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Republic of the Philippines

ENERGY REGULATORY COMMISSION


San Miguel Avenue, Pasig City

IN THE MATTER OF THE


JOINT APPLICATION FOR
APPROVAL OF THE POWER
SUPPLY AGREEMENT
BETWEEN MANILA
ELECTRIC COMPANY AND
EXCELLENT ENERGY
RESOURCES INC. WITH
MOTION DSFOR
CONFIDENTIAL
TREATMENT OF
INFORMATION
ERC CASE NO. 2021-021 RC

MANILA ELECTRIC
COMPANY (“MERALCO”)
and EXCELLENT ENERGY
RESOURCES INC. (“EERI”),

Applicants
.
x ---------------------x

EX-PARTE MANIFESTATION AND MOTION


Applicant EXCELLENT ENERGY RESOURCES INC. (“EERI”),
through the undersigned counsels and unto this Honorable
Commission, most respectfully state:

On 19 May 2020 EERI received a copy of the Comment and


Opposition (“Comment”) of Power for People Coalition (“P4P”) et.al.,
dated 28 April 2021.

In compliance with the directive given by the Honorable


Commission concerning the submission of the corresponding
responsive pleading thereto, EERI hereby adopts the “Reply (To
Comment and Opposition) dated 18 May 2021 filed by Co-Applicant
MERALCO as its reply to the Comment of P4P in this case.
Ex-Parte Manifestation and Motion
MERALCO & EERI
ERC Case No. 2021-021 RC

PRAYER

WHEREFORE, premises considered, EERI hereby respectfully


prays that the instant Ex-parte Manifestation and Motion be duly
noted and to be favorably considered in the dismissal of the
Comment and Opposition of P4P.

Other reliefs just and equitable under the circumstances are


likewise prayed for.

Respectfully submitted.

Mandaluyong City for Pasig City, 28th May 2021.

EXCELLENT ENERGY RESOURCES INC.

By:

JUPITER M. CABAGUIO 
23 Floor, San Miguel Properties Centre, 
rd

No. 7 St. Francis Street, Mandaluyong City 


Telephone No. (02) 8702-4512 / 0917-8034173
jcabaguio@smcgph.sanmiguel.com.ph 
PTR No. 4577718 / 07 January 2021 / Mandaluyong City 
IBP No. 06372 / Lifetime / Makati City 
MCLE Compliance No. VI-0015891/ 13 December 2018
Roll No. 47112 
 

 
 AVELINO G. CEDO III 
23 Floor, San Miguel Properties Centre, 
rd

No. 7 St. Francis Street, Mandaluyong City 


Telephone No. (02) 8702-4509 / acedoiii@smcgph.sanmiguel.com.ph
PTR No. 4580603 / 07 January 2021 / Mandaluyong City 
IBP No. 010380 / Lifetime / PPLM 
MCLE Compliance No. VI-0011960 / 03 September 2018   
Roll No. 54500 

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Ex-Parte Manifestation and Motion
MERALCO & EERI
ERC Case No. 2021-021 RC

EXPLANATION OF FILING AND SERVICE


BY ELECTRONIC MEANS

In view of the prevailing community quarantine being


implemented by the government, the undersigned counsel
respectfully manifests that the foregoing pleading will be filed
/served by electronic means pursuant to Rule 10 of ERC’s Rules of
Practice and Procedure and ERC Resolution No. 9, Series of 2020,
with reservation for further compliances and/or utilization of other
means possible/available as maybe necessary in order to ensure the
service and filing under the attendant circumstances.

JUPITER M. CABAGUIO

Copy furnished:

ATTY. FRANCIS DINO S. ANTONIO


ATTY. RAYMOND B. YAP
ATTY. ISAGANI C. CORUÑA II
ATTY. MA. ELISHA S. ELORIAGA
Counsels for Manila Electric Company
Lopez Building, Ortigas Avenue
Brgy. Ugong, Pasig City.
E-mail address: regaffairs@meralco.com.ph

ATTY. JOSE AARON PEDROSA, JR.


ATTY. ALENZ AVRIL DE TORRES
ATTY. ANA LOURDES COSME
ATTY. MA. ELISHA S. ELORIAGA
Counsels for P4P et.al
23-B Marunong Street, Barangay Central, Quezon City 1100
E-mail address:
pedrosalaw2013@gmail.com
aapdetorres@ceedphilippines.com
alcosme.ceedph@gmail.com

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