rh law petition 204934b

7/28/2019 RH Law Petition 204934B

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When governments start trying to manage the messages andideas that men and women may articulate and threaten them withpunishment for thinking and expressing themselves in a manner notin accordance with what those in authority deem appropriate, societycould soon end up witch-hunting and burning innocent women as wellas men. The freedom to think and to express oneself, with theconcomitant right to know what others might think, is a primordial andfundamental entitlement of any man and woman in a truly democraticsociety that values and treasures the inherent worth of everyindividual. To petitioner-in-intervention, such quality of life guaranteedby no less than the Constitution is being threatened by the provisionsof "The Responsible Parenthood and Reproductive Health Act of2012" (R.A. No. 10354) [hereinafter, "RH Law", specifically Section23(a)(1) which prohibits and penalizes any health care serviceprovider, whether public or private, who shall "[k]nowingly withholdinformation or restrict the dissemination thereof, and/or intentionallyprovide incorrect information regarding programs and services onreproductive health including the right to informed choice and accessto a full range of legal, medically-safe, non-abortifacient and effectivefamily planning methods."

In this regard, it is noteworthy that some ideas about what maybe "incorrect information regarding programs and services onreproductive health" is a matter of debate. To those sold to the ideaabout something, any other point of view may be incorrect. But, theguaranty of freedom of expression allows for even a possibly

Fear of serious injury cannot alone justify suppression of freespeech and assembly. Men feared witches and burnt women. It isthe function of speech to free men from the bondage of irrationalfears. To justify suppression of free speech, there must bereasonable ground to fear that serious evil will result if free speechis practiced. There must be reasonable ground to believe that thedanger apprehended is imminent. There must be reasonableground to believe that the evil to be prevented is a serious one.Every denunciation of existing law tends in some measure toincrease the probability that there will be violation of it. Condonationof a breach enhances the probability. Expressions of approval addto the probability. Propagation of the criminal state of mind byteaching syndicalism increases it. Advocacy of law-breakingheightens it still further. But even advocacy of violation, howeverreprehensible morally, is not a justification for denying free speechwhere the advocacy falls short of incitement and there is nothing toindicate that the advocacy would be immediately acted on. Thewide difference between advocacy and incitement, betweenpreparation and attempt, between assembling and conspiracy,must be borne in mind. In order to support a finding of clear andpresent danger, it must be shown either that immediate seriousviolence was to be. expected or was advocated, or that the pastconduct furnished reason to believe that such advocacy was thencontemplated.


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incorrect idea as a means to eventually arriving at what might be thetruth.One must ever be reminded that once upon a time it washazardous to think that the earth revolved around the sun!

IINATURE OF THE CASE

This is a Petition in Intervention joining several others who havefiled several petitions (for Certiorari and Prohibition under Rule 65 ofthe Rules of Court with prayer for a permanent injunction against theChief Executive and its instrumentalities) questioning theconstitutionality of The Responsible Parenthood and ReproductiveHealth Act of 2012" (R.A. No. 10354). This petition is being filedbecause there is no remedy of appeal from the acts of the Presidentand Congress, and neither is there any other plain, speedy andadequate remedy available to petitioners in the ordinary course oflaw.

The petitioner-in-intervention has commonality of interest withsome of the points raised in the pending petitions and wishes to jointhem in that regard.

IllTHE PARTIES

Petitioner-in-intervention Atty. Samson S. Alcantara is of legalage, Filipino, the President of Social Justice Society (hereinafter,SJS), and with office address at Suite 1402, 14th Floor Manila AstralTower, Taft Avenue corner P. Faura St., Ermita, Manila where hemay be served with pleadings, orders, motions and other legalprocesses of this Honorable Court. He caused the filing of thisPetition in Intervention as a taxpayer and as a citizen who iscommitted in p r o t ~ c t i n g and advancing the rights, liberties andfreedoms of individuals as important particles of polity and society.His advocacies include the right of everyone to decide for himself orherself important and vital questions in life, such as determining whento have children and how many, as well as the means by which thisintimate matter of life is to be achieved.Respondents are public officials in charge of the enforcementand administration of the assailed law. For this reason, the followingrespondents are sued in their official capacities and may be servedpleadings, notices and other court processes at their respectiveoffices at:

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vARGUMENTS

AFREEDOM TO SPEAK IS A FUNDAMENTAL RIGHT

Whenever the Court speaks of the guaranty of the right tospeak one's mind, it does so with the recognition that it is a basic,fundamental and highly valued and treasured attribute of a society that prides itself on being republican and democratic. "The primacy,the high estate accorded freedom of expression is of course afundamental postulate of our constitutional system."2

"When on its face, it is clear that a governmental act is nothingmore than a naked means to prevent the free exercise of speech, itmust be nullified," thus declared the Court at the very outset inChavez v. Gonzales, 545 SCRA 441, 4 73 (2008 ). The Court went onto further highlight the high value that speech and the press have byholding that "[i]n this jurisdiction, it is established that freedom of thepress is crucial and so inextricably woven into the right to free speechand free expression, that any attempt to restrict it must be met withan examination so critical that only a danger that is clear and presentwould be allowed to curtail it."3 Elsewhere, the Court characterizedfreedom of expression as "the most exalted of all the civil rights."4The Court also observed that "[i]n the Philippines, the primacy andhigh esteem accorded freedom of expression is a fundamentalpostulate of our constitutional system. "5

In the earlier case of Gonzales v. Commission on Elections, 27SCRA 835 (1969), the Court expounded on the value of speech andthe concomitant right to conform or not:The vital need in a constitutional democracy forfreedom of expression is undeniable whether as a means

of assuring individual self.,.fulfillment, of attaining the truth,of securing participation by the people in social includingpolitical decision-making, and of maintaining the balancebetween stability and change. The trend as reflected inPhilippine and American decisions is to recognize thebroadest scope and assure the widest latitude to thisconstitutional guaranty. It represents a profoundcommitment to the principle that debate of public issue2 Gonzales v. Commission on Elections, 27 SCRA 835, 856 (1969).3 Ibid.4 /d., at 480.5 /d., at 482.


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should be uninhibited, robust, and wide-open. It is notgoing too far, according to another American decision, toview the function of free speech as inviting dispute. "Itmay indeed best serve its high purpose when it induces acondition of unrest, creates dissatisfaction with conditionsas they are, or even stirs people to anger."

Freedom of speech and of the press thus meanssomething more than the right to approve existing politicalbeliefs or economic arrangements, to lend support toofficial measures, to take refuge in the existing climate ofopinion on any matter of public consequence. Soatrophied, the right becomes meaningless. The rightbelongs as well, if not more, for those who question, whodo not conform, who differ. To paraphrase JusticeHolmes, it is freedom for the thought that we hate, no lessthan for the thought that agrees with us."6In regard to political dissent, which might as well be appliedmutatis mutandis to non-conformity and disagreement relative togovernment-sponsored programs, we have these enlightening wordsfrom a case decided when the country was still under less liberalgovernment:

We have adopted the concept that freedom ofexpression is a "preferred" right and, therefore, stands ona higher level than substantive economic or otherliberties. The primacy, the high estate accorded freedomof expression is a fundamental postulate of ourconstitutional system. (Gonzales v. Commission onElections, 29 SCRA 835). As explained by JusticeCardozo in Palko v. Connecticut (302 U.S. 319) this mustbe so because the lessons of history, both political andlegal, illustrate that freedom of thought and speech is theindispensable condition of nearly every other form offreedom. Protection is especially mandated for politicaldiscussions. This Court is particularly concerned whenallegations are made that restraints have been imposedupon mere criticisms of government and public officials.Political discussion is essential to the ascertainment ofpolitical truth. It cannot be the basis of criminalindictments. 7

Further, the Court has also held:All of the protections expressed in the Bill of Rights

6 At 857-858; Italics supplied.7 Salonga v. Cruz Paflo, 134 SCRA 438, 458-459 (1985).

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,, .are important but we have accorded to free speech thestatus of a preferred freedom. (Thomas v. Collins, 323 US516, 89 L. Ed. 430 [1945]; Mutuc v. Commission onElections, 36 SCRA 228 [ 1970]).

This qualitative significance of freedom ofexpression arises from the fact that it is the matrix, theindispensable condition of nearly every other freedom.(Palko v. Connecticut, 302 U.S. 319 [1937]; Salonga v.Pallo, 134 SCRA 438 [1985]) It is difficult to imagine howthe other provisions of the Bill of Rights and the right tofree elections may be guaranteed if the freedom to speakand to convince or persuade is denied and taken away.

We have adopted the principle that debate on publicissues should be uninhibited, robust, and wide open andthat it may well include vehement, caustic and sometimesunpleasantly sharp attacks on government and publicofficials. (New York Times Co. v. Sullivan, 376 U.S. 254,11 L. Ed. 686 [1964]; cited in the concurring opinion ofthen Chief Justice Enrique Fernando in Babst v. NationalIntelligence Board, 132 SCRA 316 [1984]) Too manyrestrictions will deny to people the robust, uninhibited, andwide open debate, the generating of interest essential ifour elections will truly be free, clean and honest. 8Given the preferred status given to the freedom of expression, itfollows that it demands more from the government to justify anyrestriction placed on speech, such as the provision in the RH Lawprohibiting and penalizing the dissemination of ideas or views whichmay be characterized as incorrect just because it does not conform tothe authorities' ideas.

8SECTION 23(A)(1) OF THE RH LAWIS CONTENT -BASED REGULATION

A close scrutiny of the assailed provision, Section 23(a)(1) ofthe RH Law would disclose that it is a content-based regulation. It isdirected at the message that is sought to be disseminated, outlawingit simply because it does not conform to what the government wants.Content-based restrictions - those which either approve ordisapprove based on the contents of the expression, such as favoringor disfavoring some topics - are anathema to the guaranty of free8 B/o Umpar Adiong v. Commission on Elections, 207 SCRA 712, 715-716(1992).


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speech because they "distort public debate, have impropermotivation, and are usually imposed because of fear of how peoplewill react to a particular speech."9 "Clearly, content-based priorrestraint is highly abhorred in every jurisdiction."10 Such is thecase of the assailed provision here. The government wants to outlawand penalize speech that does not conform to its own speech. But thesame, in the word of an American case, "would create anunacceptable risk of the suppression of ideas. "11

In Ashcroft v. American Civil Liberties Union, 542 U.S. 656,660 (2004 ), the American Supreme Court said:Content-based prohibitions, enforced by severecriminal penalties, have the constant potential to be arepressive force in the lives and thoughts of a free people.

To guard against that threat the Constitution demandsthat content-based restrictions on speech be presumedinvalid, R. A. V. v. St. Paul, 505 U. S. 377, 382 (1992),and that the Government bear the burden of showing theirconstitutionality, United States v. Playboy EntertainmentGroup, Inc., 529 U. S. 803, 817 (2000). This is true evenwhen Congress twice has attempted to find aconstitutional means to restrict, and punish, the speech inquestion.The assailed being in the nature of a content-based restrictionand not merely a content-neutral regulation, it is subject to the mostexacting scrutiny. As the Court explained in Chavez v. Gonzales,supra.:[A] governmental action that restricts freedom of speechor of the press based on content is given the strictestscrutiny in light of its inherent and invasive impact. Onlywhen the challenged act has overcome the clear andpresent danger rule will it pass constitutional muster,with the government having the burden of overcoming thepresumed unconstitutionality. Unless the government canoverthrow this presumption, the content-based restraintwill be struck down.

With respect to content-based restrictions, thegovernment must also show the type of harm the speechsought to be restrained would bring about-especially thegravity and the imminence of the threatened harm-9 Osmena v. Commission on Elections, 288 SCRA 447, 478 (1998).1Chavez v. Gonzales, 545 SCRA 441, 517 (2008); Boldfacing in theoriginal.11 Members of City Council of Los Angeles v. Taxpayers for Vincent, 466U. S. 789, 797 (1 984).

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otherwise the prior restraint will be invalid. Prior restrainton speech based on its content cannot be justified byhypothetical fears, "but only by showing a substantive andimminent evil that has taken the life of a reality already onground." As formulated, "the question in every case iswhether the words used are used in such circumstancesand are of such a nature as to create a clear and presentdanger that they will bring about the substantive evils thatCongress has a right to prevent. It is a question ofproximity and degree."

The regulation which restricts the speech contentmust also serve an important or substantial governmentinterest, which is unrelated to the suppression of freeexpression. Also, the incidental restriction on speechmust be no greater than what is essential to thefurtherance of that interest. A restriction that is so broadthat it encompasses more than what is required to satisfythe governmental interest will be invalidated. Theregulation, therefore, must be reasonable and narrowlydrawn to fit the regulatory purpose, with the leastrestrictive means undertaken.Thus, when the prior restraint partakes of acontentneutral regulation, it is subjected to an

intermediate review. A content-based regulation,however, bears a heavy presumption of invalidity and ismeasured against the clear and present danger rule.The latter will pass constitutional muster only if justified bya compelling reason, and the restrictions imposed areneither overbroad nor vague. 12As to be shown shortly, the assailed provision is overly broadand is likewise vague- it cannot pass constitutional muster.

cSECTION 23(A)(1) OF THE RH LAW

VIOLATES THE OVERBREADTH PRINCIPLE

It could be readily seen that the law, in trying. to implement andenforce its policy relative to population control, penalizes what itconsiders to be incorrect information regarding reproductive health.But as shown above and as discussed in the different petitions filedso far, there is really no unanimity as to what may constitute safe orbeneficial as against dangerous or hazardous means or devices and

12 545 SCRA, at 494-496; Boldfacing in the original.

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substances when it comes to birth control. Thus, there is a greatpossibility that anyone not toeing the line as advocated by thegovernment could be subjected to the penal provisions of the law.The law, accordingly, tries to do something in a manner that is overlybroad threatening within its scope other constitutionally protectedareas like freedom of expression, not to speak of the chilling effect ithas on a very fundamental right to decide based on one's own idea ofa family and procreation.

A statute is considered void for overbreadth when "itoffends the constitutional principle that a governmentalpurpose to control or prevent activities constitutionallysubject to state regulations may not be achieved bymeans which sweep unnecessarily broadly and therebyinvade the area of protected freedoms." (Zwickler v.Keota, 19 L ed 2d 444 [1967]). 13Likewise, it has also been held that "[a] clear and preciseenactment may nevertheless be 'overbroad' if, in its reach, it prohibitsconstitutionally protected conduct. "14The U.S. Supreme Court has succinctly put the overbreadthdoctrine in this manner:

The Government may not suppress lawful speechas the means to suppress unlawful speech. Protectedspeech does not become unprotected merely because itresembles the latter. The Constitution requires thereverse. "[T]he possible harm to society in permittingsome unprotected speech to go unpunished isoutweighed by the possibility that protected speech ofothers may be muted .... Broadrick v. Oklahoma, 413U. S., at 612. The overbreadth doctrine prohibits theGovernment from banning unprotected speech if asubstantial amount of protected speech is prohibited orchilled in the process.

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It has been explained that "[t]he doctrine is predicated on thesensitive nature of protected expression: 'persons whose expressionis constitutionally protected may well refrain from exercising theirrights for fear of criminal sanctions by. a statute susceptible ofapplication to protected expression.' Village of Schaumburg v.Citizens for a Better Environment, 444 U.S. 620, 634 (1980); Goodingv. Wilson, supra, at 521."16 In Southern Hemisphere Engagement

13 8/o Umpar Adiong v. Commission on Elections, 207 SCRA 712, 719-720 (1992).14 Grayned v. City of Rockford, 408 U.S. 104,114 (1972).15 Ashcroft v. Free Speech Coalition, 535 U.S. 234, 255 (2002).16 New York v. Ferber, 458 U.S. 747, 768-769 (1982).


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Network, Inc. v. Anti-Terrorism Council, 632 SCRA 146 (2010), citingAmerican jurisprudence, stated that "[a]ttacks on overly broadstatutes are justified by the 'transcendent value to all society ofconstitutionally protected expression. "' 17When the government infringes and invades the sacredprecincts of one's home and bedroom, then that raises graveconstitutional issues. While petitioner is willing to concede that thegovernment may regulate certain aspects of social living, the samecould not extend to the hallowed grounds of the home in the absenceof a compelling reason, something not present here.In any event, an overly broad statute could produce a chillingeffect which would have adverse consequences for the body politic.

DSECTION 23(A)(1) IS VOID FOR BEING VAGUE

There is another fatal constitutional flaw in the assailedprovision of the law. It is vague to the point of being void. "The voidfor-vagueness doctrine holds that a law is facially invalid if men ofcommon intelligence must necessarily guess at its meaning and differas to its application."

18Further elucidating on the doctrine, the Courtin Southern Hemisphere Engagement Network, Inc. v. Anti-TerrorismCouncil, supra., explained thus:

A statute or act suffers from the defect ofvagueness when it lacks comprehensible standards thatmen of common intelligence must necessarily guess at itsmeaning and differ as to its application. It is repugnant tothe Constitution in two respects: (1) it violates dueprocess for failure to accord persons, especially theparties targeted by it, fair notice of the conduct to avoid;and (2) it leaves law enforcers unbridled discretion incarrying out its provisions and becomes an arbitraryflexing of the Government muscle. 19Section 23(a)(1) of the RH Law is one such provision whichcould be assailed for being vague and void. To reiterate, the provisionprohibits and penalizes knowing withholding of information orrestricting the dissemination thereof, and/or intentionally provide17 Southern Hemisphere Engagement Network, Inc. v. Anti-Terrorism

Council, 632 SCRA 146, 188-189 (2010), citing Gooding v. Wilson, 405 U.S. 518,31 L. Ed 2d 408 (1972).18 Romualdez v. Commission on Elections, 553 SCRA 370, 418 (2008),citing David v. Macapagai-Arroyo, 489 SCRA 160, 239 (2006).19 At 185.


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"incorrect information regarding programs and services onreproductive health including the right to informed choice and accessto a full range of legal, medically-safe, non-abortifacient and effectivefamily planning methods."The word "incorrect" is fraught with a lot of dangerousramifications. As already adverted to above, the matter of determiningwhat is "correct" or otherwise when it comes to the different means bywhich birth control could be implemented is something that is notreadily capable of definitive determination. For now, it might be this orthat drug or device that is considered "correct" in so far as thegovernment is concerned. What happens if someone disagrees andsuggests otherwise and thereafter proceeds to advise the personsseeking his counsel? Does he get to be prosecuted for violating Sec.23(a)(1 )? The list of questions could be expanded to include othersituations but that example would already sufficiently illustrate thedanger of what is considered a constitutionally vague provision thatmerits being stricken out outright.And, with such a penal provision, speech could as well besilenced into submission. Those who may have well-grounded doubtsabout the validity of government claims relative to contraceptives mayjust choose to shut their mouths for fear of prosecution or otherinconvenience. "Fear of guessing wrong must inevitably cause selfcensorship, and thus create the danger that the legitimate utterance

will be deterred."20 But when such happens, the very purpose forwhich the freedom to speak is guaranteed would be undermined,ultimately resulting in greater loss for society than the momentarycompelled conformity.

ESECTION 23(A)(1) OF THE RH LAW IS VIOLATIVE

OF THE DUE PROCESS CLAUSE

The void-for-vagueness and overbreadth doctrines are dictatesof the Due Process Clause as that constitutional guaranty is aprotection against arbitrary and unreasonable laws or governmentacts, or regulations which could only succeed in ensnaring thecitizens in traps which were not clearly marked.In any case, petitioner-in-intervention finds relevance in whatthe Court said in Chavez v. Gonzales, supra., regarding unwarranted

restrictions placed on the freedom of expression brought about byoverly strict application of laws:20 Rosenbloom v. Metromedia, Inc., 403 US 29, 50 (1971 ).

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We rule that not every violation of a law willjustify straitjacketing the exercise of freedom ofspeech and of the press. Our laws are of differentkinds and doubtless, some of them provide norms ofconduct which even if violated have only an adverseeffect on a person's private comfort but does notendanger national security. There are laws of greatsignificance but their violation, by itself and withoutmore, cannot support suppression of free speech andfree press. In fine, violation of law is just a factor, avital one to be sure, which should be weighed inadjudging whether to restrain freedom of speech and ofthe press. The totality of the injurious effects of theviolation to private and public interest must be calibratedin light of the preferred status accorded . by theConstitution and by related international covenantsprotecting freedom of speech and of the press. In callingfor a careful and calibrated measurement of thecircumference of all these factors to determinecompliance with the clear and present danger test, theCourt should not be misinterpreted as devaluingviolations of law. By all means, violations of law shouldbe vigorously prosecuted by the State for they breed theirown evil consequence. But to repeat, the need toprevent their violation cannot per se trump theexercise of free speech and free press, a preferredright whose breach can lead to greater evils. For thisfailure of the respondents alone to offer proof to satisfythe clear and present danger test, the Court has no optionbut to uphold the exercise of free speech and freepress. 21

FINAL WORDThe long and short of the debate about so-called responsibleparenthood and the means and method to achieve it is this - THEGOVERNMENT DOES NOT HAVE ALL THE ANSWERS and somust not impose the threat of punishment for those who entertainother or contrary ideas, labelling them as "incorrect" or the like.Governments and authorities through history have been provenwrong now and then. Therefore, government must allow for the freeplay of competing ideas in the marketplace as a better guaranty ofarriving at the truth, or better alternatives instead of simply imposingits own predetermined concepts.21 At109.


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PRAYER

WHEREFORE, premises considered, petitioner-in-intervention,prays that:1. Section 23(a)(1) of the "The Responsible Parenthood andReproductive Health Act of 2012" (R.A. No. 10354) be declaredunconstitutional on account of vagueness as well as for overbreadth;

2. Other provisions of the law as assailed in G.R. No.204934 (Alliance for the Family Foundation Philippines, Inc.) besimilarly declared unconstitutional.

Other relief as are just and equitable are likewise prayed for.City of Manila, 29 January 2013.

AMSON S. ALCANTARASuite 1402 14th FloorManila Astral TowerTaft Ave. cor. P. Faura St.Ermita, ManilaIBP 884007/1-13-2012/AbraPTR 0371175/1-13-2012/Mia.Roll No. 12841MCLE Exemtion No. 111-001807/10-6-10Tel. Nos.: 5216984/4980382I.

HON. FLORENCIO 8. ABAD 1 0 670.Secretary, Department of Budget and . PMalacaiiang Palace, City of ManilaHON. ENRIQUE T. ONASecretary, Department of HealthSan Lazaro Compound, City of Manila


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HON. ARMIN A. LUISTROSecretary, Department of EducationDepEd Complex, Meralco Avenue, Pas

HON. FRANCIS H. JARDELEZASolicitor General139 Amorsolo StreetLegaspi Village, Makati City

EXPLANATI.

Pursuant to Section 11 of Rule 1be informed that the filing and service . P ~ ~ t m a s t e /TellerWill be made through registered mailon aCC0Un1. OT tne Le i l l fJUI a1yunavailability of messengerial personnel to effect personal service.

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VERIFICATION AND CERTIFICATION

I, Samson Alcantara, of legal age, Filipino, and with officeaddress at Suite 1402, 141h Floor Manila Astral Tower Taft Ave1 corner P. Faura St., Ermita, Manila, after having been duly sworn toin accordance with law, hereby depose and say, that:

(1) I am the petitioner-in-intervention in the case entitled "SJSPresident Samson S. Alcantara v. Executive Secretary} et a/. 1 J1to be filed before the Supreme Court of the Philippines.

(2) I have caused the preparation of the foregoing Petition inIntervention. I have read and understood the same and theallegations therein are true and correct, of my personalknowledge and/or based on authentic records.

(3) I have not commenced any other action involving the sameissues before this Honorable Court, or any division thereof, orany other lower court, tribunal or agency.

(4) If I should thereafter learn that a similar action or proceedinghas been filed or is pending before the Supreme Court, theCourt of Appeals or different divisions thereof, or any othertribunal or agency, I undertake to promptly inform the Court ofsuch fact within five (5) days therefrom.

IN WITNESS WHEREOF, I have hereunto set my hand ~ ~ J 3 0 1 aQw ofJanuary, 2013 in \1Af


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I ,_ FEB 0 1 201l.Subscribed and sworn to before me this _ day of January,

2013, \ ~ R K t j i J r . ~ m r , affiant exhibiting to me his competentevidence o i niY as follows:Name Proof of Identity Date/Place Issued1.Samson S. Alcantara

and that he is the same person who personally signed before me theforegoing "Verification and Certification" and acknowledged that heexecuted the same.

D o c . N o . ~ ~ ;Page No. ;Book No. ;Series of 2013.f t.p '.r'1:' .").[i)J(f. ;-,If). !ll - l1854

If'' ., . , - L l f t . [ I ~ I I E MEMBERF: ' ,, ''c -


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REPUBLIC OF THE PHILIPPINES)City of Makati ) S.S.

AFFIDAVIT OF SERVICE AND FILING

I, LAURENCE A. CANCERAN, of legal age, Filipino, with postal address at, Suite 1402 141h Floor Manila AstralTower Taft Ave. cor. P. Faura St. Ermita, Manila, after having been sworn to in accordance with law, do hereby deposeand state that:Today, I have served and filed copies of the following pleading,

PETITION IN INTERVENTIONSJS PRESIDENT SAMSON S. ALCANTARA,Petitioner-in-Intervention,

-versus-HON. PAQUITO N. OCHOA, JR.,

Executive Secretary;HON. FLORENCIO B. ABAD, Secretary, Department ofBudget and Management;HoN. ENRIQUE T. ONA, Secretary, Department of Health;HON. ARMIN A. LUISTRO, Secretary, Department ofEducation; andHON. MANUEL A. ROXAS II, Secretary, Department ofInterior and Local Government,Respondents.

G.R.No.- - - -- -

Pursuant to sections 7 and 13 as well as Section 3 and 12 of the Rules of Court, respectively, by registered mail to:

HON. PAQUITO N. OCHOA, JR.Executive SecretaryOffice of the President of the PhilippinesMalacafiang Palace, City of Manila

HaN. FLORENCIO B. ABADSecretary, Department of Budget and ManagementMalacafiang Palace, City of Manila

HON. ENRIQUE T. ONASecretary, Department of HealthSan Lazaro Compound, City of ManilaHaN. ARMIN A. LUISTROSecretary, Department of EducationDepEd Complex, Meralco Avenue, Pasig CityHON. MANUEL A. ROXAS IISecretary, Department of Interior and Local GovernmentEDSA cor. Mapagmahal St., Diliman, Quezon CityHaN. FRANCIS H. JARDELEZASolicitor General139 Amorsolo Street

R.R. NO. /P &R.R. NO. ! I J ~R.R. NO. /D6JIR.R. NO. /!JG t'Z-R.R. NO. / 0 6 l ~R.R. NO.

Legaspi Village, Makati CityBy depositing a copy in the Post Office ~ M , , in a sealed envelope, plainly addressed to theparty or his/her attorney at his/her office addresd postage fully prepaid, as evidenced by the Registry Receipts heretoattached indicated opposite their names, with instruction to the postmaster to return the mail to the sender after ten (10)days if not received.IN WITNESS WHEREOF, I hereunto affix my signature this 1st day of Februa 3, the City of Makati.

CE A. CANCERANAffiantSUBSCRIBED AND SWORN TO before r r fEBs tQaJoZOJary 2013, affiant exhibiting to me his SocialSecurity System ID 33-1008964-0

D o c . N o . ~Page No. R. BATALLA

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rh law petition 204934b

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