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Republic of the Philippines

House of Representatives
LGPMA PARTY LIST
Quirino Highway, Novaliches, Quezon City, Metro Manila

PEOPLE OF THE PHILIPPINES , SEARCH WARRANT NO_______

Plaintiff,

-VERSUS- FOR

PEAK FUEL CORPORATION FACILITY VIOLATION OF R.A 11592

Brgy. Pinamucan Ibaba, Lagadlarin, Batangas City, Batangas

Respondent,

X-----------------------------X

APPLICATION FOR SEARCH WARRANT

COMES NOW, The undersigned member of the Task Force LGPMA Party List therefore declares the
following after being legally sworn in line with the law, including;

That, on July 4, 2023, our office at _____ have received a word from a reliable source that PEAK FUEL
CORPORATION FACILITY in Brgy. Pinamucan, Lagadlarin, Batangas City, Batangas; the LPG Cylinder tanks
and Refill Bullet Trucks of Businesses involved in supplying the Generic and other Unauthorized LPG Cylinder
tanks are being tampered with.

In answer, with regards whether the PEAK FUEL CORPORATION FACILITY possesses a License to
Operate (LTO) and that they have secured a certificate with the Standard Compliance Certificate (SCC), they
have sent a verification with the Department of Energy Office, located at 2F PNOC Building V, Energy Center,
Rizal Drive, 34th Street, Taguig, Metro Manila;
Thus, according to the results of verification dated July 04, 2023, the PEAK FUEL CORPORATION
FACILITY of Brgy. Pinamucan Ibaba, Lagadlarin, Batangas Province is a REGISTERED Refilling Plant, however
it solely sells its own brand.

The undersigned applicant for this Search Warrant is morally convinced and fully believed that the
PEAK FUEL CORPORATION FACILITY of Brgy. Pinamucan Ibaba, Lagadlarin, Batangas City, Batangas; is
confirmed to illegally refills the LPG Cylinder Tanks in violation of Republic Act 11592, also known as Act
establishing the “Regulatory Framework for the Safe Operation of the Liquefied Petroleum Gas Industry
delineating the powers and functions of various Government Agencies defining and penalizing certain
prohibited acts”.

Therefore; because the Municipality of Brgy, Pinamucan Ibaba is within the jurisdictional area of the
Regional Trial Court of Batangas City, we chose to apply in the same RTC as we considered was a neutral
ground and outside the reach of information leak;

As a supporting papers for this search warrant application, we have attached the deposition of the
witness of the LPG Task Force Images and certification from the Department of Energy.

Thus, the undersigned requests that this Honorable Court to issue a Search Warrant authorizing the
members of the LPG Task Force and the Batangas City, PNP personnel to search the said residence and seize
the Bullet Trucks and the other paraphernalia that are being used in an illegal refilling of the Generic and
other Unauthorized LPG Cylinder tanks turning them into a concrete evidence and bringing them to this
Honorable Court to be dealt with in an accordance with the existing laws.

Municipality of Batangas City, Province of Batangas, Philippines, ___day of July, 223

TF Nero Obien
Applicant

RECOMMEND APPROVAL: APPROVED FOR FILLING:

________________________ ______________________

Task Force Team Leader Task Force Supervisor


SUBSCRIBED AND SWORN to before me this __ day of July, 2023 at
Municipality of _______________, Province of Batangas, Philippines. This further
certifies that I personally examined the affiant and I am personally satisfied that he
freely and voluntarily executed the same.

_________________________________

Administering Officer

Republic of the Philippines }

Province of Bataan } S. S.

Municipality of Hermoza}

DEPOSITION OF WITNESSES
WE, TF Nero Obien, a resident of Olongapo, Zambales, and TF Jerry Pareja, a resident of Pasong
Tamo, in Metro Manila, both Task Force members of the LPGMA Party List, Quirino Highway, Novaliches,
Quezon City, do hereby depose and state;

That we are authentic member of the Task Force LPGMA Party List members assigned as Covert
Operatives covering the municipality of Bataan, and that our major mission is to perform
surveillance/monitoring on all types of illicit LPG Cylinder Tank refilling;

That on July 3, 2023, at about 12:00 p.m., I (TF Nero Pogi) received a call from a confidential
informant stating that PEAK FUEL CORPORATION FACILITY, Brgy. Pinamucan Ibaba, Lagadlarin Batangas City,
Batangas, tampers with LPG cylinder tanks and replenishes Bullet Trucks of companies that distribute generic
and other unlawful LPG Cylinder tanks.

On the same date, we quickly notified our Task Force Supervisor of the situation. and we were told
to perform surveillance/monitoring to establish the report's authenticity;

That according to my surveillance, monitoring, and information-gathering with the subject, he has a
covert relationship with a politician who acts as his defender. The subject establishment, according to our
trustworthy source, is in possession of multiple bullet vehicles and refilling equipment that they used to
supply modified the LPG cylinder tanks in neighboring municipalities and the province.
After surveillance/monitoring on July 03 2023, we reported the results of our findings to the
Supervisor, who then gave our Team Leader instructions to give the Department of Energy priority in
reviewing our request for confirmation of whether this establishment has LTO and SCC;

That about 12:00 PM on July 4, 2023, I (TF Jerry Pareja) received a phone call from our confidential
informant stating that the PEAK FUEL CORPORATION FACILITY is in need of two people to replace an
employee who filed a leave of absence in order to keep the refilling plant going. TF Jerry Pareja and the
confidential informant applied for the position, and we got the job right away;

That I, TF Jerry Pareja, and the confidential informant began immediately, and we were directed to
proceed in the Bullet Truck Refilling Section. Several Bullet trucks of unknown companies replenish and I have
seen it that they’re refilling the Generic and Unauthorized Brand of LPG Cylinder Tanks. Similarly, some
branded LPG cylinder tanks are tampered with and executed with their own brand. The same thing
happened the next day, which led us to the conclusion that PEAK FUEL CORPORATION unlawfully replenishes
Bullet Trucks that are not within their supervision or control.

That we left the refilling plant after three (3) days and didn't return. We informed our immediate
supervisor of the facts, worked with the company's attorney, and filed a search warrant application against
the PEAK FUEL CORPORATION FACILITY of Brgy. Pinamucan Ibaba, Lagadlarin, Province of Batangas.

Thus, according to the results of verification dated July 04, 2023, the PEAK FUEL CORPORATION
FACILITY of Brgy. Pinamucan Ibaba, Lagadlarin, Batangas Province is a REGISTERED Refilling Plant, however
it solely sells its own brand.

Based on the findings of my surveillance, we are morally persuaded by the information provided by
our confidential asset that the aforementioned PEAK FUEL CORPORATION FACILITY tampered with brand-
named LPG cylinder tanks and unlawfully refilled bullet trucks belonging to unlicensed businesses;

Which we are executing this affidavit in order to obtain a search warrant with the intention of
arresting and seizing unregistered bullet trucks and refilling equipment from the previously mentioned
Business;
IN WITNESS WHEREOF, We hereunto affixed our signature below this ___ day of July 2023 at
_________________, Batangas City

TF Nero Pogi TF Jerry Pareja

(Affiant) (Affiant)

SUBSCRIBED AND SWORN to before me this ___ day of July 2023 at Hermoza, Bataan, Philippines.

____________________________________

Administering Officer

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