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Republic of the Philippines REGIONAL TRIAL COURT National Capital Judicial Region Antipolo - Branch 191 IN RE: PETITION

FOR WRIT OF KALIKASAN SP No. 111334 Golden Meadows Home Owners Association, Town and Country Executive Village Home Owners, Filinvest East Homeowners Association, Samsonville Homeowners Association, MidtownHomeowners Association, Tresmarias Homeowners Association, Petitioner. Steel for Fears Inc., Chairman Ricardo Tinga, Chairman Emmanuel Santos, Respondent. x----------------------------------------------------------x Petitioner, though counsel, and unto this Honorable Court, respectfully avers that; 1.This is a petition for the issuance of a Writ of Kalikasan, filed with this Honorable Court pursuant to Rule 7 of A.M. No. 09-6-8-SC, otherwise known as the Rules of Procedure for Environmental Cases, concerning as it is the violation of theconstitutional rights of the residents of the Cities of Marikina and Antipolo to a balanced and healthful ecology. 2.This is a class suit, Petitioners are residents and inhabitants of Barangay Mayamot, Antipolo City and Brangay San Roque, Marikina City, registeredassociations with capacity to sue, Petitioners may be served with the orders, resolutions, notices and processes of this Honorable Court through their counsel of record, Atty. Manuel Miklat, 8floor Strata 2000, Ortigas Center, Pasig City. 3.Respondent STEELS FOR FEARS (SFF) is a domestic corporation created andorganized pursuant to the laws of the Republic of the Philippines with principaloffice address at Lepanto Building, Ortigas Avenue, Pasig City, where it may beserved with summons and other processes of this Honorable Court 4.Respondent BARANGAY CHAIRMAN RICARDO TINGA is the Barangay Chairman of Mayamot, Antipolo. 5.Respondent BARANGAY CHAIRMAN EMMANUEL SANTOS is the Barangay Chairman of San Roque, Marikina.

STATEMENT OF FACTS 6.Filinvest East, Golden Meadows, Samsonville are private residential subdivisionslocated at Barangay Mayamot, Antipolo 7.Town and Country and Midtown are private residential subdivisions located atBarangay San Roque, Marikina City. 8.Petitioners are associations of residents of the said private subdivisions, andinhabitants of Barangay Mayamot and Barangay San Roques, respectively. Somehave likewise established their respective business and livelihood therein. 9.On June 27, 2010, without the consultation with the constituents of Barangay Mayamot, Chairman Ricardo Tinga issue a Barangay Working Permit Clearancefor the operation of a steel melting factory in the parcel of land owned by STEELSFOR FEARS along Marcos Highway. 10.On the same date, Emmanuel Santos Chairman of Barangay San Roque, issued a Working Permit Clearance for the same operation, for the same company and onthe same parcel of land. 11.The land occupying the boundaries of the two (2) cities, both barangay permitshad to be attained. 12.Despite the proximity of the operation of melting metal nearby residential areas,the inhabitants were not notified or consulted with respect to such plans. 13.Sometime in August 2010, the operation of the plant increased and the residents began to notice the existence of such plant in their area. 14. After some months the residents of the said subdivisions noticed that black smoke usually is emitted from the steel plant. Also, the drainage system of the plant goes directly in the creek which runs all the way around the village of Townand Country and Golden Meadows. The blackening of the water is very noticeableand the stench of the water is very evident. 15.The alarming presence of the plant and its close proximity to nearby residentialareas is very hazardous to the health and safety of petitioners. 16.Due to the urgency of the situation there is a need to protect the petitioners fromthe hazardous and ill effects of the same.

WHEREOF, it is respectfully prayed, that:


1. A Writ of Kalikasan be immediately issued.

2.An order be likewise issued after hearing, enjoining respondent corporationfrom continuing its operation. Other reliefs just and equitable are likewise prayed for. Antipolo City, April 22, 2011. Atty. Manuel Miklat Counsel for Petitioners
VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING REPUBLIC OF THE PHILIPPINES ) CITY OF MANILA ) S.S. We, Golden Meadows Homeowners Association, Filinvest East Homeowners Association, Town and Country Homeowners Association, Midtown Homeowners Association and Samsonville Homeowners Association, all registered associations, afterhaving been duly sworn in accordance with law, depose and state that: 1. We are the plaintiffs in the above-stated case; 2. We caused the preparation of the foregoing complaint; 3. We have read the contents thereof and the facts stated therein are true andcorrect of my personal knowledge and/or on the basis of copies of documents andrecords in my possession; 4. We have not commenced any other action or proceeding involving the same issues in the Supreme Court, the Court of Appeals, or any other tribunal or agency; 5. To the best of my knowledge and belief, no such action or proceeding ispending in the Supreme Court, the Court of Appeals, or any other tribunal or agency; 6. If we should thereafter learn that a similar action or proceeding has been filed or is pending before the Supreme Court, the Court of Appeals, or any other tribunal oragency, we undertake to report that fact within five (5) days therefrom to this Honorable Court SUBSCRIBED AND SWORN to before me this 22nd day of April 2011 at Quezon City affiant exhibiting to me his Certificate of Registrations issued on 13th of July 1980 at San Juan City. Doc. No. ; Page No. ; Book No. ; Series of 2012