of judicial review pursuant to Section 1 of Article VII of the 1987 Constitution to correct and/or check the abuses and/or excesses of the Executive Department, which amounts to lack or excess of jurisdiction in issuing and/or implementing PROCLAMATION NO. 572, SERIES 2018, particularly on the following specific grounds - I. PRES. DUTERTE AND/OR THE RESPON- DENTS GRAVELY ABUSED THEIR DISCRETION IN A MANNER AMOUNTING TO LACK OR EXCESS OF JURISDICTION IN ISSUING AND/OR ATTEMPTING TO IMPLEMENT PROCLAMATION NO. 572, SERIES OF 2018, CONTRARY TO EXISTING JURISPRUDENCE TO THE EFFECT THAT THE AMNESTY GRANTED TO PETITIONER ALREADY COMPLETELY EXTINGUISHED, ABOLISHED AND/OR 1aPUT INTO OBLIVION THE ALLEGED OFFENSES OF PETITIONER. Il. PRES. DUTERTE AND/OR THE RESPON- DENTS GRAVELY ABUSED THEIR DISCRETION IN A MANNER AMOUNTING TO LACK OR EXCESS OF JURISDICTION BY ATTEMPTING TO EFFECT THE ARREST OF THE PETITIONER WHEN THERE IS IN FACT NO VALID WARRANT, NO LAWFUL CAUSE AND NO PENDING CASE AGAINST PETITIONER JUSTIFYING SUCH ARREST. II. PRES. DUTERTE AND/OR THE RESPON- DENTS GRAVELY ABUSED THEIR DISCRETION IN A MANNER AMOUNTING TO LACK OR EXCESS OF JURISDICTION WHEN THEY ISSUED AND/OR ATTEMPT TO EFFECT AND/OR IMPLEMENT THE ARREST OF PETITIONER ON THE BASIS OF THE PROCLAMATION OF PRES. DUTERTE, WHO IS NOT AUTHORIZED BY ANY LAW OR THE CONSTITUTION TO ISSUE WARRANTS OR ORDERS OF ARREST; -AND- Iv. PRES. DUTERTE’S AND/OR RESPODENTS’ ACT OF ISSUING AND/OR ATTEMPTING TO IMPLEMENT PROCLAMATION NO. 572, SERIES OF 2018, AND ESSENTIALLY REVOKING THE AMNESTY GRANTED TO PETITIONER WITH THE CONCURRENCE OF CONGRESS, IS CLEARLY UNCONSTI- TUTIONAL BECAUSE: 15,A FIRST, THE ACT OF THE PRESIDENT AND/OR THE RESPONDENTS OF UNILATERALLY WITHDRAWING THE AMNESTY GRANTED TO PETITONER VIOLATES THE CONSTITUTIONAL DESIGN INTENDING SUCH POWER TO BE A “SHARED POWER” BETWEEN THE PRESIDENT AND THE MAJORITY OF THE MEMBERS OF BOTH HOUSES OF CONGRESS; B. SECOND, PROCLAMATION NO. 572, SERIES OF 2018, SMACKS OF POLITICAL HARASSMENT AND CLEARLY VIOLATES THE “DUE PROCESS” AND “EQUAL PROTECTION” CLAUSES OF THE CONSTITUTION; Cc PROCLAMATION NO. 572, SERIES OF 2018, VIOLATES THE RIGHT OF PETITIONER AGAINST BEING PLACED TWICE IN JEOPARDY OF CONVICTION FOR THE SAME OFFENSE. -AND- D. FINALLY, PROCLAMATION NO. 572, SERIES OF 2018, WHICH ESSENTIALLY ORDERS THE PHILIPPINE NATIONAL POLICE AND THE ARMED FORCES OF THE PHILIPPINES TO ARREST PETITIONER CLEARLY VIOLATES THE CONSTITUTION, WHICH VESTS THE POWER TO ISSUE WARRANTS OR ORDERS OF ARREST UPON THE JUDICIARY.6. ARGUMENTS/DISCUSSION IN RE: THE FIRST GROUND — PRES. DUTERTE AND/OR THE RESPON- DENTS GRAVELY ABUSED THEIR DISCRETION IN A MANNER AMOUNTING TO LACK OR EXCESS OF JURISDICTION IN ISSUING AND/OR ATTEMPTING TO IMPLEMENT PROCLAMATION NO. 572, SERIES OF 2018, CONTRARY TO EXISTING JURISPRUDENCE TO THE EFFECT THAT THE AMNESTY GRANTED TO PETITIONER ALREADY COMPLETELY EXTINGUISHED, ABOLISHED AND/OR PUT INTO OBLIVION THE ALLEGED OFFENSES OF PETITIONER. 5.1 There can be no doubt that Petitioner applied for, and was granted, amnesty under PROCLAMATION NO. 75, SERIES OF 2007, as evidenced by the fact that not only was he issued his CERTIFICATE OF AMNESTY by then DND Secretary VOLTAIRE GAZMIN, ANNEX “E” hereof, all of the cases pending against him at that time were dismissed on the basis of the sald grant of amnesty. 5.2 Hence, the Honorable REGIONAL TRIAL COURT of MAKATI - BRANCH 150 issued an ORDER dated 07 September 2011 in CRIM. CASE NO. 07-3126 DISMISSING the case as against the Petitioner upon motion duly filed with the Court, as evidenced by the certified true copy of the ORDER dated 07 September 2011 issued by the Honorable Court duly signed by the HON. ELMO M. ALAMEDA, Presiding Judge, ANNEX. "G*, 5.3 Likewise, after hearing and due proceedings and acting on the Motion to Dismiss filed by Petitioner, the Honorable REGIONAL TRIAL COURT of MAKATI - BRANCH 148 issued an ORDER dated 07 September 2011 in CRIM, CASE NO. 03-2784 DISMISSING the case as against the Petitioner, as evidenced by duly certified true copy of the ORDER dated 21 September 2011 issued by the Honorable Court culy signed by the HON. MA. RITA A. BASCOS-SARABIA, Acting Presiding Judge, ANNEX “H”. 75.4 Apart from the fact that Petitioner has in his favor the legal presumption?! of regularity in the performance of his official duties when Sec. Gazmin issued the CERTIFICATE OF AMNESTY in favor of the Petitioner, ANNEX "E” hereof, the claim that Petitioner did not file an official amnesty application form and/or never expressed his guilt for the crimes that were committed on occasion of the Oakwood Mutiny and Peninsula Manila Hotel Siege is simply belied the facts, as evidenced by ANNEXES "“C”, “C-1" & "D” hereof. 5.5 Moreover, it cannot be denied that the grant of amnesty to Petitioner was an operative fact. When the Honorable Trial Courts, particularly RTC MAKATI - BRANCH 150 and RTC MAKATI - BRANCH 148 granted the motions of Petitioner and dismissed the cases against him on the basis of the amnesty granted to the Petitioner, it can reasonably and legally be presumed that said courts also reviewed and passed upon the legality and validity of the amnesty proclamation in favor of the Petitioner. 5.6 Amnesty is a public act of which the court should take judicial notice*?. 5.7 Thus, the rights to the benefits of amnesty, once established by evidence presented, either by the complainant or prosecution or by the defense, cannot be waived, because it is of public interest fa in who is regarded b Amnesty Pre ‘ion, ich has the force of law, is is ent, for he nds in the eyes the law as if he had never committed any punishable offense because of the amnesty, but as a patriot or hero, and not to be punished as a criminal". 5.8 In the instant case, any criminal liability on the part of the Petitioner has already been ccmpletely extinguished by virtue of the amnesty granted to him pursuant to PROCLAMATION NO 75, SERIES OF 2010, It has been ruled by this Court that amnesty looks backward _and_abolishi and. into oblivion the offense itself, it so overlooks and obliterates the offense with which he is charged; that the person released by amnesty stands before the law precisely as though he had committed no offerse?*, + Under Section 3 (m), Rule 131 (Burden of Proof and Presumptions], Rules of Evidence. 2 people v. Vera, G.R. No. L-26539, February 28, 1990. 3 Barrioquinto v, Fernandez, 82 Phil. 642 (1949); En Banc; Emphasis supplied. 44 Vera v. People, supra.; State v. Blalock, 62 N.C., 242, 247; In re: Briggs, 135 N.C, 118; 47 SE. 402, 403; Ex parte Law, 35 GA., 285, 296; State e» rel Anheuser-Busch Brewing Ass'n. vs. Eby,5,9 In the more recent case of People v. Casido (1997), the Honorable Supreme Court held: "xxx, Xxx amnesty looks backward and abolishes and puts into oblivion the offense itself, it so overlooks and obliterates the offense with which he is charged _that_the n_rele: by amnesty stands before the law precisely as__ though he had unit no offense.”"° [Emphasis supplied] 5.10 As can be seen from the foregoing, aside from the fact that there was utterly no basis for Pres, Duterte and/or Respondents’ act of revoking the grant of amnesty to Petitioner, under prevailing jurisprudence, supposed offenses of the Petitioner having already been abolished, put into oblivion and obliterated, the same cannot anymore be revived, reinstated and/or pursued by the Pres. Duterte, the Respondents and/or any persons acting under their orders or instructions. 5.11 Moreover, any criminal liability on the part of the Petitioner has already been completely extinguished by the amnesty granted to him under PROCLAMATION NO. 75, SERIES OF 2010, under Section 4 thereof, which provides that: “SECTION 4. Effects. - (a) Amnesty pursuant to this proclamation shall extinguish any criminal liability for acts committed in connection, incident or related to the July 27, 2003 Oakwood Mutiny, the February 2006 Marines Stand- or nd _the vember 2007 Peninsula_Manila_Hotel__Incident XXX,” [Emphasis supplied] 170 Mo., 497; 71 $.W. 52, 64; Burdick vs. United States, N.Y., 35 S. Ct., 267; 271; 236 U.S., 79; 59 Law ed., 476; as cited in Barrioquinto v. Fernandez, supra, 15G.R. No, 116512; March 7, 1997.5.12 Needless to state, the grant of amnesty to the Petitioner having already effectively extinguished any criminal liability for his supposed acts committed in connection, incident or related to the July 27, 2003 Oakwood Mutiny, the February 2006 Marines Stand- Off and the November 29, 2007 Peninsula Manila Hotel Incident, there is obviously nothing more to revive, reinstate and/or pursue. 5.13 The acts of Pres. Duterte and/or Respondents relating to PROCLAMATION NO. 572, SERIES OF 2018 ordering the DOJ and Court Martial of the AFP to pursue “ail criminal and administrative cases filed against” Petitioner “in relation to the Oakwood Mutiny and the Manila Peninsula Incident” is clearly diametrically opposed to the prevailing jurisprudence on the matter, as cited above. 5.14 Clearly, this arbitrary, whimsical and capricious acts on the part of Pres. Duterte and/or Respondents were clearly done in grave abuse of their discretion n a manner amounting to lack and/or excess of jurisdiction on their part. IN RE: THE SECOND, THIRD AND FOURTH GROUNDS ~ PRES. DUTERTE AND/OR THE RESPON- DENTS GRAVELY ABUSED THEIR DISCRETION IN A MANNER AMOUNTING TO LACK OR EXCESS OF JURISDICTION BY ATTEMPTING TO EFFECT THE ARREST OF THE PETITIONER WHEN THERE IS IN FACT NO VALID WARRANT, NO LAWFUL CAUSE AND NO PENDING CASE AGAINST PETITIONER JUSTIFYING SUCH ARREST. PRES. DUTERTE AND/OR THE RESPON- DENTS. GRAVELY ABUSED THEIR DISCRETION IN A MANNER AMOUNTING TO LACK OR EXCESS OF JURISDICTION WHEN THEY ISSUED AND/OR ATTEMPT TO EFFECT AND/OR IMPLEMENT THE ARREST OF PETITIONER ON THE BASIS OF THE PROCLAMATION OF PRES. DUTERTE, WHO IS NOT AUTHORIZED BY ANY LAW TO ISSUE WARRANTS OF ARREST; 20-AND- PRES. DUTERTE’S AND/OR RESPODENTS’ ACT OF ISSUING AND/OR ATTEMPTING TO IMPLEMENT PROCLAMATION NO. 572, SERIES OF 2018, AND ESSENTIALLY REVOKING THE AMNESTY GRANTED TO PETITIONER WITH THE CONCURRENCE OF CONGRESS IS CLEARLY UNCONSTI- TUTIONAL. 5.15 Petitioner most earnestly begs leave of the Honorable Supreme Court to discuss the Second, Third and Fourth Grounds for this Petition jointly because of the fact that the same are inter- related and intertwined. 5.16 As already alleged elsewhere above, the two (2) cases pending against Petitioner at the time PROCLAMANTION NO. rif SERIES OF 2010 was issued were already DISMISSED, particularly: a) CRIM. CASE NO. 07-3126 for Rebellion which was ten pending hefore the REGIONAL TRIAL COURT of MAKATI - BRANCH 150; end b) CRIM. CASE NO, 03-2784 for Coup d’etat which was then pending before the REGIONAL TRIAL COURT of MAKATI - BRANCH 148. 5.17 CRIM. CASE NO. 07-3126 was DISMISSED by virtue of the ORDER dated September 7, 2011 on the Honorable Court, duly signed by the HON. ELMO I, ALAMEDA, Presiding Judge of REGIONAL TRIAL COURT of MAKATI- BRANCH 150, ANNEX "G”. 5.18 CRIM. CASE NO. 03-2784 was DISMISSED by virtue of the ORDER dated September 21, 2011 as issued by the HON. MA. RITA A. BASCOS - SARABIA, Acting Presiding Judge of REGIONAL TRIAL COURT of MAKATI - BRANCH 148, ANNEX “H”. 5.19 Hence, the directive contained in PROCLAMATION NO. 572, SERIES OF 2018 issued by Pres. Duterte and/or being implemented by Respondents directing the PNP and AFP "to employ all lawful means to apprehend” Petitioner “so that he can be recommitted to the detention facility where he had been incarcerated for him to stand trial for the crimes he is charged with” as provided in Section 2 (2) thereof, is clearly whimsical, malicious 21and/or capricious, in the light of the fact that there are actually no valid warrants, no lawful causes and/or no pending cases against Petitioner justifying such arrest. 5.21 In effect, Pres. Duterte and/or Respondents have acted to cause the warrantless arrest of the herein Petitioner not only without any valid or lawful basis but despite the fact that there are actually no cases and no lawful pending against Petitioner. THE ACTS OF THE PRESIDENT AND/OR THE RESPONDENTS OF ORDERING AND/OR ATTEMP- TING TO EFFECT THE ARREST OF THE PETITIONER ARE CLEARLY ILLEGAL AND CONSTITU- TIONAL. 5.22 Clearly, the acts of Pres. Duterte and/or Respondents are clearly illegal. Verily, there is nothing in the 1987 Constitution nor in any of our existing laws which would authorized the President and/or the Respondents to issue and/or implement warrantless arrest of civilians like Petitioner except as provided in the 2000 Revised Rules on Criminal Procedure, which obviously do not apply to the instant case of Petitioner, 5,23 The actions and/or actuations of Pres. Duterte and/or Respondents, of attempting to order and/or effect the arrest of the Petitioner, without any lawful warrant of arrest against him, and lawful cause and without any cases actually pending against him which would justify such arrest clearly smacks of grave abuse of discretion amounting to lack or excess of jurisdiction, which would be the proper subject of the issuance of certiorari, prohibition and/or injunction and injunctive reliefs by the Honorable Supreme Court. THE ACTS OF THE PRESIDENT AND/OR THE RESPONDENTS IN ISSUING AND/OR ATTEMPTING TO IMPLEMENT PROCLAMATION ON. 572, SERIES OF 2018, CLEARLY VIOLATE THE PETITONER’S RIGHT TO DUE PROCESS OF LAW AND TO 22EQUAL PROTECTION OF THE LAW. 5.24 Moreover, the same are not only illegal but are also likewise unconstitutional. For one, the attempt of the Respondents to cause the arrest of herein Petitioner without just cause and due process of law is clearly violates Petitioner's right to due process of law, as guaranteed by the 1987 Constitution. 5.25 Thus, Article III, Section 1 of the 1987 Constitution reads: “Section 1. No person shall be deprived of life, liberty, or property without due process of law, nor shall any person be denied the egual protection of the Jaws.” [Emphasis supplied] 5.26 Under the circumstances where Pres. Duterte and/or the Respondents have issued and/or are attempting to implement PROCLAMATION NO. 572, SERIES 2018, which orders the arrest of the Petitioner without any trial or proceedings and without giving him the due process guaranteed by the Constitution. The same must clearly be declared as unconstitutional because it clearly runs afoul with this preferred basic and fundamental right guaranteed to all persons. 5.27 Apart from this, a review of the subject proclamation would readily show that the Petitioner was specifically named and mentioned (LTSG. ANTONIO TRILLANES IV) in PROCLAMATION NO. 572, SERIES OF 2018, at least EIGHT (8) TIMES and was specifically named and mentioned therein to the one and only person who will be adversely affected by the said PROCLAMATION. 5.28 Petitioner submits that under the same principles for which our courts and jurisprudence prohibits “class legislation”, PROCLAMATION NO. 572, SERIES OF 2018 should be stricken down as unconstitutional for being violative of the equal protection clause of the Constitution as embodies in Article ITT, Section i of the 1987 Constitution. 5.29 Much worse than “class legislation”, it is obvious from even a cursory reading of PROCLAMATION NO. 572, SERIES OF 232018, that Petitioner, whose name has been repeatedly mentioned in the text of the proclamation as LTSG. ANTONIO TRILLANES Iv, is being singled out and specifically targeted by the proclamation, thus, clearly showing the illicit and malicious nature thereof. 5.30 For this reason, Petitioner submits that PROCLAMATION NO. 572, SERIES OT 2018, should only be declared as illegal but unconstitutional as well as it clearly violates the right of Petitioner to equal protection of the law. PROCLAMATION NO. 572, SERIES OF 2018, WHICH ESSENTIALLY ORDERS THE PHILIPPINE NATIONAL POLICE AND THE ARMED FORCES OF THE PHILIPPINES TO ARREST PETITIONER CLEARLY VIOLATES THE CONSTITUTION, WHICH VESTS THE POWER TO ISSUE WARRANTS OR ORDERS OF ARREST UPON THE JUDICTARY. 5.31 Likewise, the attempt of Pres. Duterte and/or the Respondents to order and/or cause the arrest of Petitioner on the basis of the a mere proclamation, without a valid warrant of arrest and without any lawful cause or any cases pending against him which would justify his arrest likewise clearly violates Article III, Section 2 of the 1987 Constitution, which expressly provides: “Section 2. The right of the people to be secure i ir person: Ss, pal and effects against unreasonable. ches. seizures of whatever nature and for any purpose shall be inviolable, and no search warrant or warrant of arrest shall issue except upon probable _cause_to be letermined personall\ the judge aft« examination under oath or affirmation of the complainant and the witnesses he may produce, and particularly describing the place to be searched and the persons or things to be seized, [Emphasis supplied] 245.37 The power to grant amnesty is not just the sole prerogative of the Executive. Under the Constitution, this power, to be validly exercised, requires the concurrence of both houses of Congress. This can be clearly gleaned from the relevant provisions of the 1987 Constitution, particularly Article VII [Executive Department], Section 19, thus: Section 19. Except in cases of impeachment, or as otherwise provided in this Constitution, the President may grant reprieves, commutations, and pardons, and remit fines and forfeitures, after conviction by final judgment. He shall also have the power to grant amnesty with the concurrence of a jority of all the mbers th Congress. [Emphasis supplied] 5.38 In the case of the amnesty granted to Petitioner, the formal concurrence of both houses of Congress was obtained in the form of CONCURRENT RESOLUTION NO. 4, the caption of which reads as follows, to wit: “CONCURRENT RESOLUTION NO. 4” “CONCURRENT RESOLUTION CONCURRING WITH PROCLAMATION NO, 75 OF THE PRESIDENT OF THE REPUBLIC OF THE PHILIPPINES DATED 24 NOVEMBER 2010 ENTITLED: ‘GRANTING AMNESTY TO ACTIVE AND FORMER PERSONNEL OF THE ARMED FORCES OF THE PHILIPPINES, PHILIPPINE NATIONAL POLICE AND THEIR SUPPORTERS WHO MAY HAVE COMMITTED CRIMES PUNISHABLE UNDER THE REVISED PENAL CODE, THE ARTICLES OF WAR AND OTHER LAWS IN CONNECTION WITH THE OAKWOOD MUTINY, THE MARINES STAND-OFF AND THE PENINSULA MANILA HOTEL INCIDENT.” The same was adopted by the House of Representatives and the Senate on December 13, 20:0 and December 14, 2010, respectively. A duly certified true copy of the said CONCURRENT 26RESOLUTION NO. 4 is hereto appended and made an integral part hereof as ANNEX "B”. 5,39 Petitioner submits that there is a reason why the framers of the fundamental law decided to make the awesome power of granting amnesty as a shared power of the President and the members of both houses of Congress. Obviously, the power to grant amnesty, which essentially includes the power to condone And absolve even the most horrific crimes committed by persons or certain groups of persons, is too delicate a power to entrusted to one person only. 5.40 Since the power to grant amnesty is a power shared by the President with the members of both houses of Congress, it is most respectfully submitted that Pres. Duterte’s and/or Respondents act of issuing and/or implementing PROCLAMATION 572, SERIES 2018, which unilaterally attempts to revoke the amnesty jointly granted by the former President and majority of the members of both houses of Congress to the Petitioner, is clearly unconstitutional as it violates the constitutional design clearly making the said power a joint power of the President and the members of both houses of Congress. 5.41 It is most respectfully submitted that for the President to revoke and/or recall the amnesty proclamation previously issued by the former President with the concurrence of majority of the members of both houses of Congress, he must likewise obtain the concurrence of majority of the members both houses of Congress for the said revocation and/or recall. 5.42 Obviously, what the President could not do on his own, he should not also be allowed to undo on his own, Otherwise, the said attempt to revoke and/or recall the Petitioner's amnesty proclamation must be stricken down as iilegal if: not clearly unconstitutional. PROCLAMATION NO. 572, SERIES OF 2018, VIOLATES THE RIGHT OF PETITIONER AGAINST BEING PLACED TWICE IN JEOPARDY OF CONVICTION FOR THE SAME OFFENSE, 5.43 Finally, the specific provisions of Section 2 (1) of PROCLAMATION NO. 572, SERIES OF 2018, as issued by Pres. 7Duterte and/or being implemented by the Respondents expressly provides for the revival of the cases previously filed against the Petitioner, thus: “Section 2. Effects. 1. The Department of Justice and Court Martial of the Armed Forces of the Philippines to__pursue all criminal _and administrative cases filed against LTSG Antonio Trillanes [Petitioner] in relation to the Oakwood Mutiny and the Manila Peninsula Incident.” [Emphasis supplied] 5.44 Since, as already pointed out above, the two (2) cases pending against the Petitioner, CRIM. CASE NO. 07-3126 previously pending before the REGIONAL TRIAL COURT of MAKATI — BRANCH 150 and CRIM. CASE NO. 03-2734 previously pending before the REGIONAL TRIAL COURT of MAKATI — BRANCH 148 were both DISMISSED on the basis of the amnesty granted to Petitioner pursuant to PROCLAMATION NO. 75, SERIES OF 2010, long after the Petitioner was arraigned in both cases, the same constitute the dismissal on the merits of these two (2) cases, which have long become final and executory. 5.45 In view thereof, the above-quoted provisions of the proclamation ordering the revival of said cases clearly and specifically violates the constitutional guarantee against double jeopardy, specifically Article Ill, Section 21 of the 1987 Constitution, thus: “Section 21. No person shall fice put_in jeopardy of punishment for the same offense. If an act is punished by a law and an ordinance, conviction or acquittal under either shall constitute a bar to another prosecution for the same act.” [Emphasis supplied] 5.46 Viewed in the light of all the foregoing, it is very clear that Pres. Duterte’s act of issuing and/or Respondents’ act of attempting to implement, PROCLAMATION NO. 572, SERIES OF alee 282018, is clearly illegal and/or unconstitutional, as extensively discussed above. 5.47. Clearly, PROCLAMATION NO. 572, SERIES OF 2018, must be declared as illegal and/or violative of the 1987 Constitution. THE ALLEGED GROUNDS CITED BY PROCLAMATION NO. 572, SERIES OF 2018, FOR THE ALLEGED REVOCATION OF THE AMNESTY GRANTED TO PETITIONER ARE CLEARLY FALSE. 5.48 As can be seen from the text of the subject proclamation itself, the basis for the alleged revocation of Department of National Defense Ad Hoc Committee Resolution No. 2(#1) was supposedly because Petitioner “did not file an Official Amnesty Application Form” and purportedly “never expressed his guilt for the crimes committed on occasion of the Oakwood Mutiny and Peninsula Manila Hotel Siege”, as can be seen from Tenth (10%) and Eleventh (11°) Perambulatory Clauses of PROCLAMATION NO. 572, SERIES OF 2018. 5.49 These claims are clearly debunked by the official documents issued by the DND clearly showing that Petitioner applied for and was granted amnesty under PROCLAMATION NO. 75, SERIES 2010, particularly the CERTIFICATE OF AMNESTY issued to the Petitioner on 21 January 2011, duly signed by then DND Secretary VOLTAIRE GAZMIN, and the copy of PLEDGE OF ALLEGIANCE the Petitioner was asked to take after being granted amnesty also duly signed by then DND Secretary VOLTAIRE GAZMIN, duly certified true copies of which are hereto appended and made integral parts hereof as ANNEXES “E” & “F”. 5.50 Moreover, the claim that Petitioner did not file an official amnesty application form and/or never expressed his guilt for the crimes that were committed on cccasion of the Oakwood Mutiny and Peninsula Manila Hotel Siege is simply belied the facts, as evidenced by ANNEXES “C”, “C-1" & "D” hereof. 5.51 Likewise, the DND itself has recently released an official statement clarifying that in fact Petitioner did file his application for amnesty and in fact released an official document clearly showing 29this fact, particularly a MEMORANDUM addressed to the then Secretary of the DND and Chairman of the DND Ad Hoc Committee dated 05 January 2011 submitting the list of applicants who applied for amnesty under PROCLAMATION NO. 75, SERIES OF 2010, on that day, duly signed by LTC. JOSEFA C. BERBIGAL of the Judge Advocate General’s Office (JAG) who was then the Head of the Secretariat of the DND Ad Hoc Committee, ANNEX "M” hereof. 5.52 As regards the claim that Petitioner "never expressed his guilt for the crimes committed on occasion of the Oakwood Mutiny and Peninsula Manila Hotel Siege”, it impossible to apply for amnesty under PROCALAMATION NO. 75, SERIES OF 2010, without doing so because the APPLICATION FORM for amnesty under said proclamation itself, which Petitioner filled up and submitted, particularly and specifically requires such admission. 5.53 Thus, the text contained in the said application form specifically states: HE hereby acknowledge that my involvement/participation in the subject incident constitutes a violation of the 1987 Constitution, criminal laws and the Articles of War. I hereby recant my previous statements that are contrary, if any, to this express admission of involvement/participation and guilt.” The applicant is required to sign and indicate his rank and date right below statement, as can be seen from the copy of the subject APPLICATION FORM for amnesty under PROCLAMATION NO. 75, SERIES 2010, a sample copy of which is hereto appended as ANNEX “N”. 5.54 All of the foregoing should clearly show and illustrate to the Honorable Court that in fact, PROCLAMATION NO. 572, SERIES 2018, is nothing but a cheap political stunt designed to harass, prejudice and punished a political opponent of the administration.6. APPLICATION FOR THE ISSUANCE OF A WRIT OF PRELIMINARY INJUNCTION AND/OR TEMPORARY RESTRAINING ORDER (TRO) Petitioner repleads by way of reference and/or reiterates all of the allegations and averments above, and states: That - 6.1 As can be seen from all of the foregoing allegations, Petitioner is entitled to the reliefs and/or remedies he is praying for above. 6.2 Part and parcel of the said reliefs and/or remedies consists of enjoining, prohibiting and/or restraining the Respondents and all persons acting under their orders from implementing PROCLAMATION NO. 572, SERIES OF 2018, specifically the provisions under Section 2 thereof ordering: a. The Department of Justice and Court Martial of the Armed Forces of the Philippines "to pursue all criminal and administrative cases filed against” Petitioner “in relation to the Oakwood Mutiny and the Manila Peninsula Incident”; and - b. The AFP and the PNP “io employ all lawful means to apprehend” Petitioner “so he can be recommitted to the detention facility where he had been incarcerated for him to stand trial for the crimes he is charged with”. 6.3 This is true particularly in the light of the fact that the orders, directives and/or contemplated actions of Pres. Duterte and/or the Respondents would be contrary to prevailing laws and jurisprudence, as well as the fact that there are actually no pending cases against Petitioner, there are no lawful warrants for his arrest and/or Pres. Duterte and/or Respondents are not authorized either by the 1987 Constitution or any laws to order and/or effect the arrest of civilians like Petitioners without any lawful warrants issued by the Courts. 6.4 Needless to state, Petitioner stands to suffer grave and/or irreparable damages if the Respondents are not restrained, enjoined and/or prohibited from their contemplated actions and/or actuations, to wit: a. Petitioner is under threat being detained, deprived of his personal freedom and/or incarcerated without any valid or lawful cause; aab. Petitioner stands be unduly deprived of his personal liberty without due process of law; c. Worse, Petitioner will be detained against his will, in violation of all his rights, when there are in fact no cases filed against him; and — d. Petitioner is under threat of being arrested by the Respondents and/or persons acting under their orders and/or directives when there is in fact no lawful warrant for his arrest. 6.5 As can be seen from all of the foregoing, the damages the Petitioner stands to suffer are cearly grave and are irreparable in nature and/or incapable of pecuniary estimation, and are far graver than any possible damages which Respondents may suffer if a writ of injunction and/or temporary restraining order (TRO) is issued and in turns out later that the Petitioner is not really entitled to one. 6.6 Petitioner manifests that in view of the threat of his arrest poised by the Respondents’ immediate attempts and/or desire to immediately implement the assailed provisions of PROCLAMATION NO. 527, SERIES OF 2018, there is no motion for reconsideration and/or appeal or eny other just, adequate and/or speedy remedies available to him under the ordinary course of law. 6.7. Petitioner further submits that there is an extreme and urgent necessity for the Honorable Court to issue injunctive relief under the premises to protect and/or vindicate the rights of the Petitioner and/or to prevent the same from being rendered moot and academic by the actions and/or actuations of Respondents. 6.8 Petitioner manifest that he is willing, ready and able to post and/or put up a bond in such amount as may be pegged and/or required by the Honorable Court to secure the Respondents from any and/or all damages they may suffer as a result of the injunctive reliefs prayed for in the case, should it turn out latter that Petitioner was not really entitled to the same. 32PRAYER/RELIEF WHEREFORE, _ premises considered, Petitioner most respectfully prays of the Honorable Supreme Court: That - 4. Immediately upon the filing of the instant case, a WRIT OF PRELIMINARY INJUNCTION and/or TEMPORARY RESTRAINING ORDER (“TRO”) be ISSUED by the Honorable Court ENJOINING, PROHIBITING and/or RESTRAINING the Respondents and/or any and all persons acting in their behalf and/or under their orders from implementing PROCLAMATION NO. 572, SERIES OF 2018, specifically the provisions under Section 2 thereof ordering: a. The Department of Justice and Court Martial of the Armed Forces of the Philippines “to pursue all criminal and administrative cases filed against” Petitioner "in relation to the Oakwood Mutiny and the Manila Peninsula Incident”; and - b. The AFP and the PNP "to employ all lawful means to apprehend” Petitioner “so he can be recommitted to the detention facility where he had been incarcerated for him to stand trial for the crimes he is charged with”. 2. After hearing and due proceedings, JUDGEMENT be rendered, for the Petitioner and against the Respondents, GRANTING the petition for CERTIORARI, PROHIBITION and/or INJUNCTION and NULLIFYING and/or DECLARING as NULL AND VOID AB INITIO Pres. Duterte’s and/or Respondents’ act of issuing and/or implementing PROCLAMATION NO. 572, SERIES 2018 for being contrary to existing jurisprudence, to the law and/or the 1987 Constitution and PROHIBITING and/or ENJOINING the Respondents’ from implementing the same and - 3. DECLARING the WRIT OF PRELIMINARY INJUNCTION and/or TEMPORARY RESTRAINING ORDER as previously prayed for by the Petitioner and/or issued by the Honorable Court to be considered as PERMANENT. 33OTHER RELIEF AND REMEDIES as may be just and equitable under the premises are also prayed for. Pasig City for the City of Manila, 05 September 2018. THE LAW FIRM OF CHAN ROBLES AND ASSOCIATES Counsel for Petitioner Senator Antonio F. Trillanes Iv Suite 2205B Philippine Stock Exchange Centre 224 Floor, Tektite East Tower, Exchange Road Ortigas Center, Pasig City, Metro Manila Tel Nos. (632) 634-0741 to 45; Fax No, (632) 634-0736 E-mail: ct a SS ] ta» REYNALDO BUSTOS ROBLES PTR No. 3865424; 01.06.18; Pasig City IBP-LRN No. 04309; 01.10.03; Makati City MCLE Compliance No. V- 0022154; 05.30.16 Roll of Attorney No. 37366 COPY FURNISHED: OFFICE OF THE SOLICITOR GENERAL ep cv Gd) C2 2F 134 Amorsolo St., Legaspi Village Sevafe Pak wo Makati City 06 Kept I EXPLANATION: A copy of the forégoing Petition is being served to the Office the Solicitor General through registered mail with return card due to lack of material time and necessary TT service thereof. t > SSE ~~" REYNALDO BUSTOS ROBLES 34REPUBLIC OF [HE PHILIPPINES) CITY OF Baga eae )S.S. VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING 1, SEN. ANTONIO “SONNY” F. TRILLANES IV, Filipino, of legal age and with address at Room 319, Sanate of the Philippines, GSIS Financial Center, Roxas Boulevard, Pasay City, after having been sworn to in accordance with law, depose and state: That - - 1. 2. day of September 2018 at the City of | am the Petitioner in the above-captioned case; | have caused the preparation of the foregoing PETITION FOR CERTIORARI, PROHIBITION AND/OR INJUNCTION WITH APPLICATION FOR THE ISSUANCE OF A WRIT OF PRELIMINARY INJUNCTION AND/OR TEMPORARY RESTRAINING ORDER (TRO); | have read all the allegations contained therein and the same are true and correct to the best of my own personal knowledge and as culled from authentic records; | hereby CERTIFY that | have not heretofore commenced any action or proceeding with the Supreme Court, Court of Appeals or any Division thereof, any other tibunal or agency, and that to the best of my knowledge, there is no cther action or proceeding that is pending with the Supreme Court, Court of Appeals or any Division thereof, or any other tribunal or agency, involving the same parties and the same issues as in the instant case, and should | learn later that such an action or proceeding is pending or commenced with the Supreme Court, Court of Appeals or any Division thereof, or any other tribunal or agency, | shall promptly report the same within five (5) days from such notice. IN WITNESS HEREOF, | have hereui my signature this BBA , Metro Manila, “SONNY”\F. TRILLANES IV Petitioner-Affiant SEN. ANTONI!SUBSCRIBED AND SWORN to before me, a Notary Public commissioned in and for Dasay cry this ~ day of September 2018, by SEN. ANTONIO “SONNY” F. TRILLANES IV, who has satisfactorily proven to me his identity through his SENATE ID with ID Number 2007-2006 effective up to June 2019, bearing his photograph and signature, here acknowledged to me and that he is the same person who appeared and signed the foregoing instrument in my presence and within my jurisdiction, and who avowed to the truth of its content under penalty of law. NOTARY PUBLIC Doc. No. _4o _; Qr, Se Page No.__$ } ATTY. JOVINOR, ANGEL Book No._¥_; NOTARY PUBLIC Series of 2018. NOTARIL COMMISSION 17-08 ‘UNTIL DECEMBER 31, 2018 PTR NO. S82G093/BP NO. 1052667 SOTH ISSUED IN PASAY CITY ON JAN, 3, 2018, ACLE COMPLIANCE NOI V-0024151 10/25/47 ROLL OF ATIORNEYS No, 28764REPUBLIC OF THE PHILIPPINES) MWA ry )ss. I, JESUS P. CANADA, a Liaison Officer of THE LAW FIRM OF CHAN ROBLES AND ASSOCIATES, with office address at 22 Floor, Philippine Stock Exchange Centre, Tektite Tower I, Exchange Road, Ortigas Center, Pasig City, Metro Manila, after having been duly swom to in accordance with law, hereby depose and say: ‘That in connection with the case entitled SEN. ANTONIO F. TRILLANES, IV Petitioner versus HONORABLE SALVADOR C. MEDIALDEA et. Al. Respondents SP Case No. and pursuant to the provisions of the 1997 Rules of Civil Procedure, I caused the service of one (1) copy of the PETITION FOR CERTIORARI, PROHIBITION AND INJUNCTION WITH APPLICATION FOR THE ISSUANCE OF PRELIMINARY INJUNCTION AND/OR TEMPORARY RESTRAINING ORDER to the following address: OFFICE OF THE SOLICITOR GENERAL 134 Amorsolo St., Legaspi Village Makati City, 1229 Particularly, by registered mail and depositing on 6 day of September 2018 said copies in Seaok Rast offce, Pron Cit} , Metro Manila as evidenced by Registry Receipt Nos. (eo JS (bey 74 Zarereto attached and indicated after the names of the addressees, and with instruction to the postmaster to return the mail to the sender after ten (10) days, if undelivered. ‘This affidavit is executed to attest to the truth of the foregoing statements, ', I have hereunto affixed my signature this 6 day of IN WITNESS, WHERE avy City, Metro Manila, Philippines. September 2018 at SUBSCRIBED AND SWORN to before me this 6" day of September 2018 at laxyy_Joy__ City, Metro Manila, affiant exhibiting to me his Tax Identification No. 206-61! competent evidence of identity, Doc, No. _/' Page No, Book No. c Series of 2018. Abo, etn No, 1847 ‘ve 1006-0 vosefin St, Sampaoc, Manila MCLE Compliance io, V-A004S121047 AAPasig City PTR No, MLATOS1823901.17 Maia Cityaiazore Prodamaion No 75,2010 | Oil Gazal of sw Repub iba Poones AK NINJEX ™, A” _ GOVPH() Proclamation No. 75, s. 2010 Signed on November 24,2010 (tain ofchteazete. cov. otv2010/1 1/24/nroelamatian-no-75:3-20101) MALACANAN PALACE. Manila BY THE PRESIDENT OF THE PHILIPPINES PROCLAMATION NO. 75 GRANTING AMNESTY TO ACTIVE AND FORMER PERSONNEL OF THE ARMED FORCES OF THE PHILIPPINES, PHILIPPINE NATIONAL POLICE AND THEIR SUPPORTERS WHO MAY HAVE COMMITTED CRIMES PUNISHABLE UNDER THE REVISED PENAL CODE, THE ARTICLES OF WAR AND OTHER LAWS IN CONNECTION WITH THE OAKWOOD MUTINY, THE MARINES STAND-OFF AND THE MANILA PENINSULA INCIDENT WHEREAS, it is recognized that certain active end former personnel of the Armed Forces of the Philippines (AFP), the Philippine National Police (PNP) and their supporters have or may have committed crimes punishable under the Revised Penal Code, the Articles of War and other laws in connection with, in relation or incident to the July 27, 2003 Oakwood Mutiny, the February 2006 Marines Stand-Off and the November 29, 2007 Manila Pen Incident; WHEREAS, there is a clamor from certain sectors of society urging the President to extend amnesty to said AFP personnel and their supporters; WHEREAS, Section 19, Article VII of the Constitution expressly vests the President the power to grant amnesty; mnesty; Sige WHEREAS, the grant of amnesty in favor of the said active and former personnel of the AFP and PNP and their supporters will promote an atmosphere conducive to the attainment of a just, comprehensive and enduring peace and is in line with the Government's peace and reconciliation initiatives; NOW, THEREFORE, |, BENIGNO S. AQUINO Ill, President of the Philippines, by virtue of the powers vested in me by Section 19, Article Vil of the Philippine Constitution, do hereby DECLARE and PROCLAIM:SHETION 1. Grant of Amnesty. ATMAEStY Is hereby GSRECAY all aGtive afl a TBH personnel of the AFP and PNP’ as well as their supporters who have or may have committed crimes punishable under the Revised Penal Code, the Articles of War or other laws in connection with, in relation or incident to the July 27, 2003 Oakwood Mutiny, the February 2006 Marines Stand-Off and the November 29, 2007 Manila Peninsula Incident who shall apply therefor, Provided that amnesty shall not cover rape, acts of torture, crimes against chastity and other crimes committed for personal ends. SECTION 2. Where to Apply. - The concerned AFP and PNP personnel and their supporters may apply for amnesty under this Proclamation with the ad hoc committee Department of National Defense (OND) Which is hereby tasked with receiving and processing applications ~ including oppositions thereto, if any = for amnesty pursuant to this proclamation anc determining whether the applicants are entitled to amnesty pursuant to this proclamation. The final decisions or determination of the DND shall be appealable to the Office of the President by any party to the application. The decision, however, shall be immediately executory even if appealed. SECTION 3. Period of Application. — Applications for the grant of amnesty under this proclamation shall be filed under oath with the DND within a period of ninety (90) days following the date of the publication of this proclamation in two (2) newspapers of general circulation as concurred in by a majority of all members in Congress. The DND shall forthwith act on the same with dispatch. SECTION 4. Effects. — (@) Amnesty pursuant to this proclamation shall extinguish any tal liability for acts committed in connection, incident or related to the July 27, 2003 Oakwood Mutiny, the February 2006 Marines Stand-Off and the November 29, 2007 Penirisula Manila Hotel Incident without prejudice to the grantee’s civil liability for injuries or damages caused to private persons. (b) Except as provided below, the grant of amnesty shall effect the restoration of civil and political rights or entitlement of grantees that may have been suspended, lost or adversely affected by virtue of any executive, administrative or criminal action or proceedings against the grantee in connection with the subject incidents, including criminal conviction or any form, if any. (©) All enlisted personnel of the Armed Forces of the Philippines with the rank of up to Technical Sergeant and personnel of the PNP with the rank of up to Senior Police Officer 3, whose applications for amnesty would be approved shall be entitled to reintegration or reinstatement, subject to existing laws and regulations. However, they shall not be entitled to back pay durifty-the time they have been discharged or suspended from service or unable to perform their military or police duties. (d) Commissioned and Non-commissioned officers of the AFP with the rank of MastéSemeant and personnel of the PNP with the rank of at least Senior Police Officer 4 whose application for amnesty will be approved shall not be entitled to remain in the service, reintegration or reinstatement into the service nor back pay.(2) All AFP and PNP personnel granted amnesty who are not reintegrated or reinstated shall be entitled to “retiremerit and separation benefits, if qualified under existing laws and regulation, as of the time separation, unless they have forfeited such retirement benefits for reasons other than the acts covered by this Proclamation. Those reintegrated or reinstated shall be entitled to their retirement and separation benefit upon their actual retirement. SECTION 5. Repealing Clause. - This proclamation supersedes Proclamation No. 50 issued on 11 October 2010 which hereby deemed recalled. SECTION 6. Effectivity. - This Proclamation shall take effect upon concurrence of a majority of all the Members of the Congress. SN, DONE in the City of Manila, 24" day of November in the year of our Lord, Two Thousand and Ten. (Sgd.) BENIGNO S. AQUINO III By the President: (Sgd.) PAQUITO N. OCHOA, JR. Executive Secretary “This entry was posted under Executive lasuances (ntip:/ www oficialgazette gov. pl ecutjveiesunnces argon yin fn a m7 : Se Le) Sat ged Beda S, Aquing eee A w Fra end See oh notoroclomations: ‘REPUBLIC OF THE PHILIPPINES ~ All content isin the public domain unlees otherwise stated. ‘ABOUT GOvPH Learn more about the Philippine government, its structure, how governmest warks and the people behind it Oficial Gazette (itaddwwr.cov.eh) ‘Open Data Portal (httns/data gov) ~ (GOVERNMENT LINKS ‘The President (htipd/neesident.gov.nh/)‘Rourt.of Anpeals.(htiad/ea udician,.gouahh »idanbayan (httnu/sb judciary.oox.nh).Hct Ret No Nod Republic of fe Bhjlippines Gougress of the Philippines Mletee Masta nent Congrass est Reglar Session oo in Meo Manils, on Monday, the twenty-sixth :wo thousand ten, CONCURRENT RESOLUTION NO. 4 CONCURRENT RESOLUTION CONCURRING WITH FRUULAMAUION NO. 75 OP THE PRESIDENT OF THE. REPUBLIC OF THE PHILIPPINES DATED 24 NOVEMBER 2010ENTITLED: "GRANTING AMNESTY 10 ACTIVE AND FORMER PERSONNEL 0? THE ARMED FORCES OF THE PHILIPPINES, PHILIPP'NE NATIONAL POLICE AND. THBIR SUPPORTERS WHO MAY HAVE COMMITTED CRIMES PUNISHABLE UNDER THE REVISED PENAL. CODE, THE ARTICLES CF WAR AND OTHER LAWS IN CONNECTION WITH THE OAKWOOD MUTINY, THE MARINES STAND-OFF AND THE PENINSULA MANILA HOTELINCIDENT WHEREAS, Section 19, Artice VII of the Constitution provides that the President shall have the power to grant amnesty with the concurrence of a majority ofall the Members of Congress; Wueres, on 24 November 2010, President BenignoS. Aquino issued Proclamation No, 75, granting amnesty toactive and former personne] ofthe Armed Foreesof the Philippines, Philippine National Police and their supporters who mayhave committed crimesptnishable under the Revised Penal Code, the Articles of War and other laws in connection with the Oalavood Mutiny, the Marines Stand-Offand the Peninsula Manila Hotel incident, the fulltext ofwhich reads asfollow, towit: CERTIFIED TRUE PHOTOCOPY (EG, RECORDS & ACHIVES svc SENATE OF THE PHILIPPINES ANNEX *“PROCLAMATION NO. 7! 'G AMNESTY TO ACTIVE AND FORMER SUPPORTERS WHO £ COMMITTED CRIMES PUNISHABLE UNDER THE REVISED PENAL CODE. THE ARTICLES OF LaWS IN CONNECTION WITH THE 0. "HE MARINES STAND-OFF AND THE PEN: A HOTEL INCIDENT “WHEREAS, it is recognized that certain active and former personnel of the Armed Forces of the Philippines (AFP), the Philippine National Police (PNP) and their supporters have or who may have committed crimes punishable under the Revised Penal Code, the Articles of War and other laws in connection with, inrelation or incident to the July 27, 2003 Oakwood Mutiny, the February 2006 Marines Stand-Off and the November 2: Peninsula Manila Hotel incident; personnel and their Supporters; IF of the Constitution grantamnesty; “WHEREAS, Section 18, oxpresely vests the President th ‘WHEREAS ss ufamacety in favor of the eaid active and foliner pers 2 AFPand PNP and their supporters Will promote anacuiosphere conducive to the attainment ofa just, comprehensive and enduring peace and is in line with the Government’ peace and reconciliation initiatives: “NOW, THEREFORE, !, BENIGNO S. AQUINO III Presidentof the Philippines, by virtue of the powers vested in me by Section 19, Article VII of the Philippine Constitution, do hereby DECLARE and PROCLAIM “SECTION 1, Grant of Amnesty. - Amnesty"is hereby granted to all active and former personnel of the AFP and PNP as well as their supporters who have or may have committed crimes punishable under the Revised Penal Code, the Articles of War or other laws in connection with, in relation or incident to the 4 not cover rape, acts of torture, crimes against chastity and other crimes committed for personal ends. ‘SECTION 2. Where to Apply. ~ The concerned AFP and PNP personnel and their supporters may apply for amnesty under this Proclamation withthe Department of National Defense (DND) sshich ishereby tasked with receiving and processing applications, including oppositions thereto ifany, for amnesty pursuant to this proclamation. The final dcisionor determination ofthe DND shall be appealable to the Oiice of the President by anj party to the application. The decision, however, shall beimmsediately execu cevenifappealed. ? "SECTION 8. Peried of Application. - Applic ant of amnesty under this Proclamation chal bs the DND within a period of ninety (90) days following the date of the publication of this Proclamation in two (2) newspapers of ‘general circulation as eoncurred in by a majority ofall the Members cof Congress. The DND shall erthwith at on the same with dispatch, ne for the led underoath "SECTION 4. Eifecis. ~ "@) Amnesty pursuant tothis proclamation shallextinguish any criminal liability for acts committed in conneetion, incident or related to the duly 27, 2008 Oakwood Mutiny, the February 2006 ‘Marines Stand-Oif and the November 29, 2007 Peninsula Manila Hotel incident without prejudice to the grantee's civil liability for injuries or damages caused to private persons, if any. "b) Exceptas provided below, the grantof amnesty shall effect the restoration of civil and political rights or entitlement of grantees that may have been suspended, lost or adversely affected by virtue of any executive, administrative or criminal action or proceedings against the grantee in connection with the subject incidents, including criminal conviction or any form, ifany. “) All enlisted personnel of the Armed Forces of the Philippines with the rank ofup to Technical Sergeant and personnel of the PNP with the rank of up ta Senior Police OfScer 3, whose applications for amnest ‘£6. RECORDS & AC) CERTIFIED TRUE PHOTOCOP: se Oea na THTONIA P. SARROS DIRECTO! ‘SENATE OF THE Pil0 existing laws and tions. Hi a be entitled to back pay during the time they have been discharged or suspended from the service or unable to performs their military or police duties "@) Commissioned and Non-Commissioned officersof the AFP with the rank of Master Sergeant and personnel of the PNP with the rank of at least Senior Police Officer 4 whose application for amanesty would be approved shall not be entitled to remain in the service, reintegration or reinstatement into the service nor back ay. “e) All AFP and PNP personnel granted amnesty who are hot reintegrated or reinstated chall'be entitled to retirement and separation benefits, qualified under existing laws and regulations, as of the time of their separation, unless they have forfeited such retirement benefits for reasons other than the acts covered by this, Proclamation. Those reintegrated or reinstated shall be entitled to ‘their retirement and separation benefits upon their actual retirement. "SECTION 5. Repeating Clause. ~ This proclamation supersedes Proclamation No. 50 issued on 11 October 2010 which is hereby deemed recalled "SECTION 6. Ey effect upon concurrence of ty. ~ This Proclamation shall take jority ofall the Members of Congress. “DONE in the City of Manila, thig2st® day of November in the year of our Lord, Two Thousand ax Ten, “(Ssd.) BENIGNOS. AQUINO TIL "By the President: "Ged PAQUITON. OCHOA JR.” WHEREAS, both Houses of Congress share the view of the Presidentthat in order to promote an atmosphere conducive to the attainment ofa just, comprehensive and enduring peace and in line with the Government's peace and reconciliation initiatives, there is a need to declare amnesty in favor of the said active and former personnel of the AFP and PNP and their supporters; in amnesty partaking the nature proclaimed he Presidentof the Philippi terest ofthe Philippines: Ne by His Excell for the general: Resolved by both Houses of Congress, To concur with Proclamation No, 75 issued by the President of the Philippines in accordance with the provisions af Section 19, Article VII of the Constitution. Resolved, further, That both Houses of Congress adopt the ‘ng recommendations to the President of the Philippines for inclusion in the implementing rules and regulations ofthe Amnesty Proclamation: . the applicant admitting his guilt or criminal cufebility. ject incidents in writing as exprested in the witha) of any or all of the a application; and (©) The decision granting amnesty shall not be executory pending appeal. Adopted, President of the Sfoate Speaker of the House of Representatives This Concurrent Resolution was adopted by the House of Representatives and the Sonate on December 13, 2010 and December 14, 2010, respectively. IED TRUE PHOTOCOPY Pusey. Mapieyn . A Secretary of theSenare 7, Secreary Gent : ef ae OMA PSARROS DIRECTOR - ° 16, RECORDS £ ACHIVES sve SEWATE OF THE PHILIPPINESANNEX CO” e-4" OPUOLPEDT DAO ED TOL eeeDT TP OTE crepe ba Ceuta NeANNEX * DP" GMA’NEWS ONLINE YOUR NEWS AUTHORITY Trillanes avails of amnesty, admits ‘breaking rules’ Published January 5,2011 3:09pm By MARK MERUENAS, GHANEwsTY UPDATED 4:30 p.m. - "We are man enough to admit that we have broken rules.” These were thefwords of former Navy Lt. Senior Grade and incumberf Senator Antonio Trillanes IV after he availed of government amnesty on Wednesday, along with the other Magdalo soldiers. Trillanes said they filled out an application form and eee een emeremates sicned the sections that state they were agreeing to their "general admission of guilt” that they violated military rules and the Revised Penal Code (RPC). ees However, Trillanes, who won in the 2007 senatorial elections after securing 11 million votes, was quick to admit despite their admission of guilt, they never regretted participating in the 2003 Oakwood mutiny. tn the 2003 uprising, some 300 soldiers, who collectively identified themselves as the "Magdalo” group, took over a posh hotel in Makati City to air their grievances against the Arroyo administration. He insisted he and his colleagues who participated in the uprising never denied that what they did in 2003 was something out of the ordinary. “Ever since, hind! naman kami nagpanggap na ang ginawa namin na pagpunta sa Oakwood at Peninsula {Hotel in 2007} ay natural na ginagawa ng sundalo... so it's very easy for us to admit that," Trillanes told reporters at Camp Aguinaldo. "Pero wala pong regret," he added, Trillanes said while they admitted to "violating some rules," they were not admitting guilt to the mutiny and coup d'etat charges lodged against them both in the civil and mititary courts.“1 would like to qualify that we did not admit to the charge of ‘coup d'etat’ or anything na finile sa amin because we believe hindi iyon ang nararapat na charge na ginawa sa amin," he said. He said their uprising in 2003 "could not be defined as coup d'etat." “We, ourselves, don't know if what we did wes coup d'etat," he added. Trillanes said he felt "good" as he was accomplishing the application form, and described the experience as "a milestone in our lives." On Tuesday, a total of 39 "mutinous" soldiers applied for arghesty — 19 of them were officers, 20 were enlisted personnel This brings the total number of amnesty applicants to 58 - including the four officers and 15 enlisted personnel who also applied for amnesty on Tuesday. Life after amnesty Trillanes said even if they are no longer in the service, they would still pursue their advocacies as ‘although or a different path, largely in politics and social erilce! members of the Magdalo grou movements and even commun’Earlierin the day, another military officer who applied for amnesty and talked to GMANews.TV on condition of anonymity said they were availing of amnesty for the sake of their families. He also said they wanted to clear their names and restore the ranks of their colleagues who were demoted for the 2003 uprising, He said most of the Magdalo soldiers had either taken up other jobs or had migrated abroad. He said some of their colleagues abroad might be coming bagk for the amnesty application, which runs until March, a ‘ As for Trllanes, he vowed to prioritize military-related measures when sessions in Congress resume in two weeks! time, The lawmaker said he would push for the modernization af the Armed Forces of the Philippines, as well as the provision of a higher combat pay for soldiers. Trillanes acknowledged President Aquino’s order to hike the combat pay of soldiers being sent to the field by P20, but admitted the amount was insufficient. Amnesty applicants Aside from Trillanes, the following individuals also applied for amnesty on Wednesclay: OFFICERS. # 2Lt. Edgardo Aguilar + alt Leopoldo Apellanes © Lt JG Arturo Pascua Jr + Lt.GCeferino Checa + 2Lt Jonnell Sangalang Ens, Cesar Carmel Tamba * Lt Jeoffrey Tacio + 2UT Norman Spencer + Lt. SG Andy Torrato + Lt. SG Manuel Cabochan + Lt. Norberto Santiago + 2lt. Jevechboy Macarubbo = Lt Billy Pascua + Lt Francisco Ashley Acedillo + Lt Jonathan Costales + Cpt. Gary Alejano + Cpt. Segundino Orfiano + Lt Eugene Louie GonzalezENLISTED PERSONNEL + CplEdgarVelasco + Cpl. Joey Membreve + $56 Francisco Bosi + Cpl. Bonifacio Barrion + Cpl. Berting Cabara + Cpl. Dennis Lopez * Cpl. Danilo Butial + Cpl. Leo Gapayao + Set. Jigger Paculba cpl. Lorenzo Carranzo + Cpl. Getman Linde ‘+ Sgt. Walter Manatansan + Cpl. Roel Motina ‘+ PieAbraham Apostol + Sgt. Ronald Reyes + Cpl. Ruel Espenilla + Put Jocil Regulacion Cpl. Emmanuel Tirador + Cpl. Filomeno Ramirez + Cpl. Catto Pitos Proclamation 75 Trillanes and the other Magdalo soldiers were able to avail of amnesty by virtue of Proclamation 75, issued by President Benigno Simeon Aquino Ill in November last year. Aquino eorlier issued on October 11 Proctamation 50 granting amnesty to all active and former personnel of the Armed Forces of the Philippines (AFP) and their supporters, who committed acts of omissions punishable under the RPC, the Articles of War or other special laws related to the following: + the July 27, 2003 Oakwood Mutiny: + the February 2006 Marines Stand-Off; + the November 29, 2007 Manila Peninsula Incident, and/or related incidents "provided that amnesty shal not cover crimes against chastity and other crimes committed for personal ends.” However, lawmakers had questions about the proclamation such as the “effectivity clause” of the proclamation and the supporters of the rebel soldiers who will also be covered by the amnesty. JeseMalacartang transmitted to the House on November 24 and to the Senate the next day, Proclamation 75, the amended version of Proclamation 50,The Senate on December 7 adopted the resol.tion concurring with the amended presidential proclamation granting amnesty to soldiers and policemen involved in at least three attempts to overthrow the Arroyo administration. Meanwhile, the House of Representatives on December 13, voting 213-7 with two abstentions, concurred with Aquino’s Proclamation 75. Those who were not in favor of the amnesty giant were: ‘* ANAD Rep. Pastor Alcover Jr * Agusan del Norte Rep. Jose Aquino tl; ‘Arroyo's son Camarines Sur Rep. Diosdado ‘Dato’ Arroyoy ‘Arroyo's brother-in-law Negros Occidental Rep. lgnaciowArroyo Jr; * Davao del Sur Rep. Marc Douglas Cagas IV; + Siquijor Rep. Orlando Fua, and + Lanao del Norte Rep. Imelda Dimaporo. Lanao del Sur Rep. Hussein Pangandaman an¢ Bukidnon Rep. Jose Ma. Zubir! Il abstained from voting. Mutineers ‘The mutineers covered by the amnesty proclamation are those who were involved in the following incidents: Oakwood mutiny — occurred on July 27, 2003 when 322 armed soldiers, who called themselves “Bagong Katipuneros” (New Katipuneros} took aver the Oakwood Premier Ayala Center (now Ascott Makati) servicec apartment tower in Makati City. Led by Army Capt, Gerardo Gambale and then Lt, Senior Grade and now Senator Antonio Tillanes IV, the mutineers protested against the alleged corruption of the Gloria Macapagal-Arroyo administration; Manila Peninsula incident — On November 2, 2007, Trillanes, Brig. Gen. Danilo Lim, Capt. Nicanor Faeldon and other Magdalo officials walked outof their trial and marched through the streets of Makati City, calling for the ouster of Arroyo. They then headed to The Peninsula Manila Hotel along Ayala Avenue in Makati City and seized itssecond floor; February 2006 Marine stand-off — The Philippines was placed under a state of emergency on February 24, 2006 after the government foiled a7 alleged coup d'état attempt; Arroyo lifted the state of emeigency on March 3, 2006. - WP, GMANews.TVANNEX “E° Dwpnancoasoias Certificate of Anmesty hei tc ta Senator ANTONIO F. TRILLANES IV. was granted AMNESTY on January 21, 2011 for his - oement in the July 27, 2003 Oakwood Mutisy and November 29, 2007 Manila Hotel Siege in ‘Makati City, pursuant to the: provisions. of Priel Proanaton Nr B issued on November 24, 2010 by His Excellency, PresidenBeniguo 8, Aquino Il. “Tata re SE OF SENATOR TRILLANESRepublic of the Philippines eer Department of National Defense ANNEX OF DND Ad Hoc Amnesty Committee Camp Aguinald, Quezon City PLEDGE OF ALLEGIANCE I, Senator ANTONIO F TRILLANES IV, residing at #42 Ninang Virginia Street, BF Homes, Caloocan City, DO SOLEMNLY SWEAR that I will support and defend the Constitution of the Republic of the PhilippingS and obey the laws and lawful orders promulgated by the duly constituted authofities of the Philippines, and hereby declare that J will maintain true faith and allegiance thereto, and that I impose this obligation upon myself voluntarily without mental reservation or purpose of evasion. SO HELP ME GOD. Senator ANTONIO F TRILLANES IV SUBSCRIBED AND SWORN to before me this 27th day of January 2011 at the Department of National Defense, Quezoa City. lah GAZMIN beam of National Defense sarin ea) nat Tuan tlt ‘efiCE OF SENATOR TRILLAWES CERTIFIED OPYa ANNEX *6" -REPUBLIC OF THE PHILIPPINES NALTIONAL CAPITAL JUDICIAL REGION REGIONAL TRIAL COURT CITY OF MAKATI BRANCH 150 PEOPLE OF THE PHILIPPINES, Plainti - Versus- S, CRIM. CASE NO. 07-3126 SEN. ANTONIO F. TRILLANES, IV, ETAL., Accused. x ORDER Cakes Gay C. Alejano, Segundino P. Orfiano Jr, Manuel Da. Cabochan, James A. Layug, Arturo S. Pascua Jr, Bugene Loiue P. Gonzalez, Andy G: Torrato, Billy S. Pascua, Jommell © Sangalang, Armand G. Fontejos, Julius J. Mesa, Cezari Yassir Gonzalez, Clecarte D. DAhan, Juanito . Jilbury Jr., Emmanuel C Tirador, German M. Linde, Arvin P. Celestino, Elmer D Colon, Monchito 0. Lusterio, Jocil B. Regulacion and Francisco N. Bosi, Jr. in support of their motions, the accused-movants aver that 1. As they previously manifested, His Excellency, President Benigno S. Aquino III, issued Proclamation No 75 dated November 24, 2010, granting them Amnesty which was concurred by majority cf all the members of Congress pursuant to Section 19, Article VII of the 1987 Philippine Constitution; 2. The fact of issuance of Presidential Proclamation No. 75 and the concurrence by Congress of said Presidential Proclamation may bé taken Judicial cognizance by this court pursuant to the ruling of the “Supreme Court in Barrioquinto vs. Fernandez, GR No. L-1738 promulgated on January 29, 1949; $. They applied for and have been granted Amnesty under and = 4 Pursuant to Proclamation No. 75 series of 2010, evidenced GER rigs | hue, Coy shi. LOSRS RENE REE ote tuniek OF COURT vby the. attached certified true copies of Certificates of Amnesty issued by the Ad Hoc Amnesty Committee of the Department of National Defense signed by the Honerabla Voltaire T.Gazmin, Secretary of National Defense; and 4. The dismissal of the instant case is in order in the light of the fact that any possible criminal liability on their part resulting from the incidents subject of the instant case have already been fully and completely extinguished by the grant of Amnesty to them. DISPOSITION The Revised Penal Code provides: “Art. 89. How criminal liability’ is totally extinguished - Criminal liability is totally extinguished: 1. xxx 2. xxx S._ By Amnesty, which completely extinguishes the penalty and all its effects”. scac sex impediment for this court to dismiss the instant case it appearing that the criminal liability of the accused-movants for the crime of Rebellion had already been extinguished, In view of the foregoing and finding the ground raised to be well-taken, the motions are Granted, Accordingly, the above-captioned case, docketed as Crim. Case No. 07-8126 for Rebellion, is ordered DISMISSED against the accused-movants. As a consequence of its dismissal, the bail bonds posted by the accused for their provisional fiberty are deemed cancelled. so ORDEREDY City of Makati, 7 September 2011.” s ELMOM. ALAMEDA Tul EMA/ marytior P vs, Trillanes GERI Grin . pel QuEy sie Al. “APES - VAEPNE PUR OF COURT Y PageRepublic of the Philippines REGIONAL TRIAL COURT National Capital Judicial Region ~ Branch 148, Makati City PEOPLE OF THE PHILIPPINES, -versus- CRIM CASE No. 03-2784 For: Coup d'etat CAPT. MILO MAESTRECAMPO, ET. AL., Accused, Acting on the "Motion to Dismiss” and finding merit on the grounds stated therein, that pursuant to Proclamation No. 75 issued on November 24, 2010 President Benigno S. Aquino III granted amnesty, entitled: “GRANTING AMNESTY TQ ACTIVE AND FORMER PERSONNEL CF THE ARMED FORCES OF THE PHILIPPINES, PHILIPPINE NATIONAL POLICE AND THEIR SUPPORTERS WHO MAY HAVE COMMITTED CRIMES PUNISHABLE UNDER THE REVISEC PENAL CODE, THE ARTICLES OF WAR OR OTHER LAWS IN CONNECTION WITH THE OAKWOOD MUTINY, THE MARINES STANDOFF AND THE MANILA PEN INCIDENT” Further, the accused-movants to wit: SEN. ANTONIO F. TRILLANES IV, GARY C, ALEJANO and JAMES A. LAYUG; submitted their Certificate of Amnesty issyed by the Ad Hoc Amnesty Committee of the Department of National Defense signed by Hon. Voltaire T. Gazmin, Secretary of National Defense, TRUE T2 FABORIGIny ve CA Sr Le ATTY. MARISREOOG Ra MaLake; vq Clerk of Cour RTC. Eranch 148. ue ANNEX ‘ft"WHEREFORE, this instant case against herein accused, namely | SEN. ANTONIO F. TRILLANES IV, GARY C. ALEJANO and JAMES A. LAYUG is hereby DISMISSED pursuant to the grant of amnesty to them in Proclamation”No, 75 dated November 24, 2010 by President Benigno’S..Aquino III. SO ORDERED. City of Makati, Philippines. September 21, 2011, Sia MA. RITA A. BASCOS SARABIA Acting Presiding Judge Ieee Mateati Oy Wey 4, , i Krone * | PUNONGHIMPILAN HUKBONG DAGAT NG PILIPINAS (Headquarters Philippine Navy) 2335 Pres. M. Rexas Boulevard, Manila OTNA Control Nr. _MAB-0-0707-04 : 2.8 AUG 2007 (Date) MAJOR SERVICE CLEARANCE TO WHOM IT MAY CONCERN: THIS IS TO CERTIFY that LT ANTONIO F TRILLANES O-11797 PN has been cleared of money/property accountabilities except as provided for in the remarks section as per available Tecofds of this Comffiand in connection with his loso Facto Resignation effective 06 February 2007. (GO Number 515 GHQ, AFP did 03 May 07) 202 Bryn - 4 MRS.\LEAH A PONGYAN \ Chief Accountant, Phiippine Navy hee 5 — 6 Peaaeeesaaresaeaee | CAPTANTONO HAGTUAL JR Pt ) CAPT BAYAN R GAERLAN PN(GSC) Commender, Philifpine Navy Finan oe) acta fc de NS for Intel. ,N2 (Date) FIVE 32007, REMARKS: Nor OCcupyet OF fae MIL GT Deleted eff as of O1 Nar Of ze { ae OF SENATOR TRILLANES, FoR THE FLAG orFiceR Ncommano, en: | Crk TUTE ED ‘ * TRUE-GOPY IMILITARY Guar TERS ceo Anvif ee : \ fo Antex "J Philippine Navy Finance Center NAVAL FINANCE SERVICE UNIT FORT BONIFACIO Bonifacio Naval Station Fort Bonifacio, Taguig City NFSUFB.0807-024 29 August 2007 SUBJECT: CERTIFICATE OF LAST PAYMENT 1. THIS IS TO CERTIFY that L7 ANTONIO F TRILLANES IV 0-11797 PN who resigned from the miltary service PN, AFP effective 06 February 2007 was last paid by this unit the following pay and allowances: PERIOD COVERED: 01 - 28 February 2007 Base Pay 217,334.00 AFP RSBS 860.70 Longevity Pay (8rd) 9,737.55 - MBAI PREMIUM 50,00 Subsistence Allowance 4,680,00 MBA GROUP INS(SGT) 6.00 Quarters Allowance 1650.00 WITHHOLDING TAX MEt 2,181.20 Clothing Allowance 200.00 PFIC MEDICARE 62.50 Pers Emerg Relief Allowance 500.00 PAG-IBIG FUND. 100.00 Laundry Allowance 60,00 PhOC DUES 25.00 Hazard Pay 120.00 MESS DEDUCTION (BNS) 4,680.00, Add! Compensn Allowance 500.00 PHILFLT MAS! 20.00 ADCOM 1,000.00 AFPSLAI CAPITAL CONT 2,000.00 GROSS PAY 227,781.55 MBAI ADDL PREM 180.40 ASSN MIUPOL RET INC 420,00 PNFC MC CLASS FUND 200.00 PNSLAI MULTI PRPSE LN 8,708.35 NET PAY 11,811.40 Total Deductions 216,170.18 2, THIS IS TO CERTIFY FURTHER that subect Officer was dropped from the paying juristiction of this unit effective 01 March 2007. 3. Subject Officer was deleted trom the PN, IPMS Payroll effectve 01 March 2007. Overpayment of Pay and Allowances for the period from 05 — 28 February 2007 in the total amount of Twenty Two Thousand Eight Hundred Twenty Pesos and 55/100 (P 22,820.55) only will be collected from any benefits due to him, Authenticated by: | OFFICE OF SENATOR TRILLANES) 2 Weer CERTIFIED po TRUECOPY, (CERTIFIED CORRECT: APPROVED BY: === —gyE POI, AdminArowex “KY T OF RATIONAL DEFENSE RAL EAI RMED FORCES OF THE PHILIPPINES MTR/vpl/ AGPOR? 3 May 2007 GENERAL ORD! NUMBER S15 it Chief of Staff daar LABIANG pte FICE OF SENATOR | CERTIFIEBY THE PRESIDENT OF THE PHILIPPINES PROCLAMATION NO.572 [REVOGATION OF THE DEPARTHENT OF NATIONAL DEFENSE AD HOC Pe dmit ee RESOLUTION NO 21) DATED JANUARY 34, 2011 INSOFARLAS IT SRANIED AMNESTY TO FORINCR LISG ANTON TRILLANES 17 “iwHteREAs, Secon 48; Atel Vit te, 1987 Constiuton expressy anos the Pisldot of te Ropu fe Phtppnes fart eet WHEREAS, ty vit of Procaaton Nol 75, sres of 2010, an ernsaty was rant EREAS, Oe eer era of to Armed Pres ct te Phin and Bratenc atonal Pace wel as nek sapparere wa have or may have caved Crino punishable under te Refsed Penal Code, he Arcesof War or oe laws Fr agen anh In rlatn er eden, te ly 27,2003 Oakood Nun, the Fofelay 2008 Haines Sland-O% and the November 29, 2007 Manila Peansda bene) Zoe Mapa ele, sroraied tat rest shal not covet fe, a= of {Situ enes agai chasly. an ote cies eammied Tor ereoal ond Hore tke precaution The nal deco or dermnationof the OND shallbe Copal ote orice of to Prosicet by ary pay tof applica: | WHEREAS, Procamation No. 75, seo of 2010 rovies tat ne concerned AFP and ED percetel wee upparers are reguted ean appliaton for amano, ‘ident wi tno Goparmont o Nasoal Dstense (OND) ad hae Commit: -=REAS, Sections 5, 6 snd 11 ofthe OND Ansety'Comnttee (DND-AC) Giccx_ Re December 24,2010, "The Rubs and Procedutes nt roeesing Senet argnstons purser ia Procamalion te 76 saris of 2010" requres ie epics pernly 8 ard ee i! en, Peratin ran a ‘xpecoly adit Bete gut fo to ees ca st Mun, eet ate ond ta Mais BeiovinbrsdertOND-AG Grea Ho, 4 fries euler applicants ofocot a prowous sama Inconsistent wh the ‘requrement of adnissln of Pat Gu “THe PRESIDENT OF THE PHILIPPINES. WHEREAS, Set 14 ef DND-AC Chula’ No, 1 mandates the Desly Chie of “stat fer Brsomcl JV AFP to ponde and crete a Seca io provde adnistave ‘Seistance toe Cannas rosiang and processing ot wpleabons for annesty SS onion tert and fe fecrdng of ins, rocepion of evgence and ‘inet Gocumersposanieg Gung daloravons end hess MEREAS, the Supreme Gout inthe case of Paoco of the Pips vs. Vera, I Gakroed tii and Mar Persosle redo 2. The Aired Forces of the Pilippines and the Phiipine Nationa Police aro ovdrod to employ alll east apprehend forme’ LTEG fale Tlanes 2 thal i pan be resorted 1th cetenton fc where ‘ite tn ncrceated for hf Stand ial fr themes he charged vn ‘Secon 3 fet Tis Proclamation shal iat imme. INWITNESS HEREOF, nave sgn hie Precldnaton and caused the seal of Repub of te hiippne obo aos to ‘DONE in the City of Marla, 31 day of August in tho yar of our Lord, lwo lead Orne Pree: ‘Ene Sela mao cues mea 4Republic of the Philippines ice Department of National Defense (hovex4 M DND Ad Hoc Amnesty Committee Camp Aguinaldo, Quezon City 05 January 2011 Chairman, DND Ad Hoc Amnesty Committee Camp Gen Emilio Aguinaldo, Quezon City 1. Reference: Presidential Proclamation Nr 75 dated 24 November 2010. 2. Submitted is the list of applicants for Amnesty for today, January , 2011: a. Officers 2LT EDGARDO R AGUILAR 0-135570 PN(M) 2LT LEOPOLDO D APILLANES JR 0-13746 PN(M) LTJG ARTURO S$ PASCUA JR 0-12615 PN LTJG CEFERINO M CHECA III 0-12841 PN QLT JONNELL P SANGALANG 0-13131 PN(M) ENS CESAR CARMEL P TAMBA 0-13358 PN 2LT JEOFFREY C TACIO 0-13137 PA LTSG ANTONIO F TRILLANES IV 0-11797 PN 7 2LT NORMAN SPENCER O LO 0-13817 PN(M) 40. LTSG ANDY G TORRATO 0-11863 PN 41. LTSG MANUEL D CABOCHAN 0-11923 PN 42. LTNORBERTO E SANTIAGO JR O-11974 PN 13. 2LT JEVEEHBOY N MACARUBBO 0-13431 PAF 14, LT BILLY S PASCUA 0-12911 PAF 15, 1LT FRANCISCO ASHLEY L ACEDILLO 0-12748 PAF 16, 1LT JONATHAN D COSTALES 0-12887 PN(M) 17. CPT GARY C ALEJANO 0-11830 PN(M) 48, CPT SEGUNDINO P ORFIANO JR O-11813 PAF 19, LT EUGENE LOUIE P GONZALEZ 0-11838 PN PENDREV = b. Enlisted Personnel 1. Cpl Edgar B Volasco 792657 PA 2. Opi Joey L Membreve 790884 PN(M) 3. SSq Francisco N Bosi Jr 788599 PN(M) 4. Cpl Bonifacio B Barrion 791680 PN(M) 5. Cpl Berting G Cabana 791781 PN(M) 6. Cpl Dennis F Lopez 809356 PN(M) 2. Cpl Danilo C Butial 791900 PN(M) 8. Cpi Leo G Gapayao 789140 PN(M) 9. — SqtJigger $ Paculba 812112 PN(M) 10. Cpl Lorenzo V Caranzo 796428 PN(M) 11. Sgt German M Linde 788659 PN(M) 12. Cpl Walter M Manalansan 791762 PN(M) 43.__ Cpl Roel C Molina 802148 PN(M)14. Pfc Abraham P Apostol 829472 PN(M) Sgt Ronald B Reyes 791637 PN(M) a5. 16. Cpl Ruel S Espenilla 824097 PN(M) 17. Pyt Jocil B Regulacion 829478 PN(M) 18. Cp! Emmanuel C Thador 816062 PA 19. Cpl Filomeno J Rarrirez 799486 PA 20. Cpl Carlo P Pillos 815525 PA c. PNP«0 d, Civillan-0 3. For information and reference.FORM NO. __ “APPLICATION FOR AMNESTY UNDER APPLICANT NO. PROCLAMATION NO. 75 DATED NOVEMBER 24. 2010 Rank __Famiylome Fest Name tsidee Name ecrrl ADQUD peared SAS Cosy Tcmisses O) snge LMamed Liwaowler | DiSeasrateaniuinAreulies | Tombee | SaimPace To eeat a Lueqiye. Hegy soma et 13. Complenan Ta, Eyes (Caep 5 Haz (ake) 1. Regen Ty osntiynng Maries Oren OF air Cert, 7 | TE APP Ont Assgaaent Gung Be] 1, Despuaon ERS Aan ined Beementsry Okscerdary Olenary Caress (Spent) 21, Nam of Nestot Kin: 22, Adiese otNewtol Kr 23. Relatonshia: a ‘24 Character Ralrences (Prominent residents of your hoclty) ‘25. Address of Character Reterence: a a 3 2 5 Haden moledpetcosted mt Ci ly 27, 2063 Oakwood Mutiny D Feteuaty 2006 Macnies Stand-O# QO Novemter 29, 2007 Peniaule Mania Matai kxdent NOTE: Anoleant shat suome.a narratan o tacts ct his nvolweneet)pavogban 26 anna A Thereby scknowiedge mat my Invevemantipenapalon nthe sebject inecents coniculed a Wolgtan a] be (987 ConstAion, corrinal Lams 2rd tha Arscles of War. thereby recavé my previous atements thal are contrary, It ary, to ths express admis olinvaleerrectipsctispation end gult. Rane Fest Nace (Print Name ath Sanatice) ate fiked: 28. Stas ct Case (Cintan Courts 42 aryl Pending} equned CiComicted Cdkemsset Atach pectin court eccrds Bi Sis of Casa (GOMER. | SD, Sats of Apphicare. Penang Ci Presently Deane CQvot Surencer CJOrer Speci) Daoguttes ‘31, Sus in Sardion: O Ceavactes DD Indcne Sevice 0 Finsing Status CSuspendec Oi Dirissea Ey Durie (te et Semssay 2.‘ certy Dial | hse cond end propared De loregatg dats and fie facts sueeshed y of involetmectprbelpaten’, and that the same are tue fo ne dest of my personal knewiedos. | finer cenfy mst Zs Agclicalion is hereby gomized 1 cennection aith my daure 1g aval ot he Amedty’as provised for in Procsmation No.7 sted Navezabes 24, 2010. Inowiinass hereot, Lave signed my maine ang atthad my then marks Fs ‘ny of Wenessed By: 1), 4____—___—_—___- ‘SUBSCRIBED AND SWORN to before me this.DECLARATION OF COMPLETENESS DECLARATION OF COE |, SEN. ANTONIO “SONNY” F. TRILLANES IV, hereby declare that the Pétition and the annexes thereof hereto submitted electronically in accordance with the Efficient Use of Paper Rule are complete and faithful electronic reproductions thereof filed with the Supreme Court. SEN. ANTONIO mee F. TRILLANES IV Petitioner-Declarant 05 September 2017 SUBSCRIBED AND SWORN to before me on this S*_ day of September 2018, affiant exhibiting to me his competent proof of identity in the form of his Senate Identification (ID) Card with Serial No. 2006-2007, bearing his photograph and signature, issued by the Philippine Senate with Expiry Date on 30 June 2019. i yh ATTYJOVINO.R. ANGE. Doc. No. _4)__; NOTARY PUBLIC Page No._4 5 NOTARML COMMISSION 17-08 Book No. _v__} UNTIL DECEMBER 31, 2018 Series of 2018. PTR NO. S826093/1BP NO. 1062667 30TH ISSUED IN PASAY CITY OW JAN, 3, 2078 CLE COMPRIANCE NO! V-0024151 10/25/41" ROLL OF ATTORNEYS No. 28764