RH Law Comment League of Cities

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REPUBLIC OF THE PHILIPPINES
SUPREMECOURTi,i,:i,':i.; ,<]
MANILA
ENBANC
ALLIANCE FOR THE FAMILY
FOUNDATION PHILIPPINES, INC.
(ALFI), represented by its President
Maria Concepcion S. Noche, Spoues
Reynaldo S. Luistro & Rosie B. Luistro,
Jose S. Sandejas & Elenita S. A. Sandejas,
Arturo M. Gorrez & Marietta C. Gorrez,
Salvador S. Mante, Jr., & Hazeleen L.
Mante, Rolando M. Bautista & Maria Felisa
S. Bautista, Desiderio Racho & Tranquilina
Racho, Fernand Antonio A. Tansingco &
Carol Anne C. Tansingco for themselves
· and on behalf of their minor children,
Therese Antonette C. Tansingco, Lorenzo
Jose C. Tansingco, Miguel Fernando C.
Tansingco, Carlo J osemaria C. Tansingco &
Juan Paolo C. Tansingco, Spouses Mariano
V. Araneta & Eileen Z. Araneta for
themselves and on behalf of their minor
children, Ramon Carlos Z. Araneta & Maya
Angelica Z. Araneta, Spouses Renata C.
Castor & Mildred C. Castor for themselves
and on behalf of their minor children, Renz
Jeffrey C. Castor, Joseph Ramil C. Castor,
John Paul C. Castor & Raphael C. Castor,
Spouses Alexander R. Racho & Zara Z.
Racho for the1nselves and on behalf of their
minor children Margarita Racho, Mikaela
Racho, Martin Racho, Mari Racho .. &
Manalo Racho, Spouses Alfred R. Racho &
Francine V. Racho for themselves and on
behalf of their minor children Michael
Racho, Mariana Racho, Rafael Racho, Maxi
Racho, Chessie Racho, & Laura Racho,
Spouses David R. Racho & Armilyn A.
Racho for themselves and on behalf of their
minor child Gabriel Racho, Mindy M.
Juatas, and on behalf of her minor children
Elijah Gerald Juatas and Elian Gabriel
Juatas, Salvacion M. Monteiro, Emily R.
Laws, Joseph R. Laws & Katrina R. Laws,
Petitioners,
For: Prohibition
Under Rule 65 of the
Rules of Court With
Prayer for the
URGENT Issuance of
a Temporary
Restraining Order
and/or Writ of
Preliminary
Injunction
1
---------versus---------
HON. PAQUITO N. OCHOA, Executive
Secretary, HON. ENRIQUE T. ONA,
Secretary of the Department of Health,
HON. ARMIN A. LUISTRO, Secretary
of the Department of Education, HON.
CORAZON SOLIMAN, Secretary of the
Department of Social Welfare and
Development, HON. MANUEL A.
ROXAS II, Secretary of the Department of
Interior and Local Government, HON.
FLORENCIO B. ABAD, Secretary of
Budget and Management, HON.
ARSENIO M. BALISACAN, Socio-
Economic Planning Secretary and NEDA
Director-General, the PHILIPPINE
COMMISSION ON WOMEN,
represented by its Chairperson Remedios
Ignacio-Rikken, the PHILIPPINE
HEALTH INSURANCE
CORPORATION, represented . by its
.President Eduardo Banzon, the LEAGUE
OF PROVINCES OF THE
PHILIPPINES, represented by its
President Alfonso Umali, the LEAGUE
OF CITIES OF THE PHILIPPINES,
represented by its President Oscar
Rodriguez, and the LEAGUE OF
MUNICIPALITIES OF THE
PHILIPPINES, represented by its
President Donato Marcos,
Respondents.
VERIFIED COMMENT with MOTION FOR EXCLUSION AS
PARTY
Respondent LEAGUE OF CITIES OF THE PHILIPPINES, by
counsel, into the Honorable Court most respectfully moves that it be
excluded as party on the following grounds:
1. The League of Cities of the Philippines, hereinafter referred to
as the League, is an organization registered with the Securities
and Exchange Commission of all cities
1
for the primary purpose
of ventilating, articulating and crystallizing issues affecting city
1
A copy of the League's Certificate of Registration is hereto attached as Annex "1".
2
government administration, and securing, through proper and
legal means, solutions thereto.
2
The highest policy-making body
of the League in between sessions of its General Assembly is its
National Board of Directors;
2. The League is not a part or an adjunct of the Executive and has
no power to execute or enforce laws but only such matters as
may have been validly resolved or agreed upon by its Assembly
or Board. No such resolution or agreement exists pertaining to
Republic Act (R.A.) 10354;
3· For the foregoing reasons, it is respectfully submitted that the
inclusion of herein League as respondent is erroneous and it is
thus prayed that the League be excluded as party-respondent.
RIGOROSO GALINDEZ and RABINO
Law Offices
Room 901, 9th Floor, Fil Garcia Tower,
Kalayaan Avenue, Quezon City
Tel.No. 924-8552/924-2396
By:
TEDDY ]:SFEBJ ·--\F:ruGOROSO
&:PR.# 755097 o \ ~ = 1 3 ; Q.C.
IBP # 923300 01-09-13; Q.C.
MCLE Compliance N . V-0008405; 10-03-12
Roll# 42240
.Copy Furnished:
ATTY. MARIA CONCEPCION S. NOCHE
MCS NOCHE LAW OFFICE
91 Melchor Street
Loyola Heights, 1108 Quezon City
EXPLANATION
Copy of the foregoing Comment with motion for exclusion as party
was served to the other party by register d mail due to lack of
material time and personnel to effect semce.
\
2
Section 499 of the Local Government Code of 1991, as amended.
3
VERIFICATION
I, Oscar S. Rodriguez, of legal age and with office address at
Unit J&K, Floor, CyberOne Building, # 11 Eastwood Avenue,
Bagumbayan, Quezon City, after having been sworn to in accordance
with law, do hereby depose and state that:
I am the National President of the League of Cities of the
Philippines; I have caused the preparation of the foregoing Comment
with motion for exclusion as party; I have read the allegations
contained therein and the same are true and correct of my own
personal knowledge and based on authentic records.
(\ WITNESS HEREOF, I have hereunto set n1y hand this
rt of February 2013 at Quezon City. '
.
'
••
LA
Oscar S. Rocfriguez
Affiant
t. () 1(\'J
SUBSCRIBED AND SWORN to before me thil day of
February 2013 at Quezon City. Affiant exhibited to me as competent
evidence of identity his 'Philippine with
number E\b\b339'-lll valid uoli\ ·
Doc No. ]:""),- ;
Page No.-1.!_;
Book No. __Jk_;
Series of
H ANY,
ATTY'S ROLL NO_ 273B
NOTARY PUBLIC
UNTIL DECEMBER 31, 1114
PTR Nil 756fl959 JAN. '1. 2f!12;
lf.W NlJ. l::34:!i'l2 llEC. 1L 21112
TIN NO. 1'25- 85 '2 - 35'1
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HOLA1J;.N)l\ T,. TESOklC·

J..;t:1ga1
Republic of the Philippines
Quezon City
)
)ss.
Affidavit of Service
I, Jamilo M. lbias, of legal age, Filipino, and with office address at Rm. 901-9th Fir. FilGarcia Tower,
140 Kalayaan Avenue, Diliman, Quezon City, after having been duly sworn to in accordance with law hereby
depose and state, that
1. On 8 February 2013, I have personally filed the foregoing Pleading/Document with the Supreme
Court En Bane, re:
VERIFIED COMMENT WITH MOTION FOR EXCLUSION ASP ARTY
ALLIANCE FOR THE FAMILY FOUNDATION PHILIPPINES, INC., ET AL., Petitioners,
versus HONORABLE PAQUITO OCHOA, ET AL., Respondents.
G.R. No. ____ _
2. On 8 February 2013, I have likewise served copy of the foregoing Pleading by Registered Mail to the
following:
Atty. Maria Concepcion S. Noche
MCS Noche Law Office Registry Receipt No.
QC Hall Post Office
February 8, 2013
91 Melchor Street, Loyola Heights, 1108 Quezon City
by depositing a copy at the QC Hall Post Office in a sealed envelope, plainly addressed to the addressee
mentioned above, with pre-paid postage, as evidenced by registry receipt correspondingly attached beside the
name of the addressees appearing on page 3 of the original Pleading and with instruction to the postmaster to
return the mail to the sender after Ten (10) days if undelivered.
IN TRUTH WHEREOF, I hereunto affix my signature this 8th day of February 2013 at Quezon City.
SUBSCRIBED AND SWORN TO before me this 8th day of February 2013 at Quezon City, affiant
exhibited to me as competent proof of identity his TIN bearing numbers 297-973-841.
Doc. No.I=
Page No.
Book No.
Series of 20 3.

0
IN ANA
ATTY'5 ROLL N!J. 273 6
NOTARY PUBLIC
UNTIL DECEMliER 2DH _
PTR HD. 756[l?59 .IAN. 2. 2[1 H
IBP Na. 334?i22 DEL 11. 21112
TJN NO. 125-852-859
Cr!'rl'l1!55f[JN N[J_ rJfl=t<21lEi- 2!114J
'!ICLf ND.lV · IJU19t,.ro

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