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Republic of the Philippines

OFFICE OF THE OMBUDSMAN


Office of the Deputy Ombudsman for the Mindanao
Earth corner Libra Streets, GSIS Heights, Matina, Davao City

MARIA GERTRUDES SERRANO DEDUMO


MA. ETHEL SERRANO LUMOGDA
CARLOTA SERRANO NAVALES
JUVY SERRANO GUANSI
Complainants,
Docket No. OMB-M-A-20-0033

For: Abuse of Authority;


Neglect of Duty; Violation
of Section 5(a) of Republic
Act No. 6713

-AND-

Docket No. OMB-M-C-20-0018

For: Malversation of Public


Funds (Article 217 of the
Revised Penal Code);
Violation of Section 3 (a)
and (e) of Republic Act No.
3019; Violation of Republic
Act No. 8048
-versus-

DEPARTMENT OF SOCIAL WELFARE AND


DEVELOPMENT, ET AL.
Respondents.
x----------------------------------------//

ENTRY OF APPEARANCE AS COUNSEL FOR


RESPONDENT
with MOTION TO ADMIT COUNTER-AFFIDAVIT
OF RESPONDENT DEPARTMENT OF SOCIAL
WELFARE AND DEVELOPMENT (DSWD)

The undersigned respectfully enters his appearance as


counsel for RESPONDENT DSWD only for the submission of
the attached two (2) Counter-Affidavits for the

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aforementioned cases and moves for the admission of said
Affidavits, and avers THAT:

1. The undersigned respondent Department of Social


Welfare and Development (DSWD), is represented by
the Assistant Regional Director for
Administration RAMIL FELIAS JAMEN, with
authority from the Regional Director MITA CHUCHI
GUPANA-LIM thru Regional Special Order No.
00059, and who is a resident of Purok-2 Camote,
Brgy. Maon, Butuan City;

2. On 26 February 2020, the respondent received an


ORDER from the Office of the Honorable Ombudsman
for Mindanao to file its Counter Affidavit relative to
the aforementioned cases;

3. The DSWD filed its Motion for Extension of Time to


Submit Counter Affidavit and prayed that it be given
an additional period of ten (10) days from March 6,
2020, or/until March 15, 2020 within which to file its
Counter-Affidavit before the Honorable Office;

4. Regrettably, respondent and counsel were not able


to complete the respondent’s counter-affidavit on
March 15, 2020, and file the same on time as prayed
for, considering the respondent’s mandate to
respond on National Emergencies, since during this
period of time, the Philippines and the rest of the
world, is experiencing an extra-ordinary ordeal,
owing to the spread of Coronavirus Disease (COVID-
19);

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5. Nevertheless, herewith is the respondent’s
COUNTER-AFFIDAVITS.

PRAYER

WHEREFORE, premises considered, it is most


respectfully prayed that this Motion with attached COUNTER-
AFFIDAVITS of the Respondent, despite belated submission,
be admitted by the Office of the Honorable Ombudsman for
consideration in resolving this case.

Other reliefs just and equitable under the premises are


likewise prayed for.

Most respectfully submitted. March 18, 2020, Butuan


City, Philippines.

ATTY. GERAMER V. DURATO


Counsel/ Notary Public
2/F Jast Bldg. 926 Ochoa Ave.
Limaha, Butuan City
Email Address: regaille77@gmail.com

ROLL NO. 67741 I TIN NO. 938-430-119


IBP NO. 052695 / 01-10-20 / Butuan City
PTR NO. 1888529 / 01-13-20 / Butuan City
NOTARIAL COMMISSION NO. 08-01-2020
MCLE Compliance No. VI-0007906

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