REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF THE INTERIOR AND LOCAL GOVERNMENT

NATIONAL POLICE COMMISSION
DILG NAPOLCOM CENTER
EDSA CORNER QUEZON AVENUE, QUEZON CITY, 1104
METRO MANILA, PHILIPPINES

ZENAIDA DUHAY ET AL.,

Complainants,

-versus - SD Case No. 2010-1964

For: Grave Misconduct
P/SUPT. ABUSAMA MAGUID, ET AL.,
Respondents.
X----------------------------------------------X

SECOND MOTION
FOR IMMEDIATE RESOLUTION
(OF THIS ADMINISTRATIVE CASE)

COMPLAINANTS, by counsel, respectfully file before the

Honorable Commission this Second Motion for Immediate Resolution (of
this Administrative Case), and state that:

1) On 17 December 2010, Complainants filed before the

Honorable Office their Formal Offer of Evidence in this administrative
case. It has been four (4) years and eleven (11) months since Complainants
filed their Formal Offer of Evidence in this administrative case.

2) Further, from June 2011 to September 2011, Complainants

received the respective formal offer of evidence of the different groups of
Respondents, who are represented by different counsels.

3) On 13 September 2011, Complainants received the Formal

Offer of Documents for the Respondents of Respondents who are members
of the 1507th Maguindanao Police Mobile Group, represented by
Atty. Laguindab A. Marohombsar. This formal offer of evidence is the last
formal offer of evidence to be filed. Hence, with this formal offer of
evidence, all of the Respondents in this administrative case have already
filed their respective formal offer of evidence.

4) On 29 September 2011, Complainants filed their corresponding

Comment to the last formal offer of evidence that they received. Hence, it
has been four (4) years, one month, and twenty-five (25) days since

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Complainants filed their Comment to the last formal offer of evidence
they have received in this administrative case.

5) Further, on 19 November 2014, Complainants filed before this

Honorable Commission a Motion for Immediate Resolution, praying
therein that this Honorable Commission immediately resolve this
administrative case.

6) Nevertheless, Complainants are not aware and have not

formally received any resolution of this administrative case from this
Honorable Commission.

7) In fact, today23 November 2015--- is exactly six (6) years

since the 23 November 2009 Maguindanao Massacre. Nevertheless,
Complainants are not aware and have not formally received any resolution
of this administrative case from this Honorable Commission.

8) Further, the only main legal issue to be resolved in this

administrative case is whether or not herein Respondents policemen are
administratively liable for grave misconduct in relation to their respective
conducts as policemen when the 23 November 2009 Maguindanao massacre
happened. Also, it only requires substantial evidence to determine the main
legal issue of this administrative case.

9) Moreover, Complainants, as family members of the thirteen

(13) victims of the 23 November 2009 Maguindanao massacre,
under the applicable principles of international human rights law, are entitled
to due recognition of victimhood and effective participation in the search for
legal remedies---including this administrative case--- to the injury they
suffered as a result of the gruesome death of their loved ones.

10) Therefore, Complainants respectfully pray that the Honorable

Commission immediately resolve this administrative case.

PRAYER

WHEREFORE, premises considered, Complainants respectfully pray

that the Honorable Commission IMMEDIATELY RESOLVE this
administrative case.

Other reliefs that are just and equitable under the premises are
likewise prayed for.
Makati City for Quezon City, 23 November 2015.

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 By the Counsel for Complainants:

ROQUE & BUTUYAN LAW OFFICES

1904 Antel 2000 Corporate Center
121 Valero Street, Salcedo Village
Makati City 1200
Email: mail@roquebutuyan.com
Tel. Nos. 887-4445/887-3894;
Fax No: 887-3893

By:

H. HARRY L. ROQUE, JR.

Roll No. 36976
PTR No. 4781976|Jan 30, 2015|Makati City
IBP No. 01749|Lifetime
MCLE Exemption No. IV-000513
(issued on Feb 15, 2013)

ROMEL R. BAGARES
Roll No. 49518
PTR No. 4781972|Jan. 30, 2015|Makati City
IBP No. 0993980|Jan. 30, 2015|So. Cotabato
MCLE Compliance No. IV-0011822
(issued on Jan. 25, 2013)

GILBERT T. ANDRES
Roll No. 56911
PTR No. 4781973|Jan. 30, 2015|Makati City
IBP No. 0993979|Jan. 30, 2015|Negros Occ.
MCLE Compliance No. IV-0011824
(issued on Jan. 25, 2013)

Copy furnished:

AD HOC COMMITTEE
Dilg Napolcom Center
Edsa Corner Quezon Avenue, Quezon City, 1104
Metro Manila, Philippines

INVESTIGATION AND MONITORING DIVISION

Dilg Napolcom Center
Edsa Corner Quezon Avenue, Quezon City, 1104
Metro Manila, Philippines

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ATTY. LAGUINDAB A. MAROHOMBSAR
PUBLIC ATTORNEYS OFFICE
Hall of Justice, DPWH Compound
Upper Bicutan, Taguig City

ATTY. ABDULKALIM A. ASKALI

Feranceullo Evora Askali Law Firm
Room 206, C.K. Sy Diamond Bldg.
156 Libertad St., Pasay City

ATTY. JOSE EMILIO VALENTIN

6 Notre Dame Avenue, Cotabato City

KHO BUSTOS MALCONTENTO ARGOSINO LAW OFFICES

Unit 1103, 11th Flr., Prestige Tower Condominium
F. Ortigas Jr., Pasig City

ATTY. MARLON G. PAGADUAN

Rm. 48-B, 4th Flr, Zeta Bldg.
191 Salcedo St., Legaspi Village
Makati City

BETITO PEA & ASSOCIATES LAW OFFICES

U-709, 7th Flr. CityLand Mega Plaza
ADB Avenue
Ortigas Center, Pasig City

ATTY. FERDINAND TAMACA

Rm. 306, Masonic Bldg.
35 Matalino St., Diliman,
Quezon City

ATTY. JONATHAN PRESQUITO

Fabtech Bldg., 1229 Quezon Avenue
1104 Quezon City

ATTY. FEDERICO F. BIOLENA

Ching Mendoza Quilas Florendo Biolena Ching and Partners
Suites 2503 & 2504 Atlanta Center
25th Floor, 31 Annapolis Street
Greenhills, San Juan City

ATTY. ADILBERTO V. GOLLA, JR.

Golla and Associates Law Office
Suite 911 Espaa Tower
Espaa Avenue, Sampaloc
1008 Manila, Philippines

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ATTY. TAHIR LIDASAN
23 Malinis Street, UP Village
Diliman, Quezon City

NOTICE OF HEARING
AND
EXPLANATION

THE HON. CLERK OF THE HONORABLE OFFICE

Dilg Napolcom Center
Edsa Corner Quezon Avenue, Quezon City, 1104
Metro Manila, Philippines

INVESTIGATION AND MONITORING DIVISION

Dilg Napolcom Center
Edsa Corner Quezon Avenue, Quezon City, 1104
Metro Manila, Philippines

ATTY. LAGUINDAB A. MAROHOMBSAR

PUBLIC ATTORNEYS OFFICE
Hall of Justice, DPWH Compound
Upper Bicutan, Taguig City

ATTY. ABDULKALIM A. ASKALI

Feranceullo Evora Askali Law Firm
Room 206, C.K. Sy Diamond Bldg.
156 Libertad St., Pasay City

ATTY. JOSE EMILIO VALENTIN

6 Notre Dame Avenue, Cotabato City

KHO BUSTOS MALCONTENTO ARGOSINO LAW OFFICES

Unit 1103, 11th Flr., Prestige Tower Condominium
F. Ortigas Jr., Pasig City

ATTY. MARLON G. PAGADUAN

Rm. 48-B, 4th Flr, Zeta Bldg.
191 Salcedo St., Legaspi Village
Makati City

BETITO PEA & ASSOCIATES LAW OFFICES

U-709, 7th Flr. CityLand Mega Plaza
ADB Avenue
Ortigas Center, Pasig City

5
ATTY. FERDINAND TAMACA
Rm. 306, Masonic Bldg.
35 Matalino St., Diliman,
Quezon City

ATTY. JONATHAN PRESQUITO

Fabtech Bldg., 1229 Quezon Avenue
1104 Quezon City

ATTY. FEDERICO F. BIOLENA

Ching Mendoza Quilas Florendo Biolena Ching and Partners
Suites 2503 & 2504 Atlanta Center
25th Floor, 31 Annapolis Street
Greenhills, San Juan City

ATTY. ADILBERTO V. GOLLA, JR.

Golla and Associates Law Office
Suite 911 Espaa Tower
Espaa Avenue, Sampaloc
1008 Manila, Philippines

ATTY. TAHIR LIDASAN

23 Malinis Street, UP Village
Diliman, Quezon City

Please take note that the undersigned counsel will submit the
foregoing Second Motion for the immediate consideration and approval of
the Honorable Commission immediately upon receipt thereof.

Also, due to the distance between the parties and their counsel and
due to lack of manpower, this Second Motion for Immediate Resolution is
being served to the other parties by registered mail.

GILBERT T. ANDRES