REPUBLIC OF THE PHILIPPINES OFFICE OF THE DEPUTY OMBUDSMAN FOR LUZON 3RD FLOOR, OMBUDSMAN BLDG. , AGHAM ROAD, DILIMAN, QUEZON CITY MARCELINO N. RAMOS, Complainant OMB-L-C-10-0020-A -versus- For: Violation of R. A. No 3019 ARNOLD C. MARAMAG, ET. AL. , Respondent/s, x————————————————-x MARCELINO N. RAMOS, Complainant OMB-L-A-10-0030-A -versus- For: Violation of R. A. No 6713 CECILIO JACINTO, Respondent, ————————————————-x JOINT MOTION FOR BILL OF PARTICULARS Respondent/s, unto this Honorable Office most respectfully states: 1. Respondents ARNOLD C. MARAMAG, FERNANDO S. MARAMAG, HERMINIA G. SALVADOR in OMB-L-C-10-0020-A, and CECILIO JACINTO in OMB-L-A-10-0030-A, respectively, received a copy of the Orders issued by this Honorable Office on April 31, 2010, ordering them to submit their respective Counter-affidavits in answer to the attached Affidavit-complaints and supporting documents. 2.
That the respondents have been preparing their respective counter-affidavits, but are having difficulty in squarely answering the charges against them as the affidavit-complaint suffers from insufficient definiteness, which necessities this motion for bill of particulars. 3. That as provided in the affidavit-complaints in both OMB-L-C-10-0020-A and OMB-L-A-10-0030-A, the charge of the complainant is that the respondents committed a violation of Republic Act 3019, a violation of Republic Act 6713 and the crime of Falsification under the Revised Penal Code.
Such complaints are not definite and that the respondents are not being properly informed of the charges against them. 4. That the affidavit-complaint failed to indicate what particular prohibited act under Republic Act 3019 has been violated. In the same vein, the affidavit-complaint does not indicate what particular provision of Republic Act 6713 is violated. Likewise, the respondents do not know what specific act of Falsification under the Revised Penal Code is being charged against them. 5.
That as provided under Rule 12 of the Rules of Court, respondents hereby moves for a Bill of Particulars or for a more definite statement of the charges against them so that they may be able to properly prepare a responsive pleading. WHEREFORE, premises considered, it is respectfully prayed of the Honorable Office to issue an order granting this Motion for a Bill of Particulars for both OMB-L-C-10-0020-A and OMB-L-A-10-0030-A and the complainant to make a Compliance therewith. Other reliefs just and equitable under the premises are likewise prayed for.
Ilagan, Isabela April 6, 2010 CECILIO JACINTO ARNOLD C. MARAMAG Respondent/Movant Respondent/Movant FERNANDO S. MARAMAGHERMINIA G. SALVADOR Respondent/Movant Respondent/Movant THE CLERK OFFICE OF THE DEPUTY OMBUDSMAN FOR LUZON Greetings! Please take notice that the foregoing motion shall be submitted for the kind consideration of the Honorable Office without any further argument thereof. CECILIO JACINTO ARNOLD C. MARAMAG FERNANDO S. MARAMAGHERMINIA G. SALVADOR Copy furnished: MARCELINO N. RAMOS Purok 6, Bliss Village, Ilagan, Isabela.