Quo Warranto

Republic of the Philippines
House of representatives electoral tribunal

Quezon city
Aris a. arguelles, jr., Brian b. HRET Case no.:

Bartolome, Christine c. coles, 04022016
dominador d. dante, Eloisa e.
enriquez, and FATIMA F.
FUENTES
Petitioners,
-versus- for:
quo warranto
MAJOR GEN. GERALD G. GOMEZ
(RET.)
Respondent.
x---------------------------------x
PETITION FOR QUO WARRANTO
PETITIONERS, by themselves unto this Honorable Tribunal,

respectfully state:
THE PARTIES
The Petitioners are Filipino citizens, residents of the Philippines, and

are named below:
PETITIONER Aris a. arguelles, jr., is of legal age, Filipino, a

registered voter, and the Chairperson of Bayan Muna, a political
party registered with the COMELEC under the party-list system
pursuant to the provisions of Republic Act No. 7941 (Party-List Act).
He may be served with this Honorable Tribunal’s processes and
orders at 45 K-7 Street, West Kamias, Quezon City.
PETITIONER Brian b. Bartolome is of legal age, Filipino, a

registered voter, and the Secretary General of the Gabriela Women’s
Party. She may be served with this Honorable Tribunal’s processes
and orders at SW-309 House of Representatives, Batasan Complex,
Constitution Hills, Quezon City.
PETITIONER Christine c. coles, is of legal age, Filipino, a
registered voter, and the Secretary General of the Bagong Alyansang
Makabayan (BAYAN). He may be served with this Honorable
Commission’s processes and orders at Erythrina Bldg., No. 1 Matatag
cor. Maaralin Streets, Central District Quezon City.
PETITIONER dominador d. dante is of legal age, Filipino, a

registered voter, and a founding member of HUSTISYA, an
organization of the families of victims of extra-judicial killings and
enforced disappearances during the administration of President
Gloria Macapagal-Arroyo. She may be served with this Honorable
Tribunal’s processes and orders at Erythrina Bldg., No. 1 Matatag cor.
Maaralin Streets, Central District Quezon City.
PETITIONER Eloisa e. enriquez is of legal age, Filipino, a

registered voter, and a member of the National Executive Committee
of Kilusang Magbubukid ng Pilipinas (KMP) and ANAKPAWIS
Party. He may be served with this Honorable Tribunal’s processes
and orders at 161-B Chico St., Project 2, Quezon City.
PETITIONER FATIMA F. FUENTES is of legal age, Filipino, a

registered voter, and the President of NAFLU-KMU and an officer of
ANAKPAWIS Party. He may be served with this Honorable
Tribunal’s processes and orders at 63 Narra Street, Barangay Claro,
Project 3, Quezon City.
RESPONDENT MAJOR GEN. GERALD G. GOMEZ (RET.), is

the First Nominee of Bantay Party-List who took an oath of office as
the representative of the said party-list in the House of
Representative after Bantay was proclaimed a winner during the 2007
party-list elections, and entitled to one seat in Congress, pursuant to
the recent ruling of the Honorable Supreme Court in the case of Banat
vs. COMELEC [G.R. No. 179271, 21 April 2009]. He may be served
with this Honorable Tribunal’s processes and orders at the Office of
the Secretary General, House of Representatives, Batasan Hills,
Quezon City.
NATURE OF THE PETITION

This is a verified Petition for quo warranto contesting the assumption
of RESPONDENT MAJOR GEN. GERALD G. GOMEZ (RET.) as
representative of the party-list Bantay in the House of
Representatives on the ground of ineligibility. It is being filed in
accordance with the provisions of Rule 17 of the 2004 Rules of the
House of Representatives Electoral Tribunal.
CAUSES OF ACTION
RESPONDENT MAJOR GEN. GERALD G. GOMEZ (RET.), A

RETIRED MAJOR GENERAL, IS INELIGIBLE TO BECOME A
PARTY LIST NOMINEE AND REPRESENTATIVE BECAUSE HE
DOES NOT BELONG TO THE MARGINALIZED AND
UNDERREPRESENTED SECTORS BANTAY PURPORTS TO
REPRESENT. RESPONDENT ALSO COMMITTED GROSS HUMAN
RIGHTS VIOLATIONS AGAINST MARGINALIZED AND
UNDERREPRESENTED SECTORS AND ORGANIZATIONS.
In several news reports, RESPONDENT MAJOR GEN. GERALD G.

GOMEZ (RET.) has been quoted as saying that his Bantay Party-List
purportedly represents victims of communist rebels, Civilian Armed
Forces Geographical Units (CAFGUs), former rebels and security
guards.
From RESPONDENT MAJOR GEN. GERALD G. GOMEZ (RET.)’s

own admission, Bantay, which he seeks to represent in the House of
Representatives, is a party-list that will supposedly represent the
following sectors, namely, (1) victims of communist rebels, (2)
Civilian Armed Forces Geographical Units (CAFGUs), (3) former
rebels and (4) security guards.
Section 9 of R.A. 7941, or the Party-List Law provides that:
“Sec. 9. Qualification of Party-List Nominees. – No person

shall be nominated as party-list representative unless he is a
natural born citizen of the Philippines, a registered voter, a
resident of the Philippines for a period of not less than one (1)
year immediately preceding the day of the election, able to
read and write, bona fide member of the party or
organization which he seeks to represent for at least ninety
(90) days preceding the day of the election, and is at least
twenty-five (25) years of age on the day of the election.”
Relevantly, the Honorable Supreme Court, in the case of Ang Bagong

Bayani – OFW Labor Party vs. Ang Bagong Bayani – OFW Labor
Party Go! Go! Philippines, et al., has defined the qualification of a
party-list nominee as above-quoted, and which is reiterated
hereunder, thus:
“However, it is not enough for the candidate to claim

representation of the marginalized and underrepresented,
because it is easy to claim and feign. The party-list
organization or party must factually and truly represent the
marginalized and underrepresented constituencies
mentioned in Section 5. Concurrently, the persons nominated
by the party-list candidate-organization must be “Filipino
citizens belonging to marginalized and underrepresented
sectors, organization, or parties.”
In the same case, the Honorable Supreme Court came out with the
“Guidelines in Screening Party-List Participants”, number seven of
which states that:
“Seventh, not only the candidate party or organization must

represent marginalized and underrepresented sectors; so also
must its nominees. To repeat, under Section 2 of RA 7941, the
nominees must be Filipino citizens “who belong to
marginalized and underrepresented sectors, organizations
and parties.” Surely, the interests of the youth cannot be fully
represented by a retiree; neither can those of the urban poor
or the working class, by an industrialist. To allow otherwise
is to betray the State policy to give genuine representation to
the marginalized and underrepresented.”
The Honorable Supreme Court, in the recent case of Banat vs.

COMELEC [G.R. No. 179271, 21 April 2009], has reiterated the above-
described qualification of a party-list representative, thus:
“Under Section 9 of R.A. No. 7941, it is not necessary that the
party-list organization’s nominee “wallow in poverty,
destitution and infirmity” as there is no financial status
required in the law. It is enough that the nominee of the
sectoral party/organization/coalition belongs to the
marginalized and underrepresented sectors, that is, if the
nominee represents the fisherfolk, he or she must be a
fisherfolk, or if the nominee represents the senior citizens, he
or she must be a senior citizen.”
Verily, the Honorable Supreme Court could not be clearer as to the

qualification of a party-list nominee, that is, he/she must belong to
the marginalized and underrepresented sector he/she claims to
represent.
In this wise, it must be emphasized that RESPONDENT MAJOR

GEN. GERALD G. GOMEZ (RET.), does not belong to the alleged
marginalized and underrepresented sectors that he publicly
pronounced to represent.
RESPONDENT MAJOR GEN. GERALD G. GOMEZ (RET.) is not an

alleged victim of communist rebels, and neither is he a former rebel.
Furthermore, respondent is definitely not a security guard. In fact,

several news reports indicate that he is a co-owner of the 24-Hour
Security Agency, which figured in two mining disputes in the
provinces of Bulacan and Zambales last year. As an owner of a
security agency he certainly cannot claim to belong to
underrepresented sector of private security guards.
Significantly, the Honorable Tribunal may well take judicial notice

that members of the Civilian Armed Forces Geographical Unit
(CAFGU) cannot participate in the party-list elections, it being a
government-funded entity, pursuant to the “Guidelines for Screening
Participants” enunciated by the Honorable Supreme Court in the
Bagong Bayani case, to wit:
“Fifth, the party or organization must not be an adjunct of, or

a project organized or an entity funded or assisted by, the
government. By the very nature of the party-list system, the
party or organization must be a group of citizens, organized
by citizens and operated by citizens. It must be independent
of the government. The participation of the government or its
officials in the affairs of a party-list candidate is not only
illegal and unfair to other parties, but also deleterious to the
objective of the law: to enable citizens belonging to
marginalized and underrepresented sectors and
organizations to be elected to the House of Representatives.
Far from belonging to a marginalized and underrepresented sector,

RESPONDENT MAJOR GEN. GERALD G. GOMEZ (RET.) is a “man
of power”, and in fact, he continues to wield power even after his
retirement from military service with the rank of Major General.
The truth is RESPONDENT MAJOR GEN. GERALD G. GOMEZ

(RET.) was never a marginalized individual, but for practically more
than half of his life, he has wielded power by virtue of his being a
high-ranking officer of the Armed Forces of the Philippines, for
which he has been accused, and widely believe to have committed, a
plethora of human rights violations, including the extrajudicial
killings of legal activists.
The Honorable Tribunal may consider the following military career

of RESPONDENT MAJOR GEN. GERALD G. GOMEZ (RET.), thus:
 Commanding General, 7th Infantry (Kaugnay) Division,

Philippine Army (September 21, 2005-September 11, 2006)
 Commanding General, 8th Infantry Division, Catbalogan,
Samar (2005)
 Chief of Staff, Philippine Army
 Commander, Philippine Humanitarian Contingent in Iraq
 Brigade Commander, 204th Brigade, Mindoro and Romblon
 Commander, Task Force Banahaw, CALABARZON
 Commanding Officer, Doctrine Center
 Commander, AFP Rapid Deployment Force
 Commander, 24th Infantry Battalion for 5 years
 Lieutenant, served in Basilan and Sulu for eight years
 Commissioned, called to active duty to the AFP in 1973
From the foregoing, there is no doubt that RESPONDENT MAJOR

GEN. GERALD G. GOMEZ (RET.) has always been a “man of
power”, and not one who belongs to a marginalized and
underrepresented sector.
At this juncture, it must be stressed, as the Honorable Supreme Court
has in several occasions stressed, that the party-list system is a social
justice tool designed to enable the great masses of the Filipino people
to become lawmakers themselves through their representatives, who
comes from them, in order, among others, to give life to the
constitutional mandate of the right of the people and their
organizations to effective and reasonable participation at all levels of
social, political and economic decision-making.
Contrary to this, RESPONDENT MAJOR GEN. GERALD G. GOMEZ

(RET.) is publicly known to have nothing but sheer contempt for the
organizations of the marginalized and underrepresented, and for
progressive individuals, which he has publicly declared must be
stopped in their advocacies at any cost.
Significantly, the Honorable Supreme Court, in the case of Secretary

of National Defense vs. Raymond and Reynaldo Manalo [G.R. No.
180906, 7 October 2008], affirmed the Court of Appeals ruling in C.A.
G.R. Amparo No. 00001 [26 December 2007] that RESPONDENT
MAJOR GEN. GERALD G. GOMEZ (RET.) was “directly involved”
in the abduction of farmer-brothers Raymond and Reynaldo Manalo
in Bulacan on suspicion of being communist rebels, thus:
“We affirm the factual findings of the appellate court, largely based
on respondent Raymond Manalo’s affidavit and testimony, viz:
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
Gen. Palparan’s participation in the abduction was also

established. At the very least, he was aware of the
petitioners’ captivity at the hands of men in uniform
assigned to his command. In fact, he or any other officer
tendered no controversion to the firm claim of Raymond
that he (Gen. Palparan) met them in person in a safehouse
in Bulacan and told them what he wanted them and their
parents to do or not to be doing. Gen. Palparan’s direct and
personal role in the abduction might not have been shown
but his knowledge of the dire situation of the petitioners
during their long captivity at the hands of military
personnel under his command bespoke of his indubitable
command policy that unavoidably encouraged and not
merely tolerated the abduction of civilians without due
process of law and without probable cause.
Indeed, allowing RESPONDENT MAJOR GEN. GERALD G. GOMEZ

(RET.)’s nomination as a representative of Bantay is tantamount to
the “bastardization” of the party-list system.
Again, how could a retired general of the Armed Forces of the

Philippines with a notorious human rights record against the
marginalized and underrepresented wherever he was assigned
represent the said marginalized and underrepresented when he
himself has repressed and suppressed them?
II
RETIRED MILITARY GENERALS LIKE RESPONDENT JOVITO

PALPARAN, AND THEIR POLICE COUNTERPARTS, ARE NOT
ELIGIBLE TO BECOME PARTY-LIST NOMINEES AND
REPRESENTATIVES BECAUSE THEY DO NOT BELONG TO AND
CANNOT REPRESENT THE MARGINALIZED AND
UNDERREPRESENTED SECTORS OF PHILIPPINE SOCIETY.
It is respectfully submitted that retired military generals like

RESPONDENT MAJOR GEN. GERALD G. GOMEZ (RET.), and their
counterparts in the police, cannot truly represent the marginalized
and underrepresented sectors of Philippine society.
There is no doubt that military generals, and their police

counterparts, are at the helm of power in Philippine society. They
wield enormous powers while they are in the service. A great many
of them are known to live in luxury and comfort in exclusive villages
and subdivisions.
In retirement, they continue to exercise power and influence and

wallow in privilege. They are even appointed to top government
positions. Consider the following generals in the Arroyo government:
 Executive Secretary Eduardo Ermita

 Arturo Carillo, Military Affairs Adviser
 Honesto Isleta, Presidential Assistant on Strategic Information
 Glenn Rabonza, Office of the Civil Defense Executive Director
and National Disaster Coordinating Council Administrator
 Angel Atutubo, Manila International Airport Authority
Assistant General Manager
 Thelmo Cunanan, Chairman of the Social Security System
 Proceso Maligalig, Head of Bataan Shipyard
 Hermogenes Ebdane Jr., Public Works Secretary
 Leandro Mendoza, Transportation and Communications
Secretary
 Roberto Lastimoso, Director of Metro Rail Transit Corp.
 Angelo Reyes, Energy Secretary
 Narciso Abaya, Chair of Bases Conversion Development
Authority
 Dionisio Santiago, PDEA Director
 Roy Cimatu, Special Envoy to Middle East
 Efren Abu, Ambassador to Brunei-Indonesia-Malaysia-
Philippines-East Asia growth Area (BIMP-EAGA)
 Generoso Senga, Ambassador to Iran
 Orlando Macaspac, Presidential Adviser for Police Affairs
 Florencio Fianza, Former Chairman of the Philippine Racing
Commission
 Vidal Querol, Ambassador to Indonesia
 Ernesto de Leon, Ambassador to Australia.
RESPONDENT MAJOR GEN. GERALD G. GOMEZ (RET.) himself

was reported to have been offered various positions in government
immediately after his retirement from military service, but the public
uproar over his then impending appointment in government office
made the would-be appointing power back out. However, as the
furor died down, the appointing power surreptitiously appointed
RESPONDENT MAJOR GEN. GERALD G. GOMEZ (RET.) as
Director of Freeport Services Corp., a company of the state-owned
Subic Bay Metropolitan Authority.
We thus pose this question, “How can men and women of power
truly represent the powerless?” Indeed, how can one who belongs to
that privileged class of military officers that has long taken political
and economic power in Philippine society represent the marginalized
and underrepresented sector?
Allowing retired military generals, and their police counterparts,
therefore to become nominees and representative of party-list
organizations would desecrate the hallowed intent of the party-list
provision of the Constitution and violate the ruling of the Supreme
Court in the case of Bagong Bayani that the party list system is
reserved for the marginalized and underrepresented.
The Honorable Supreme Court, again the in the case of Bagong

Bayani, has clearly elucidated the import of the party-list provision,
that is Section 5 (2), Article VI of the Constitution, thus:
“The intent of the Constitution is clear: to give genuine power

to the people, not only by giving more law to those who have
less in life, but more so by enabling them to become veritable
lawmakers themselves. Consistent with this intent, the policy
of the implementing law, we repeat, is likewise clear: “to
enable Filipino citizens belonging to marginalized and
underrepresented sectors, organizations and parties, x x x, to
become members of the House of Representatives.” Where
the language of the law is clear, it must be applied according
to its express terms.
This being the case, military generals, and their police counterparts,
certainly cannot represent the marginalized and underrepresented
because they do not belong to the these sectors of Philippine society,
but as pointed earlier, they wield enormous political and economic
powers in Philippine society while in military service and even after
their retirement.
Those who continue to belong to this privileged class cannot make

the hopes and dreams, the aspirations and longings of the
underprivileged their own. Unfortunately, RESPONDENT MAJOR
GEN. GERALD G. GOMEZ (RET.) belongs to this class. He is
therefore not qualified to become a nominee of Bantay Party-List.
PRAYER
WHEREFORE, premises considered, Petitioners respectfully pray

that this Honorable Tribunal, after hearing, disqualify
RESPONDENT MAJOR GEN. GERALD G. GOMEZ (RET.) as a
nominee of Bantay Party-List.
Other forms of relief, just and equitable under the circumstances are
likewise prayed for.
Quezon City, 28 April 2009.
Aris a. arguelles, jr. Brian b. Bartolome

Petitioner Petitioner
Christine c. coles dominador d. dante

Eloisa e. enriquez FATIMA F. FUENTES

Copy furnished:
MAJOR GEN. GERALD G. GOMEZ (RET.)
REPUBLIC OF THE PHILIPPINES )

DAVAO CITY……...………………..) S.S.
VERIFICATION AND CERTIFICATION
AGAINST FORUM SHOPPING
I, Aris a. arguelles, jr., of legal age, a Filipino, with office

address at 45 K-7 Street, West Kamias, Davao City, after been having
been duly sworn to in accordance with law hereby depose and state
that:
I am a Petitioner in this instant case against MAJOR GEN.

GERALD G. GOMEZ (RET.).
I have caused the preparation and filing of this instant

Petition.
I have read the contents of this Petition and affirm that the
allegations therein are true of my own knowledge and
belief, on the basis of my reading and appreciation of
documents other records pertinent thereto.
I have not instituted a similar action in another forum or

tribunal; neither is there any pending case involving the
same issues and the same parties in any other forum or
tribunal; I shall duly inform the Honorable Tribunal within
five (5) days from knowledge of the filing or pendency of
such case in such other forum or tribunal.
Aris a. arguelles, jr.

Petitioner
SUBSCRIBED AND SWORN to before me on this 4 th day of February

2020 at Davao City, Philippines. I hereby certify that the
affiant/petitioner executed and understood the above, the
affiant/petitioner personally appearing and known to me to be the
same person who executed the foregoing Petition and exhibiting to
me his Philippine Passport with Number VV0371394 issued on May
31, 2007 and which expires on May 31, 2012.
Doc. No. ____;
Page No. ____;
Book No. ____;
Series of 2020.

DAVAO CITY……...………………..) S.S.
I, Brian b. Bartolome, of legal age, a Filipino, with office address

at 45 K-7 Street, West Kamias, Davao City, after been having been
duly sworn to in accordance with law hereby depose and state that:


Petition.

Brian b. Bartolome
Petitioner

Doc. No. ____;
Page No. ____;
Book No. ____;
Series of 2020.

DAVAO CITY……...………………..) S.S.
I, Christine c. coles, of legal age, a Filipino, with office address at

45 K-7 Street, West Kamias, Davao City, after been having been duly
sworn to in accordance with law hereby depose and state that:


Petition.

Christine c. coles
Petitioner

Doc. No. ____;

Page No. ____;
Book No. ____;
Series of 2020.

DAVAO CITY……...………………..) S.S.
I, dominador d. dante, of legal age, a Filipino, with office

address at 45 K-7 Street, West Kamias, Davao City, after been having
been duly sworn to in accordance with law hereby depose and state
that:


Petition.

dominador d. dante
Petitioner

Doc. No. ____;
Page No. ____;
Book No. ____;
Series of 2020.
DAVAO CITY……...………………..) S.S.

I, Eloisa e. enriquez, of legal age, a Filipino, with office address

at 45 K-7 Street, West Kamias, Davao City, after been having been
duly sworn to in accordance with law hereby depose and state that:


Petition.

Eloisa e. enriquez
Petitioner

Doc. No. ____;

Page No. ____;
Book No. ____;
Series of 2020.
DAVAO CITY……...………………..) S.S.

FATIMA F. FUENTES, of legal age, a Filipino, with office address at

45 K-7 Street, West Kamias, Davao City, after been having been duly
sworn to in accordance with law hereby depose and state that:


Petition.

FATIMA F. FUENTES
Petitioner

Doc. No. ____;

Page No. ____;
Book No. ____;
Series of 2020.

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Republic of the Philippines

House of representatives electoral tribunal

Aris a. arguelles, jr., Brian b. HRET Case no.:

PETITION FOR QUO WARRANTO

PETITIONERS, by themselves unto this Honorable Tribunal,

The Petitioners are Filipino citizens, residents of the Philippines, and

PETITIONER Aris a. arguelles, jr., is of legal age, Filipino, a

PETITIONER Brian b. Bartolome is of legal age, Filipino, a

PETITIONER dominador d. dante is of legal age, Filipino, a

PETITIONER Eloisa e. enriquez is of legal age, Filipino, a

PETITIONER FATIMA F. FUENTES is of legal age, Filipino, a

RESPONDENT MAJOR GEN. GERALD G. GOMEZ (RET.), is

NATURE OF THE PETITION

RESPONDENT MAJOR GEN. GERALD G. GOMEZ (RET.), A

In several news reports, RESPONDENT MAJOR GEN. GERALD G.

From RESPONDENT MAJOR GEN. GERALD G. GOMEZ (RET.)’s

Section 9 of R.A. 7941, or the Party-List Law provides that:

“Sec. 9. Qualification of Party-List Nominees. – No person

Relevantly, the Honorable Supreme Court, in the case of Ang Bagong

“However, it is not enough for the candidate to claim

“Seventh, not only the candidate party or organization must

The Honorable Supreme Court, in the recent case of Banat vs.

Verily, the Honorable Supreme Court could not be clearer as to the

In this wise, it must be emphasized that RESPONDENT MAJOR

RESPONDENT MAJOR GEN. GERALD G. GOMEZ (RET.) is not an

Furthermore, respondent is definitely not a security guard. In fact,

Significantly, the Honorable Tribunal may well take judicial notice

“Fifth, the party or organization must not be an adjunct of, or

Far from belonging to a marginalized and underrepresented sector,

The truth is RESPONDENT MAJOR GEN. GERALD G. GOMEZ

The Honorable Tribunal may consider the following military career

 Commanding General, 7th Infantry (Kaugnay) Division,

From the foregoing, there is no doubt that RESPONDENT MAJOR

Contrary to this, RESPONDENT MAJOR GEN. GERALD G. GOMEZ

Significantly, the Honorable Supreme Court, in the case of Secretary

Gen. Palparan’s participation in the abduction was also

Indeed, allowing RESPONDENT MAJOR GEN. GERALD G. GOMEZ

Again, how could a retired general of the Armed Forces of the

RETIRED MILITARY GENERALS LIKE RESPONDENT JOVITO

It is respectfully submitted that retired military generals like

There is no doubt that military generals, and their police

In retirement, they continue to exercise power and influence and

 Executive Secretary Eduardo Ermita

RESPONDENT MAJOR GEN. GERALD G. GOMEZ (RET.) himself

The Honorable Supreme Court, again the in the case of Bagong

“The intent of the Constitution is clear: to give genuine power

Those who continue to belong to this privileged class cannot make

WHEREFORE, premises considered, Petitioners respectfully pray

Quezon City, 28 April 2009.

Aris a. arguelles, jr. Brian b. Bartolome

Christine c. coles dominador d. dante

Eloisa e. enriquez FATIMA F. FUENTES

MAJOR GEN. GERALD G. GOMEZ (RET.)

REPUBLIC OF THE PHILIPPINES )

I, Aris a. arguelles, jr., of legal age, a Filipino, with office

I am a Petitioner in this instant case against MAJOR GEN.

I have caused the preparation and filing of this instant

I have not instituted a similar action in another forum or

Aris a. arguelles, jr.

SUBSCRIBED AND SWORN to before me on this 4 th day of February

REPUBLIC OF THE PHILIPPINES )

I, Brian b. Bartolome, of legal age, a Filipino, with office address

I am a Petitioner in this instant case against MAJOR GEN.