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REPUBLIC OF THE PHILIPPINES

OFFICE OF THE OMBUDSMAN


OFFICE OF THE DEPUTY OMBUDSMAN FOR MINDANAO
DAVAO CITY

EBAO SULANG, VICTOR


LUMONDANG, JR., ARNEL
TAKYAWAN, MARK ANTHONY
DELGADO and LUMENARIO
AGUSTIN,
Complainants,

- versus - OMB Case No.


For: Murder, Frustrated, Murder,
3 Counts of Attempted Murder,
Violation of R.A. 9745 (Anti-
Torture Law), Violation of R.A.
7438 (Rights of Accused), B.P.
880 (Public Assembly Act), P.D.
1829 (Obstruction of Justice),
Gross Misconduct, Grave
Abuse of Authority, Gross
Oppression and for Conduct
Unbecoming of a Public Officer.

DILG Sec. MEL SENEN


SARMIENTO, North Cotabato
Gov. EMMYLOU TALINO-
MENDOZA, Kidapawan Mayor
JOSEPH EVANGELISTA, PNP
Director General RICARDO
MARQUEZ, PNP Regional
Director for Region 12 P/SUPT
NOEL ARMILLA, PNP Acting
Deputy Regional Director For
Operations for Region
12 PSSUPT. ROBERTO BADIAN,
North Cotabato PNP Provincial
Director P/SSUPT. ALEXANDER
TAGUM, Kidapawan Police
Chief P/Insp. JOHN PATRICK
CALINGA, a certain LT. COL.
BIRREY Ground Commander of
the PNP Strike Force, P/Dir
ISAGANI NEREZ, MGEN.
Page 2 of 17

RAFAEL VALENCIA,
Commander 10th ID, PA, COL.
RONALD VILLANUEVA, 1002nd
Brigade Commander (GSC),
10th Infantry Division, PA, LT.
COL. ARNOLD ARGAMOSA,
Battalion Commander 39th
Infantry Battalion, PA, Fire
Senio Inspector NOA
PACALDA, Military agent
CHARLIE PASCO aka
"LONGHAIR", a certain SGT
OBIANO, SPO1 BOYNEL
LUMOGDANG, P01 SOLON
and P02 BALDUA of the PNP
and several John Does of police
and military officers and
civilian agents of the police and
military units operating in
Region 12,

Respondents.
x--------------------------------------------------x

COMPLAINT
===========

COMPLAINANTS EBAO E. SULANG, VICTOR LANAY


LUMONDANG, JR., represented herein by his father Victor Dalapan
Lumondang, Sr., ARNEL TAKYAWAN, MARK ANTHONY
DELGADO and LUMENARIO AGUSTIN, assisted by the
undersigned counsels, hereby accuse all the above-named
respondents1

1
In conspiracy with one another and aided by the following PNP
personnel, among others, PO2 DYBEN DOMINIC FIGUEROA, PO2
BEN JIIMENEZ TORION, PO3 RODRIGO ENTERO TITO, SPO2
ROBIN BANDIOLA PORRAS, PO3 XERXES ANTHONY DONASCO
FIEL, PO3 MICHAEL C. JORDAN, PO3 ELSON PAEZ GADAT,
Page 3 of 17

of Murder under Art. 248 of the Revised Penal Code, Frustrated


Murder under Art. 250, par. 1 of the Revised Penal Code in relation to
Republic Act No. 7610 otherwise known as the “Special
Protection of Children Against Abuse, Exploitation and
Discrimination Act”, three (3) counts of Attempted Murder under
Art. 250, par. 2 of the Revised Penal Code, violation of R.A. 9745

SPO3 FORTUNATO ARCE, PO2 ROBERT HOPE SANGHAN


AGOT,PO1 KRISTINE ALAS OCUMEN, PI JOSE MARI CORPUZ
MOLINA, PO1 RAY SON L. ALOLOD, SPO2 MAGIN EDGARDO L.
BUENO III, PO1 CLARK AHIT GAYAS, PO3 RUEL B. MARIMON,
SPO2 CESAR RUIZ OLIVAR, PO3 ROMEL MAGDATO GUHILING,
SPO2 RODERICK CABALLERO SILLOTE, PO3 ELMER GESULGA
DASALLA, PO1 ANTHONY JALA MACAILING, PO1 JOSELITO
SUMIDO PALMAERA, PO1 RICKY PARNADA NAPAO, PO3
GARRY DOPLYNA BOOC, PO1 HERWIN PALLER PAJO, PO1
ERIC CASILAD GEOLINGO, PO2 ALREC ALBINA DELA CRUZ,
PO1 AMOR NIEGOS GULLIERMO, PO2 RONAN BATISLAONG
CRUSPERO, PO1 RONALD BATION SILLOTE, PO1 RONALD
CHARKIE ALCALA AMANDE, PO2 JHOVEN FRANCISCO
LANDRITO, PO1 JOHNY BURGOS BENITEZ, PO3 JOEMER
LLAGAS, JASPER JAY BELOCURA MORENO, PO1 SHIELA MAE
J. ESTRADA, PO2 MERCIL P. MILLOMEDA, PO1 TEOLIT T.
LAGLIVA, PO1 WILMAE MACAYA, PO1 LIEZELJOY NICER, PO1
BEAULAHLY SALAZAR, SPO2 GLESILDA ATUD, PO3 IVY BULA,
PO1 MARIVIC O. ARAGON, PO1 RICHELLE JOAN D. LAM-AN,
PO1 BERLYN B. ALBA, PO1 MICHELLE A. VICENTE, PO1
ANAMARIE ABATAY, PO1 ROXANNE JILL GARDE, PO1 BELINDA
L. PACATANG, PO3 RICHARD VILLEGAS LAGUTANG, PI
CHARLES SUAREZ FULACHE, PO2 NORODIN M. CABUYAO,
SPO2 NILO AVENTURA LOREDO, PO3 JOVETTE S. GALAN, PI
IRVIN BASILIO CAMBANG, PO2 ARIEL HERMADO MAQUILING,
PO1 CRISMAL P. LAGUERDER, SPO4 ULYSIS VILOAN SAGUN,
SPO2 ARNOLD REMOTIN, PO1 ROBERT IAN DIGNADICE,
P/INSP. ARMANDO S. ABASOLO, PO3 JAYPEE SARABIA, SPO2
RAUL LITERATO CANTOY, PO1 ARIEL GANALONZA ACOSTA,
PO1JERIEL P. CATIPAY, PO3 RENATO OCLARINO TESORO, PO1
BERNRD MOLINA SUMAGIT, PO3 DINDO PAREDES CELARTA,
PO1 CHRLYN CANTOMAYOR INES, SPO4 JOSEPH DASIA ONES,
AND PO1 JENNIFER L. ISLA,
Page 4 of 17

(Anti-Torture Law), violation of R.A. 7438 (Rights of Accused),


B.P. 880 (Public Assembly Act), P.D. 1829 (Obstruction of
Justice),Gross Misconduct, Grave Abuse of Authority, Gross
Oppression and for Conduct Unbecoming of a Public Officer.

1. Murder for the death of Darwin Sulang. Darwin Sulang


was one of those killed during the illegal and violent dispersal of a
protest rally staged by farmers on April 1, 2016 in Kidapawan City,
North Cotabato. While his Death Certificate states that he died
supposedly from head injuries due to mauling, witnesses saw that he
was shot and killed by a policeman. The independent autopsy
conducted on Darwin Sulang contradicts the cause of death stated in
the death certificate because it was determined that he died of
perforating gunshot wound in the middle of his forehead with the
bullet exiting at the top back of his head. It was also confirmed that
the bullet that killed him came from a high velocity rifle. Witnesses
confirm that Darwin Sulang was unarmed and was simply
participating in a peaceful protest rally when he was intentionally
shot. In support of this charge, the following documents are hereto
attached:

ANNEX “A” : Affidavit of complainant Ebao Sulang


ANNEX “B” : Supplemental Affidavit of
complainant Ebao Sulang
ANNEX “C” : Affidavit of Lumenario Agustin
ANNEX “D” : Death Certificate
ANNEX “E” : Medical Certificate
ANNEX “F” : Autopsy Report by Dr. Raquel Fortun
ANNEX “G” : Pictures of dead body of Darwin
Sulang

2. Frustrated Murder, in relation to R.A. 7610 for the


near fatal shooting of complainant Victor Lumondang, Jr.
Complainant Lumondang was among the farmers who joined the
protest action in Kidapawan City on April 1, 2016. Complainant
Lumondang saw the other victim, complainant Arnel Takyawan shot
in his right foot. He immediately ran to Arnel to help him. He bent
down with his back at the place were the shooter of Arnel was. It was
at this point that Victor was shot at the back of his neck. Victor’s
father, Victor, Sr. was a few meters away from him when he heard a
fellow farmer, Daniel Unsang shouted that his son Victor was shot.
Victor, Sr. and Daniel Unsang immediately went to where Victor fell to
rescue him. However, they too were shot at. Victor, Sr. saw the
Page 5 of 17

policeman who shot his son who was hiding in a limestone near a
firetruck.

Complainant sustained seven (7) gunshot wounds which


wound would have caused death if not for timely medical intervention.
Victor is only 17 years old, a minor covered by the definition under
Section 3 (a) of Republic Act No. 7610, and the injuries he sustained
from the policemen is an abusive act covered by the definition under
Section 3 (b) (1) of the same Act. In support of this charge, the
following documents are hereto attached:

ANNEX “H” : Affidavit of complainant Victor


Lumondang, Jr.
ANNEX “I” : Affidavit of Victor Lumondang Sr.
ANNEX “J” : Affidavit of Daniel Unsang
ANNEX “K” : Birth Certificate of complainant
Lumondang
ANNEX “L” : Certificate of confinement of
complainant Lumondang
ANNEX “M” : Midway Hospital Discharge order
ANNEX “N” : Clinical Abstract issued by the
Midway Hospital
ANNEX “O” : Statement of Account issued by
Midway hospital
ANNEX “P” : Picture of complainant Lumundang
after he was shot.

3. Attempted Murder for the shooting of Arnel


Takyawan. Complainant Arnel Takyawan was also part of the protest
action on April 1, 2016 in Kidapawan City. While the dispersal was
going on, he saw a policeman aimed and shoot at him. The shot
missed him. He tried to run and hide, but he heard a second shot,
and later felt pain in his right foot where the bullet hit him. After two
steps, he fell down. It was obvious that the shooter’s intention was to
kill him because he took another shot when he missed. Arnel saw
that the shooter was one of the policemen on top of the firetruck,
whom he cannot identify because the policeman was wearing a
helmet and a face mask. There is also no doubt that Arnel was
targeted by the said policeman. In support of this charge, the
following documents are hereto attached:

ANNEX “Q” : Affidavit of complainant Takyawan


ANNEX “R” : Affidavit of Larry Laidan
ANNEX “S” : Medical Certificate issued by the Holy
Page 6 of 17

Infant Medical Laboratory


ANNEX “T” : Medical Certificate issued by Midway
Hospital
ANNEX “U” : Radiologic findings issued by the
Midway Hospital
ANNEX “V” : Hematology laboratory result issued
by the Midway Hospital
ANNEX “W” : Pictures of complainant Takyawan

4. Attempted Murder for the shooting of Mark Anthony


Delgado. Complainant Delgado heard respondent S/Supt. Tagum
counted “1, 2, 3, 4, 5”, thereafter, he saw the latter fired three
warning shots, and the policemen started to move in. Several minutes
later, the police started shooting. Complainant Delgado tried to run
away, but was hit by a bullet in his right leg, and fell down. Then he
saw armed policemen aiming their guns at him. They kicked him and
whipped him with their truncheons. He was rushed to the Kidapawan
Doctors Hospital, but was later transferred to the North Cotabato
Provincial Hospital and later on to Midway Hospital. In support of this
charge, the following documents are hereto attached:

ANNEX “X” : Affidavit of complainant Delgado


ANNEX “Y” : Medical Certificate issued by the
Midway Hospital
ANNEX “Z” : Radiologic Finding issued by the
Midway Hospital
ANNEX “AA” : operation Record issued by the
Midway Hospital
ANNEX “BB” : Clinical Abstract
ANNEX “CC” : Certificate of Confinement
ANNEX “DD” : Medical Certificate issued by the Holy
Infant Medical Center

5. Attempted Murder for the shooting of Lumenario


Agustin. Complainant Agustin was cooking while the protest action
was going on. Darwin Sulang was with him when the latter was shot
and killed by policemen. After Darwin fell down, the same policeman,
who was positioned at the top of firetruck aimed and fired his gun at
him. He took cover behind a tree, but the policemen continued to fire
at him. In They fired several shots at him, which fortunately did not hit
him. A copy of the Affidavit of complainant Agustin is hereto attached
as Annex “EE”.
Page 7 of 17

6. Complainants are also filing charges of Violation of R.A.


9745 (Anti-Torture Law), Violation of R.A. 7438 (Rights of Accused),
B.P. 880 (Public Assembly Act), P.D. 1829 (Obstruction of Justice).,

7. Respondents, in conspiracy with each other, committed


different acts of physical and mental torture on the complainants,
including being handcuffed to a hospital bed, denial of immediate
medical attention, scoffing at ones injuries and threat of being
summarily executed, the details of which are specified in the
respective affidavits of complainants.

8. Respondents, in conspiracy with each other, also did not


apprise the complainants of their basic constitutional rights, and to
counsel, and to be informed of this rights upon arrest.

9. Respondents, in conspiracy with each other, furthermore


violated the proscription of bearing firearms at a public assembly
while staying within the prohibited distance to such mass gathering.

10. Respondents moreover, in conspiracy with each other


destroyed and contaminated the crime scene by bulldozing the area;
by confiscating or burning the clothes and personal effects of the
complainants; by prejudging the investigation of the incident and
exonerating prematurely the police and military; and by
manufacturing perjured testimony through a professional witness that
slandered even the dead rallyist, among others.

11. Complainants are also filing ADMINISTRATIVE


COMPLAINTS against the said respondent public officers for Gross
Misconduct, Grave Abuse of Authority, Gross Oppression and for
Conduct Unbecoming of a Public Officer in relation to their aforesaid
criminal acts.

12. The following common facts further establish the basis of


the charges, as well as the individual liabilities of all the respondents:

a. The foregoing criminal acts were committed by the


respondents in relation to their office.

b. Respondent Talino–Mendoza convened the North


Cotabato Crisis Committee to deal with the protest action. The Crisis
Committee was composed of respondent Talino-Mendoza,
Evangelista, Armilla, Tagum and Calinga. It was the committee which
decided to disperse the protest action, and which crafted the plan on
how to implement their decisionn. The decision to disperse the
Page 8 of 17

protest action, and the plan for dispersal operation were carried out
by respondents Tagum, Evangelista and Calinga. However, before
the actual implementation was carried out, they sought further
directives and guidance from respondents Armilla (as Regional
Director), Badian and Nerez. Respondent Armilla admitted that he
also sought guidance from Police Director General Ricardo Marquez.

c. The flow of command and directives leading to the


implementation of the order to disperse as decided by Crisis
Committee were revealed by the respondents police officers during
the April 7, 2016 hearing of the Senate Committee on Human Rights.
This evidently show the complicity and acquiescence, not only of the
provincial and regional officers of the PN, but also that of respondent
Marques (Please see : Transcript of Stenographic Notes of the
hearing of the Senate Committee on Human Rights held on April 7,
2016 at www.senate.gov.ph.)2
2
SEN. A. CAYETANO. Yes. So may I ask now the regional director. Sir, who
made the call na “Ngayong alas diyes, mag-disperse na tayo”? We’ll give you
time later on. But just so that masundan lang natin kwento ni Governor from the
farmers.

MR. ARMILLA. Yes, sir. Ito po iyong premise from my end. On March 31, sir,
per instruction rin ni chief regarding doon sa situation—

SEN. A. CAYETANO. Sorry. Instruction, sir, ni?

MR. ARMILLA. Ni chief, PNP.

SEN. A. CAYETANO. Okay.

MR. ARMILLA. Tinatanong po. Kasi hindi na, sir, ako nagattend ng command
conference dito sa Davao--

SEN. A. CAYETANO. So the chief, PNP was involved already.

MR. ARMILLA. Yeah, yeah. From time--no, he’s not involved, sir. From
time to time, I see to it that my immediate upline maiinform siya. That was
on the--I have my text here. So sabi niya,“Sige, bro, you just handle the
situation in the area,” that’s why hindi na ako nag-attend ng command
conference. So that was on the 31, sir—

SEN. A. CAYETANO. What was the instruction, sir, na ikaw ang bahala
sa sitwasyon or you listen to the crisis committee?

MR. ARMILLA. The crisis committee, sir, is with us pero iyong sinasabing
judgment call is with the police.2

xxx

SEN. A. CAYETANO. Sir, what I want to know who made the


decision to clear.

MR. ARMILLA. Sir, I’ll refer it to my provincial director.


Page 9 of 17

c. Respondent Talino-Mendoza admitted during the second


hearing of the Senate Committee on Human Rights on April 20, 2016
in Manila that Police Director General Ricardo Marquez was in Davao
City for a Command Conference before the implementation of her
order to disperse the protesters. For his part, Director General
Marquez admitted in several media interviews that he was personally
apprised of the situation, and was regularly updated of the
development of the operation, which gave him personal knowledge of
the operation, and put him in a position to stop the violence. As a
matter of fact respondent Marquez was all this time privy to the

SEN. A. CAYETANO. Okay. Sir, kay provincial director, who made the
decision noong alas diyes ng umaga na iyon na mag-clear? It’s not an
illegal decision, I just want to know sino ang gumawa ng decision na time
to clear.

MR. TAGUM. Sir, I received a go signal, sir, from my regional


director.

SEN. A. CAYETANO. Sorry. You received...?

MR. TAGUM. From my regional director, sir.

MR. ARMILLA. Ang guidance, sir, from me to Alex is clear the


highway without the police action.

SEN. A. CAYETANO. So, kayo ang nagbigay ng decision, sir, na clear


the highway na?

MR. ARMILLA. Yes, sir.

SEN. A. CAYETANO. Kailan n’yo binigay n’yo, sir?

MR. ARMILLA. That was on the 31, sir.

SEN. A. CAYETANO. 31. So kung kailan gawin ng provincial


director, you left it up to him depende sa sitwasyon sa ground.

MR. ARMILLA. Yes, sir, that’s it, sir.

SEN. A. CAYETANO. Wala kang ibinigay na oras or—

MR. ARMILLA. Yes, sir. There was a time pa kasi, sir. Sabi ni Gov, “RD,
please, kailangan nating i-negotiate pa.” That’s why umabot pa ng
kinabukasan. May standing order na, sir, kasi ako na, “Be sure nasa
proper police action tayo and...”

SEN. A. CAYETANO. Yes, because it’s a national highway, sir.


That’s why I said I’m not saying na illegal iyong decision. Gusto ko lang
sundan. So 31 po, sinabi mo sa provincial director, “Pwede nang i-clear
iyan.”

MR. ARMILLA. Yes, sir.


Page 10 of 17

operation of his subordinate police officers and men. (Please see:


www.senate.gov.ph)

d. In carrying out the dispersal operation, the Crisis


Management Team authorized the deployment of more than 200
heavily armed, combat ready policemen from the Special Weapons
and Tactics and the PNP Strike Force. The deployment of these
battle ready policemen was an indication of the premeditated plan to
use violence and firearms in the dispersal operation. As admitted by
respondent Talino Mendoza, the situation was handled by the Crisis
Management Team, and as such, only the team can order the
deployment. Respondent Tagum likewise admitted that the order to
carry out the planned dispersal operation was given by respondent
Talino – Mendoza, a claim that the latter did not disput.

e. As testified to by witnesses, respondent Evangelista gave


a five minute ultimatum to the protesters, but even before the time
was up, respondent Tagum fired three (3) warning shots which gave
the signal for the CDM unit to move forward, pushed the protesters
with their shield and hit them with their batons. This was followed by
water cannons fired by the firetrucks of the Bureau of Fire Protection
under the command of respondent Noa Pacalda. The ranks of the
protesters broke, and they started to scamper. It was at this point that
stones were thrown at them from the direction of the policemen, then
bursts of gunfire were heard.

Copies of the Affidavit of Jerome Alladin Aba, a member of the


negotiating panel that negotiated with the police before the dispersal
narrating the events immediately prior to, during and after the
dispersal, the compact disc containing video footages as well as the
pictures of the dispersal are hereto attached as Annexes “FF”,
“GG” and “HH”, respectively. Finally, a copy of the Report of the
National Fact Finding and Humanitarian Mission is attached as
Annex “II”.

f. After the shooting, Darwin Sulang died, while


complainants Lumondang, Takyawan and Delgado and several other
protesters sustained injuries.

g. The intention to kill is evident from the manner of the


shooting, and the injuries sustained by the victims. As stated earlier,
Darwin Sulang sustained a single gunshot wound at the center of his
forehead. It was further established that the bullet that killed him
came from a high powered rifle obviously aimed specifically to kill
him.
Page 11 of 17

h. Complainant Takyawan was shot twice, even if he was


already running. Complainant Lumondang, who came to the rescue
of complainant Takyawan was likewise shot at the back of his neck
and in six other parts of his body. Complainant Delgado was likewise
targeted and was hit in his right leg, while complainant Agustin was
repeatedly shot at by the same policeman who killed Darwin Sulang,
but fortunately he was not hit.

i. The shooters who came from the ranks of the police and
military were deployed at strategic positions to be able to take aims at
the protesters. Aside from armed policemen on top of firetrucks,
several more were seen strategically positioned around the
protesters. The strategic positions of the armed policemen is an
indication that the violence and the killing were carefully planned and
premeditated, and the use of high powered rifle ensured to weaken
the defense of the herein victims, and to ensure impunity, coupled by
the use of disproportionate and superior strength.

j. To reiterate, the order to disperse and the plan on how


the dispersal was to be carried out was carefully hatched by the
Crisis Committee of which respondents Talino Mendoza, Armilla,
Tagum, Evangelista and Calinga were members. The plan was
obviously with the acquiescence of respondents Badian and Nerez,
and was finally carried out after respondent Marquez was sufficiently
informed of such plan. These respondents evidently conspired and
acted in concert in the planning and the carrying out of the dispersal
operation, which in turn resulted in the killing of Darwin Sulang and
causing injuries the complainants.

k. Respondents Evangelista, Tagum and Calinga were the


ones who carried out the directives and they were present during the
dispersal itself. It was respondent Evangelista who gave the
ultimatum to disperse, and it was respondent Tagum who gave the
orders to both the Civil Disturbance Management Unit as well as the
fully armed and battle ready policemen to disperse the rally.
Respondent Calinga was also responsible as the Chief of Police of
Kidapawan City, and the order or command to disperse actually
passed through him. As a result of the order, the policemen carried
out their well laid plan and started shooting at the designated targets.

l. For his part, respondent Sarmiento, in utter callousness,


precipitately bestowed medals on police personnel even before the
dead were buried and the wounded were still recuperating from their
fresh wounds. He also deliberately misled, confused and prejudged
the so-called investigation by public exonerating the involved
policemen. Worse, he even publicly lied by claiming that the cause of
Page 12 of 17

death of the death farmers were due to heat stroke or mauling, a wild
claim scientifically debunked by the aforementioned Autopsy Report
of Dr. Fortun.

m. All these acts of respondent Sarmiento are tantamount to


deliberate acts of obstruction of justice which is furthermore
condoned by his immediate principal, former DILG Secretary Mar
Roxas, in concert with President Benigno Aquino III, and members of
his cabinet including Agriculture Secretary Proceso Alcala,
Communications Secretary Sonny Coloma, Communications
Undersecretry Manolo Quezon, III, among others.

n. Respondent Pasco, a confessed saboteur, and


professional witness, admitted during the hearing of the Senate
Committee on Human Rights on April 20, 2016 that he was sent by
his handlers from the 39th Infantry Batallion to infiltrate the protest
action. With his admission, it is clear that he also participated in the
operation, and was at the scene of the crime at time it occurred.
Moreover, he also admitted that he was the last person to have seen
Darwin alive. As an infiltrator, respondent Pasco is complicit and part
of the conspiracy that led to death of Darwin, and the injuries
sustained by the other complainants. On his own account, he is liable
for perjury, slander, obstruction of justice and incriminatory
machination, charges which will be filed separately and in due time.

o. Respondent Pasco’s testimony established the criminal


liability of respondent Argamosa, Battalion Commander of the 39th
Infantry Battalion-Philippine Army, the handler of respondent Pasco,
and who evidently authorized his participation and deployed soldiers
from his battalion around Spottswood Methodist Center. The order to
infliltrate and to deploy troops were with the knowledge and consent
of respondent Villanueva as the commander of 1002nd Brigade
Commander, and respondent Valencia of the 10th Infantry Division-
Philippine Army. These facts also show that they are part of the
operation that led to the violent dispersal, and that they in concert
with the other respondents. As a matter of fact, the video footages
show that there were several other John Does pretending to be
farmers who mixed into the crowd.

13. The complainants may be served with subpoena and


notices through the undersigned counsels.

14. The respondents may be served with subpoena and


notices as follows:
Page 13 of 17

Mel Senen Sarmient : Office of the Secretary


Dept. of the Interior and
Local Government
NAPOLCOM Building
Quezon Ave. corner EDSA
Quezon City

Emilou T. Mendoza : Office of the Governor


Provincial Capitol, Amas
Kidapawan City, North Cotabato

Joseph Evangelista : Office of the Mayor


City Hall, Kidapawan City
North Cotabato

Ricardo Marquez : Office of the Director General


Philippine National Police
PNP National Headquarters
Camp Crame, Quezon City
1100 Metro Manila

Noel Armilla : Office of the Regional Director


Police Regional Office 12
Brgy. Tambler, General Santos City
South Cotabato

Roberto Badian : Office of the Deputy Regional


Director for Operations
Police Regional Office 12
Brgy. Tambler, General Santos City
South Cotabato

Alexander Tagum : c/o Police Regional Office 12


Brgy. Tambler, General Santos City
South Cotabato

Isagani Nerez : Directorate for Police Operations


Police Regional Office 12
Camp Lira, General Santos City
South Cotabato

John Calinga : Kidapawan City Police Office


Digos-Sultan Kudarat Road
Page 14 of 17

Kidapawan City, North Cotabato

Jerson Birrey : PNP Public Safety Batallion


Police Regional Office 12
Brgy. Tambler, General Santos City
South Cotabato

Rafael Valencia : 10th Infantry Division


Camp Gen. Manuel T. Yan, Sr.
Brgy. Tuboran, Mawab
Compostela Valley

Arnold Argamosa : 39th Infantry Battalion, Philippine Army


Poblacion, Makilala, North Cotabato

Ronald Villanueva : 1002nd Brigade-Philippine Army


Poblacion, Makilala, North Cotabato

Charlie Pasco : c/o 39th Infantry Batallion


Poblacion, Makilala, North Cotabato

OTHER respondents : c/o Police Regional Office 12


certain SGT OBIANO Brgy. Tambler, General Santos City
SPO1 BOYNEL South Cotabato
LUMOGDANG,
P01 SOLON and
P02 BALDUA)

John Does/Jane Does : c/o Police Regional Office 12


Brgy. Tambler, General Santos City
South Cotabato

We trust that the foregoing is sufficient for the filing of the


appropriate Information, and the imposition of the appropriate
administrative sanctions against the above-named respondents, and
request that the respondents public officers be suspended from office
pending investigation.

Davao City. April 25, 2016.

EBAO SULANG VICTOR LUMUNDANG, JR.


Page 15 of 17

ARNEL TAKYAWAN MARK ANTHONY DELGADO

LUMERIANO AGUSTIN

ASSISTED BY:

NATIONAL UNION OF PEOPLES' LAWYERS


Counsel for the COmplainants
3/F Erythrina Building
#1 Matatag cor. Maaralin Sts.
Central District, Quezon City 1101
Email address nupl2007@gmail.com
Telefax number (+632) 9206660

By:

EDRE U. OLALIA
IBP No.1026436-1/25/16-RSM
PTR No. 2353568C- 1/21/16- Quezon City
Roll of Attorneys No. 36971
MCLE Compliance No. IV-0016615 - 04/11/2013
(MCLE 5th Compliance under process)

JULIAN F. OLIVA, JR.


IBP No.1026438-1/25/16- RSM
PTR No. 2353570C- 1/21/16- Quezon City
Roll of Attorneys No. 35870
MCLE Compliance No. IV-0021476 - 07/26/2013
(MCLE 5th Compliance under process)

EPHRAIM B. CORTEZ
IBP No. 1026437 - 1/25/16 – Isabela
PTR No. 2353569C - 1/21/16- Quezon City
Roll of Attorneys No. 41366
Page 16 of 17

MCLE Compliance No. IV-0018068 - 04/25/2013


(MCLE 5th Compliance under process)

MARIA CRISTINA YAMBOT


PTR No. 4996582/1-07-16/Rizal
IBP No. 1026440/1-25-16/Rizal
Roll No. 59700
MCLE Compliance No. V – 0016653 4-4-16

MINERVA F. LOPEZ
PTR No. 2131515/01-04-16/QC
IBP LR No. 011325 - 01/04/13- Pangasinan
Roll No. 60637
MCLE Compliance No. V -0016666/04-4-16

JOSALEE S. DEINLA
IBP No.1026439-1/25/16/ Quezon City
PTR No. 2353571C- 1/21/16- Quezon City
Roll of Attorneys No. 64967
Admitted to the Bar 2015, MCLE not yet required

PUBLIC INTEREST LAW CENTER


Counsel for the Complainants
4/F Kaija Building, 7836 Makati Avenue
Corner Valdez Street, Makati City
Tel. No. (632) 899-3439; Tel. Fax No. (632) 899-3416
Email address: publicinterestlawcenter@gmail.com

By:
Page 17 of 17

RACHEL F. PASTORES AMYLYN B. SATO


IBP No. 1020877; 01/06/16; Makati IBP No. 1020876; 01/06/16; Q.C.
PTR No. 5329124; 01/06/16; Makati PTR No. 2183336; 01/07/16; Q.C.
Roll No. 39818 Roll No. 50389
MCLE Compliance MCLE Compliance
Number IV-0019444; 04-30-13 Number IV-0019952; 05-06-13

SANDRA JILL S. SANTOS CARLOS MONTEMAYOR, JR.


IBP NO. 1020874; 01/06/16; RSM IBP No. 1020873; 01/06/16; Q.C
PTR NO. 2623245; 01/06/16;Mand. PTR No. 2183337; 01/07/16; Q.C.
Roll No. 59809 Roll No. 61085
MCLE Compliance MCLE Compliance
Number IV – 0020709; 06-13-13 Number IV – 0017620; 04-22-13

MARIA KRISTINA C. CONTI


IBP Lifetime Member No. 012641 - Batangas
PTR No. 2183339; 01/07/16; Quezon City
Roll of Attorneys No. 63574
Admitted to the Bar 2014, MCLE not yet required