Republic of the Philippines

Province of Cagayan
SANGGUNIANG PANLALAWIGAN
Tuguegarao City, Cagayan

CORAZON “CORING” M. GARCIA,

MICHAEL M. GARCIA, RODRIGO
“MANNY” GARCIA and MARLON B.
ARQUERO,
Complainants,
ADMIN. CASE No. _______
-vs-

S.B. AMBROCIO V. PENA,

Respondent,
X - - - - - X

ADMINISTRATIVE COMPLAINT
Complainants, under oath, state THAT:

1. Complainants are all residents Nabbialan, Amulung West, Cagayan and

they may served with notices and process in the said address;

2. Respondent is likewise a resident of the same barangay and an incumbent

member of the Municipal Council of the Municipality of Amulung, Cagayan;

3. Complainants hereto accuse the Respondent for Grave Misconduct,

Oppression, Being Notoriously Undesirable, Disgraceful and Immoral
Conduct, and Violation of Law Amounting to Crime under the Revised Penal
Code committed as follows:

That on or about 6:00AM of May 17, 2009, at Barangay Nabbialan,

Municipality of Amulung, Province of Cagayan, incumbent Sangguinian
Bayan Member AMBROCIO V. PENA, conspiring with his two (2) sons,
namely: EMMANUEL “Not-Not” PENA and EMMANUELITO “Pong-
Pong” PENA and other relatives, namely: DENNIS PENA; BONG PENA;
ARY PENA; RAYMUND PENA; RAY PARAGUA; TOM PENA; and
ABE PENA, helping one another, armed with bolos and other weapons,
with intent to kill and intent to cause damage to the house of the
Complainant Corazon Garcia, through threat, intimidation and use of
violence, did there willfully and unlawfully surrounded the house
Complainant Corazon Garcia, hurling stones and wood thereat and with
attempt to enter inside the said house to cause injury to the Complainants
who are then inside and within its premises, directing his companions and
uttering the words “sirreken yu ti balay ni coring ta patayin yu isuda,
salikawlawan yu, haan yu ituluk nga adda rumuar, patayin yu isuda,
pang one hundred cavans lang ti biag da, saan ku nga meybayad ti
sangaribu cavan nga irik ku” which caused much alarm and fear to the
occupants of the house of Corazon Garcia and causing injury to
Complainant Michael M. Garcia as well as damages to the house and store
of Complainant Corazon Garcia.
 That having failed to gain entry inside the house of Corazon Garcia,
Sangguinian Bayan Member Ambrocio V. Pena and with his group went
to the house of Complainant Marlon B. Arquera surrounded the same and
uttered the words “Palawlawan tayu ti balay ni Marlon ta patayin tayu,
saan yu ituluk nga rumuar nga sibibiag, patayin tayu ta bayadak biag
na uary manu, sika Marlon, pumanaw ka ditoy Nabbialan nu kayat mu
pay ti agbiag, ta uray taltalun ti pakakitaan mi kenka ket patayin daka”,
and they thereafter entered the house of Complainant Marlon Arquera
against his will and consent and caused damage to the house as well the
television owned by the Complainant which acts and utterances caused
much alarm and fear to the occupants of the said house.

4. We have personal knowledge of the foregoing acts committed by the

Respondent and that in support of our administrative complainant, we are
attaching hereto our affidavits and the affidavits of our witnesses to form part
of this administrative complaint;

5. For the purpose of complying with standing rules and procedures in

administrative cases, we hereby declare:

a) We have not instituted similar administrative complaint against the

afore-named person arising from the same facts and circumstances before
other administrative tribunal or agency except a criminal case of Attempted
Murder before the Provincial Prosecutor’s Office of Cagayan docketed as
NPS Docket No. II-02-INV-09E-151 entitled Marlon Arquero vs. SB
Ambrosio Pena for Attempted Murder;

b) No similar administrative complaint is pending before any

administrative tribunal;

c) Should we learn that a similar complaint is filled or pending against the

afore-named in another tribunal, we undertake to notify the administrative
tribunal handling this case within five (5) days from knowledge thereof.

WHEREFORE, it is most respectfully prayed of this Honorable Body that

foregoing administrative complaint be treated as such pursuant to the Local
Government Code of 1991 and other administrative rules of this Honorable Body.

Other reliefs and equitable under the premises are likewise prayed for.

Dated this 4th day of June 2009 at Tuguegarao City, Cagayan.

CORAZON “CORING” M. GARCIA MICHAEL M. GARCIA

RODRIGO “MANNY” GARCIA MARLON B. ARQUERO

Republic of the Philippines )
Province of Cagayan ) SS
Tuguegarao City )

SUBSCRIBED AND SWORN to before me this 3rd day of June 2009 at

Tuguegarao City, Cagayan.

Doc. No. _____;

Page No. _____;
Book No. _____;
Series of 2009

CERTIFICATION

I CERTIFY that I have personally examined the Affiant/Complainant and I

am satisfied that she executed the foregoing statements freely and voluntarily.