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Republic of the Philippines

DEPARTMENT OF JAIL MANAGEMENT AND PENOLOGY
REGIONAL OFFICE NO. VIII
Tacloban City

BUREAU OF JAIL MANAGEMENT Adm. Case No. 2017-01

AND PENOLOGY, REGION VIII FOR: Serious Neglect of
Duty

JO3 GERALD ANDERSON,

Complainant,

-versus-

J/INSP ENRIQUE GIL

Respondent.
x-----------------------------------------------------------------------------x

ANSWER
COMES NOW, respondent by counsel, unto this Honorable Office,
hereby files his Answer and pleads that;

1. He is the Jail Warden of the Tacloban City Jail;

2. He received the summons and the attached copies of the Charge Sheet
along with the attachments on March 1, 2017;
3. This pleading is filed to deny any culpability or liability for all the
charges against the respondent, and in defense, he hereby pleads the
following:

A. Respondent made immediate report of the incident.

Respondent lives by the rule to “always keep the commander

informed”. These are the words that ring in the mind whenever
he is engaged in the performance of his duties as a jail warden
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and every time any unusual incident happens in relation to his

job. These are the same words that his Regional Director,
J/SSupt Ian Veneracion always emphasized on them. When the
escape incident transpired, the respondent and his
subordinates had immediately pursued the escapees on foot,
and the first thing he did was to call the Regional Director using
his cellphone. Unfortunately, for the many times, respondent
could not get through because the regional director’ was out of
coverage. Respondent was trying to avoid the recurrence of
past situations when the regional director would be the last
person to learn about what is going on in the organization that
he leads and commands.
Understanding that the regional director was inspecting
some jail facilities in the area where there was no cell phone
signal, respondent texted him several times hoping that he
might immediately get the message and read it at any time
moment that he might catch a signal. At around 0945H,
respondent still could not contact the regional director. At
around 1020H, respondent again tried to call the regional
director to no avail so he decided to call J/Supt Zanjoe Marudo,
the assistant regional director and it was to him instead whom
respondent was able to report the incident.

B. The lack of a second perimeter fence is not the fault of the

respondent.

Respondent asserts that it is unfair on his part to be

charged as such because, beforehand, no funding was given for
the construction of a second perimeter fence.
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Before the end of December 2016, respondent was

already starting to construct a make shift secondary fence
outside the jail.
In his one year as the warden of Tacloban City Jail, he had
accomplished the following:
a. Repaired of hinges, cell bars and cell gate latches;
b. Purchased new heavy duty padlocks;
c. Repainted the cells;
d. Constructed garage and meeting area; and
e. Repaired the wardens’ office.

Respondent had also made representations in the

Tacloban City council requesting for funds for the repair of other
parts of the jail. He had also made requests in the regional
office.
Respondent though just had a little set back on his efforts
at improving the jail facility that time because of a strong
typhoon. He instead opted to buy relief goods to donate and
give to personnel who were devastated by the typhoon. He also
donated school supplies for the kids of BJMP personnel under
his watch.

PRAYER

WHEREFORE, foregoing premises considered, it is most humbly

prayed that respondents be afforded the benefit of a formal hearing, and
thereafter, the instant complaints be dismissed for lack of bases and merit.
Other just reliefs are likewise prayed for. Tacloban City, March 15, 2017.
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ATTY. LIZA SOBERANO

Counsel for the Respondent
PJLMV LAW OFFICES
ABC Building, Paterno St., Tacloban City
Attys Roll No. 387484/5-10-15
IBP OR No. 92929292/01-10-16, Leyte
PTR No. 83793939393/1-6-16, Palo, Leyte
MCLE Compliance No. IV-7374738383, 1-24-2016

VERIFICATION

I, J/INSP ENRIQUR GIL, of legal age, after having been duly sworn in
accordance with law, depose and state that:

1. I am the respondent in the above-stated case;

2. I caused the preparation of the foregoing position Answer; and
3. I have read the contents thereof and the facts stated therein are
true and correct of my personal knowledge and/or on the basis
of copies of authentic documents and records in my possession.

IN WITNESS HEREOF, I have hereunto affixed my signature this day

March 15, 2017, in Tacloban City, Philippines.

J/INSP ENRIQUE GIL

Affiant

Subscribed and Sworn to before me this day, March 15, 2017 in

Tacloban City, Philippines.
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ATTY. LIZA SOBERANO

Counsel for the Respondent
PJLMV LAW OFFICES
ABC Building, Paterno St., Tacloban City
Attys Roll No. 387484/5-10-15
IBP OR No. 92929292/01-10-16, Leyte
PTR No. 83793939393/1-6-16, Palo, Leyte
MCLE Compliance No. IV-7374738383, 1-24-2016

Doc No. ______

Page No. _______
Book No. _______
Series of 2017

Copy furnished: by Personal Service

JO3 GERALD ANDERSON JMP

Regional Prosecutor