Republic of the Philippines SUPREME COURT Manila En Banc x x MA. CERES P. DOYO, JOSEFA ANDRES - MAGLIPON MARCELO, MARIA A. RESSA, RACHEL E. KHAN, MARIA ROSARIO. F. HOFILENA, LILIBETH SOCORRO FRONDOSO, MARIA TERESA D. VITUG, MARIO S. NERY, JR., BEATRICE Ps PUENTE, FLORANGEL ROSARIO-BRAID, FRANCIS N. PANGILINAN, LEILA M. DE LIMA, JOSE CHRISTOPHER Y. BELMONTE, SERGIO OSMENA. Il, WIGBERTO E. TANADA, SR., LORENZO R. TANADA III, JOSE MANUEL ib DIOKNO, EDMUNDO Ge GARCIA, LUTGARDO B. BARBO, LORETTA ANN P. ROSALES, Petitioners, -versus- SALVADOR MEDIALDEA, in his capacity as Executive Secretary: HERMOGENES ESPERON, in his capacity as National Security Adviser; TEODORO L. LOCSIN, JR., in his capacity as Secretary of Foreign Affairs: DELFIN LORENZANA, in his capacity as Secretary of National Defense: EDUARDO ANO, in his capacity as Secretary of the Interior and Local Government: CARLOS DOMINGUEZ III, in his capacity as Secretary of Finance; MENARDO I. GUEVARRA, in his capacity as Secretary of Justice: G.R. No. 252741 FOR: Writs of Certiorari and Prohibition under Article VIII, Section 1 of the 1987 Constitution, with Application for a Temporary Restraining Order and Preliminary InjunctionGREGORIO BALLESTEROS: HONASAN II, in his capacity as Secretary of Information and Communications Technology: MEL GEORGIE B. RACELA, in his capacity as Executive Director of the Anti-Money Laundering Council: WENDEL E. AVISADO, in his capacity as the Secretary of Budget and Management: the ANTL-TERRORISM COUNCIL, (ATC) created under Republic Act No. 11479; the NATIONAL INTELLIGENCE COORDINATING AGENCY (NICA); and any persons acting under their control, supervision, or direction in relation to the enforcement of Republic Act No. 11479, Respondents. MANIFESTATION WITH MOTION PETITIONERS, by counsel, respectfully state that: iL On July 22, 2020, undersigned counsel served and filed via email a Petition for Certiorari and Prohibition with Application for a Temporary Restraining Order and Preliminary Injunction dated July 15, 2020. 2 On July 23, 2020, petitioners personally filed the same Petition for Certiorari and Prohibition with Application for a Temporary Restraining Order and Preliminary Injunction dated July 15, 2020 before this Court. 3. However, after said filing, Petitioner MARIO S. NERY, JR. informed undersigned counsel of a minor typographical erroron page 9 of the Petition. The pertinent portion thereof is quoted and emphasized below: “2.1. Petitioners’ capacity to sue and standing. XXX c. Petitioner MARIO S. NERY, JR. is of age, Filipino, and resides at 84 Small Horseshoe Road, Horseshoe Village, Barangay Horseshoe, Quezon City. He may be served with notices and other court processes through undersigned counsel. He is a columnist of the Philippine Daily Inquirer, a member of the Inquirer's Editorial Council, the author of books on contemporary political and social issues, and a multi-awarded journalist.” (footnote removed, emphasis and underline added) 4. While Petitioner Nery remains a columnist of the Philippine Daily Inquirer, he is no longer a member of the Editorial Council thereof. The word “was” was inadvertently omitted in the relevant phrase. Petitioner Nery therefore respectfully submits the following formal amendment to the portion quoted above: “2.1 Petitioners’ capacity to sue and standing. XXX c. Petitioner MARIO S. NERY, JR. is of age, Filipino, and resides at 84 Small Horseshoe Road, Horseshoe Village, Barangay Horseshoe, Quezon City. He may be served with notices and other court processes through undersigned counsel. He is a columnist of the Philippine Daily Inquirer, was a member of the Inquirer's Editorial Council, the author of books on contemporary political and social issues,! and a multi-awarded journalist.” ' He wrote REVOLUTIONARY SPIRIT: JOSE RIZAL IN SOUTHEAST ASIA (2011); and edited INTO THE MOUNTAIN: HOSTAGED BY THE ABU SAYYAF and UNHOLY NATION: STORIES FROM A GAMBLING REPUBLIC (which both won the National Book Award from the Manila Critics Circle).5. Considering that the amendment herein pertains to a minor defect in the Petitioner's designation, it may be summarily corrected as no prejudice is caused to any of the adverse parties.” 6. Further, petitioners manifest that as of this writing on this date July 24, 2020, the following similar petitions have been filed before this Court assailing the same Anti-Terrorism Law: Pp g. Brrr Howard Calleja’s Petition filed on 04 July 2020; the National Union of Peoples' Lawyers (NUPL)’s Petition which was filed electronically last 04 July 2020 and physically on 06 July 2020; Albay Ist District Representative Edcel Lagman's Petition filed on 06 July 2020; Far Eastern University Institute of Law's Petition filed on 06 July 2020: the Makabayan Bloc’s Petition filed on 06 July 20205 Former Office of the Government Corporate Counsel (OGCC) chief Rudolf Jurado’s Petition filed on 08 July 2020; Constitutional framers, Atty. Christian Monsod and Atty. Felicitas Aquino-Arroyo, with Ateneo and Xavier lawyers’ Petition filed on 08 July 2020; the Center for Trade Union and Human Rights (CTUHR) and the Pro-Labor Legal Assistance Center (PLACE)’s Petition filed on 08 July 2020; the Sanlakas party list’s Petition filed on 13 July 2020; Federation of Free Workers’ Petition filed on 17 July 2020; BAYAN's petition filed on 19 July 2020; Jose Ferrer, Jr.’s Petitions Associate Justice Antonio T. Carpio, Associate Justice Conchita Carpio Morales and members of ? Section 4, Rule 10 of the Rules of Court provides: ection 4. Formal amendments. — A defect in the designation of the parties and other clearly clerical or typographical errors may be summarily corrected by the court at any stage of the action, at its initiative or on motion, provided no prejudice is caused thereby to the adverse party.” Based on the list released by Supreme Court spokesperson Brian Keith Hosaka; date of filing could not be ascertained. 4the UP College of Law Faculty’s Petition filed on 22 July 2020; n. National Union of Journalists of the Philippines (NU4JP)’s Petition filed on 23 July 2020; o. Kabataang Tagapagtanggol ng CKarapatan’s Petition filed on 23 July 2020; p. Algamar Latiph’s Petition filed on 23 July 2020 q. Alternative Law Groups, Inc.’s Petition filed on 24 July 2020; r. Leaders of churches’ Petition filed on 24 July 2020: and s. Gabriela’s Petition filed on 24 July 2020. Prayer WHEREFORE, the petitioners respectfully pray for the correction of the minor defect in Petitioner Mario S. Nery, Jr.’s designation in paragraph 2.1 (c) of the Petition for Certiorari and Prohibition with Application for a Temporary Restraining Order and Preliminary Injunction dated July 15, 2020, and for this Honorable Court to note the petitioners’ Manifestation through counsel. Metro Manila, Philippines, 24 July 2020.FREE LEGAL ASSISTANCE GROUP (FLAG) Counsel for Petitioners clo Sanidad Law Office 24 Floor, Eastside Building 77 Malakas Street Brgy. Pinyahan, Quezon City JOSE EL I. DIOKNO Roll 6f Attorneys No. 35394 PTR No. 9668094, 02-04-2020, Quezon City IBP (Lifetime) No. 00236, 02-09-1995, Pasig City MCLE Exemption No. VI-000914 (Valid until 04-14-2022) BM2012 Mandatory Legal Aid Service Exempt — Free Legal Assistance Group Tel. No. 8877-9242 E-mail:dioknolawcenter@gmail.com ae HEODORE 0. TE Roll of Attorneys No. 37142 PTR No. 9542333, 01-24-2020, Makati City IBP No. 112306, 01-24-2020, Makati City MCLE Exemption No. VI-001316 (Valid until 04-14-2022) BM2012 Mandatory Legal Aid Service Exempt — Free Legal Assistance Group Tel No. 8920-5514 loc. 418 Rolllof Attorneys No. 35221 PTR No. 5242319, 01-08-2020, Pasig City IBP (Lifetime) No. No. 09437, 12-16-2010, Quezon City MCLE Compliance No. VI - 0023513, 03/27/2019 Tel. No.: 8638-0400 E-mail: rlaquinox@gmail.comNA, TLLE ROSS'G, PARPAN Roll of Attorneys No. 66528 PTR No. 9829142, 02-19-2020, Quezon City IBP No. 112738, 01-10-2020, Pampanga MCLE Compliance No. VI-0005357, 01-28-2017 Tel. No. (02) 8372-4770 Email: cgp@leflegis.com MICHAEL cunishopHER C. DE CASTRO Roll of Attorneys No. 68718 PTR No. 9343828; 01-06-2020, Quezon City IBP No. 111122, 01-20-2020, Bicolandia/Masbate MCLE Compliance No. VI-0026337, 05-08-2019 CP. No. 0995 651 2090 Email: medc@leflegis.com COPY FURNISHED: OFFICE OF THE SOLICITOR GENERAL Counsel for the Respondents 134 Amorsolo St., Legaspi Village Makati City, Metro Manila docket@osg.gov.ph efile@osg.gov.phREPUBLIC OF THE PHILIPPINES) QUEZON CITY )ss. AFFIDAVIT OF FILING AND SERVICE (x compliance with Rule 13 of the 2020 Amended Rules of Civil Procedure) 1, Vince Pedragosa, of legal age, as part of FREE LEGAL ASSISTANCE GROUP (FLAG) with address ¢/o Sanidad Law Office, 2 Floor, Eastside Building, 77 Malakas Street, Brgy. Pinyahan, Quezon City, after being duly sworn, depose and say that: 1. On July 27, 2020 I filed and/or served a MANIFESTATION with MOTION for the case entitled MA. CERES P, DOYO, et al, versus SALVADOR MEDIALDEA, et al, docketed as G.R. No. 252741. 2 Pursuant to Rule 13 Secs. 4, 5,6 ,7, and 8 of the 2020 Amended Rules of Civil Procedure, I filed and/or served the above-stated pleading through the following mode/s: Q Personal By personally delivering the pleading to the court, the party, their counsel, or their authorized representative named in the pleading, By leaving it in their office with his or her clerk. By leaving a copy, between 8:00AM and 6:00PM, at the party's or counsel's residence, with a person of sufficient age and discretion residing therein, AX Registered A By depositing the copy in the post office, in a sealed envelope, Mail with postage fully paid, with instructions to the postmaster to return the mail to the sender after ten (10) calendar days if undelivered, and plainly addressed to the court, the party or to their counsel at the their residence / office. The registry receipts issued by the mailing office are attached to the original pleading on file with the court. Registry Receipt No.__ © 140 Wp aay 2e Q Ordinary By resorting to ordinary mail because no registry service is Mail available in the locality of ether the sender or the addressee. Accredited By depositing the copy in the accredited courier, in a sealed Courier envelope, with postage fully paid, with instructions to the courier to return the mail to the sender after ten (10) calendar days if undelivered, and plainly addressed to the court, the party or to their counsel atthe their residence / office. Official Receipt No. Document Tracking No. (attach additional pages if necessary) Q Electronic D_By sending an email to the following email address es: Mail Q Facsimile By sending a facsimile to the following facsimile number/s: Transmission D Substituted By delivering a copy of the pleading / paper to the clerk of Service court because service in any of the above methods is unavailing and the office/residential address of the party and their counsel are upkn SUBSCRIBED AND SWORN to before me this July 27, 2020, by the affiant, at Quezon City, exhibiting, before me his competent evidence of identity (CEI) Philhealth ID 10-250306777-0. wll Doc. No.: 284 ; ‘CALMA, JR. PageNos 88 - Ral. S018 ‘ 9521280o, Jan, 21,2020 Book Nox WV; FIBP No. 098280 Nov 20,2019 Series of 2020. ‘MCLE Comp, No. VI-0012847 until Apri 14,2022 (20 Kamagong St., Sapamanai Village East Fairview, Quezon City ADM Matter No. Ni-06?‘VERIFIED DECLARATION I, CAMILLE ROSS G. PARPAN, hereby declare that the documents (and annexes thereof) hereto submitted electronically in accordance with the Efficient Use of Paper Rule are complete and true copies of the documents (and annex CAMILLE ROSS G. PARPAN Counsel for Petitioners MA. CERES P. DOYO, JOSEFA ANDRES MAGLIPON MARCELO, MARIA A. RESSA, RACHEL E. KHAN, MARIA ROSARIO F. HOFILENA, LILIBETH SOCORRO FRONDOSO, MARIA TERESA D. VITUG, MARIO S. NERY, JR., BEATRICE P. PUENTE, FLORANGEL ROSARIO-BRAID, FRANCIS N. PANGILINAN, LEILA M. DE LIMA, JOSE CHRISTOPHER Y. BELMONTE, SERGIO OSMENA Il, WIGBERTO E. TANADA, SR., LORENZO R. TANADA III, JOSE MANUEL I. DIOKNO, EDMUNDO G. GARCIA, LUTGARDO B. BARBO, and LORETTA ANN P. ROSALES July 28, 2020 SUBSCRIBED AND SWORN TO before me on this 28th day of July 2020, affiant exhibiting her competent evidence of identity, to wit: Driver's License No. C-10-014268. Notayy Public Doc No. |S2 ; Page No. 22; Book No. Céi)_; a Series of 2020. rene Mirae TIN GSAT, con \ a 135-064-700 ws