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Complaint: Page 1 of 3

1. Ina Api, a PHILHEALTH employee, filed a complaint against President Duterte, the Executive Secretary, and the Secretary of the Department of Budget and Management seeking a declaratory relief regarding Executive Order 7. 2. Executive Order 7 precludes government owned and controlled corporations from granting bonuses and increasing salaries or benefits for employees. 3. The plaintiff claims EO 7 was issued without proper publication and is prejudicing his compensation and benefits. He is asking the court to determine the validity of EO 7 and declare his rights under it.

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Francis Louie Allera Humawid
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67 views3 pages

Complaint: Page 1 of 3

1. Ina Api, a PHILHEALTH employee, filed a complaint against President Duterte, the Executive Secretary, and the Secretary of the Department of Budget and Management seeking a declaratory relief regarding Executive Order 7. 2. Executive Order 7 precludes government owned and controlled corporations from granting bonuses and increasing salaries or benefits for employees. 3. The plaintiff claims EO 7 was issued without proper publication and is prejudicing his compensation and benefits. He is asking the court to determine the validity of EO 7 and declare his rights under it.

Uploaded by

Francis Louie Allera Humawid
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
You are on page 1/ 3

Page 1 of 3

ORIGINAL
Republic of the Philippines
REGIONAL TRIAL COURT
8th Judicial Region
Branch _____
Bulwagan ng Katarungan
Magsaysay Blvd., Tacloban City

INA API,
Plaintiff, CIVIL CASE No.3452
FOR:
DECLARATORY RELIEF,

-v e r s u s-

H.E. PRES. RODRIGO R. DUTERTE, In his capacity as President


of the Republic of the Philippines;
ATTY. LAW YER, in his capacity as Executive Secretary; and
MANNY MAKER, in his capacity as Secretary of the Department of
Budget and Management,
Defendants.

x----------------------------------------x

COMPLAINT

YOUR PLAINTIFF, by counsel, unto the Honorable Court


respectfully avers: THAT---

1. Ina Api,employee of PHILHEALTH, single, and a resident of Zone


6 Brgy.Pago, Tanauan, Leyte and; Defendant Rodrigo R. Duterte is the
President of the Republic of the Philippines (Pres. Duterte) while Defendant
Atty. Law Yer is the Executive Secretary of the President of the Republic of
the Philippines and Defendant Manny Maker as the Secretary of the
Department of Budget and Management;

2. Defendant issued Executive Order 7 which precluded the Board of


Directors, Trustees and/or Officers of GOCCs from granting and releasing
bonuses and allowances to members, and from increasing salary rates of
granting new or additional benefits and allowances to their employees;
Page 2 of 3

3. The petitioner claims that as a PhilHealth employee, he is affected


by the implementation of EO 7, which was issued with grave abuse of
discretion amounting to lack or excess of jurisdiction, for the same has not
ripened into law for lack of publication.

4. That the execution of such law without the necessary publication


will be inimical and greatly prejudice his rights to his compensation and
benefits;

5. I trust that the declaration by the court on this question is necessary


and would terminate the uncertainty or controversy, which give rise to the
action.

WHEREFORE, it is respectfully prayed of the Honorable Court to


determine the validity of the Executive Order in question and to declare
plaintiff’s rights and duties thereunder.

City of Tacloban, Philippines, January 12, 2020

ATTY. JUAN DELA CRUZ


Counsel for Plaintiff
Brgy. San Roque, Tanauan, Leyte
Roll No. 12345
IBP Lifetime No. 123456
PTR No. 1234567; 1-2-06; Tacloban City

Republic of the Philippines )


Province of Leyte ) SS
City of Tacloban )

VERIFICATION AND CERTIFICATE


Page 3 of 3

OF NON-FORUM SHOPPING

I, the UNDERSIGNED, is of legal age, Filipino, employee of the


PhilHealth, and with postal address at Brgy. Pago, Tanauan, Leyte, after
having been first sworn according to law, hereby depose and say: THAT—

I am the plaintiff in the above-captioned case; I have caused the


preparation of this complaint, and I have read and understood the contents
thereof and that the averments therein are true and correct of my own
personal knowledge and belief, and based on authentic records and
documents.

I have not commenced any case involving the same issues in any other
forum and to the best of my knowledge, there is no pending case, suit or
proceedings similar to the present case in any other forum, and that if I
should learn thereafter that the same case, suit or proceedings has been filed
or pending in such other forum, I shall report that fact to this Honorable
Court within five (5) days therefrom.

IN WITNESS WHEREOF, I have hereunto affixed my signature


this 12 JANUARY 2020 at Tanauan, Leyte, Philippines.

_______________ _______________ ______________

SUBSCRIBED AND SWORN to before me this 12 January 2020 at


Tanauan, Leyte, Philippines.

Doc. No. ___


Page No. ___
Book No. ___
SERIES OF 2020

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