REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT

12th JUDICIAL REGION
1LANAO DEL NORTE
ILIGAN CITY, BRANCH 2

SITTY NOR-AISAH M. PUMBAYA

Plaintiff,

Vs. ELECTION CASE NO.

KHARLEEN DELA CRUZ

Defendant.

OPPOSITION TO THE APPLICATION FOR VOTER’S REGISTRATION

PLAINTIFF, through Counsel, states:

1. That on January 12, 2019, defendant filed her application for voter registration in Precinct No.

0325A of BARANGAY 30 ZONE 8, SANTA ELENA ILIGAN CITY;

2. That on February 15, 2018 the defendant has been declared mentally incompetent by the proper

court;

3. That the plaintiff herein opposes her registration in the said precinct on the ground of mental

incompetence;

4. That according to Section 11 of Republic Act No. 8189, the defendant shall not be allowed to

register as voter:

Sec. 11. Disqualification. – The following shall be disqualified from registering:

(a) Any person who has been sentenced by final judgment to suffer
imprisonment of not less than one (1) year, such disability not having been
removed by plenary pardon or amnesty: Provided, however, That any person
disqualified to vote under this paragraph shall automatically reacquire the
right to vote upon expiration of five (5) years after service of sentence;

(b) Any person who has been adjudged by final judgment by a competent
court or tribunal of having committed any crime involving disloyalty to the
duly constituted government such as rebellion, sedition, violation of the
firearms laws or any crime against national security, unless restored to his
full civil and political rights in accordance with law: Provided, That he shall
automatically reacquire the right to vote upon expiration of five (5) years
after service of sentence; and

(c) Insane or incompetent persons declared as such by competent authority

unless subsequently declared by proper authority that such person is no
longer insane or incompetent.
5. That it appears that the defendant was previously confined in a mental institution

situated in Cagayan de Oro City;

6. That ten (10) days before she filed her application for registration, the defendant was

apprehended for deviant behavior;

7. That she will not be able to fulfill her duties as duly registered voter.

8. Upon a thorough review of defendants’ averments, plaintiff respectfully submits that

said Application for Voter Registration is bereft of merit.

 PRAYER

WHEREFORE, it is respectfully prayed that the defendants’ Application to Voter’s Registration be

denied and the case be set for trial. All other reliefs, just and equitable under the premises, are likewise

prayed for.

Cagayan de Oro City for Iligan City. January 12, 2019.

By:

SITTY NOR-AISAH M. PUMBAYA

Counsel for the Plaintiff
Block 8, Lot 11, Santa Elena, Iligan City
Roll No. 12345
IBP O.R. No. 123456-0-1-09
Lanao del Norte Chapter

Copy Furnished by personal service:

Kharleen Dela Cruz
Atty. Jovencio G. Balanquit, Mr. Felipe Saclamitao
And Ms. Rosario Francisco
Members of the Election Registration Board c/o Atty. Jovencio G. Balanquit, Election Officer
District 1, City of Iligan
Commission on Elections Arroceros Street, Manila