REPUBLIC OF THE PHILIPPINES

FIRST JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 3
BAGUIO CITY
LEOMARIE F. HIRANG, GIANCARLO
FEDERICO T. TABANGIN, RUFINO
VELASCO, ABRILLIUS RAFFY C.
LAGUESMA, PHILIP REY B. AMELING
Plaintiffs,

Civil Case No. ________

For:

-versusCITY BUILDINGS AND ARCHITECTURE OFFICE

(BAGUIO CITY), DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES (BAGUIO CITY), CITY
ENVIRONMENT AND PARKS MANAGEMENT OFFICE
(BAGUIO CITY), RESIDENTS WITHIN CAMP 8
WATERSHED, BAGUIO CITY
Defendants.
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COMPLAINT
COMES NOW, the plaintiffs through the undersigned counsel and unto this Honorable
Court most respectfully avers:
1. That the plaintiffs, Leomarie F. Hirang, Giancarlo Federico T. Tabangin, Rufino Velasco,
Abrillius Raffy C. Laguesma, Philip Rey B. Ameling, are of legal age, Filipino citizens
with residence at Baguio City;
2. That the defendant, City Buildings And Architecture Office of Baguio City, is tasked of
issuing building permits in the City;
3. That defendant, Department Of Environment And Natural Resources of Baguio City, is
the primary implementing agency in the enforcement of environmental laws;
4. That defendant, City Environment And Parks Management Office Baguio City, is a local
office within the City of Baguio created to oversee the environment and parks to maintain
and protect it;
5. That private defendants, residents Within Camp 8 Watershed, Baguio City, constructed
buildings and farmed within the Camp 8 watershed;
6. By virtue of Proclamation 107, series of 1936, President Manuel L. Quezon proclaimed
portions of Camp 8 for water reserve purposes;
7. The defendants, Department of Environment and Natural Resources (Baguio City), City
Environment And Parks Management Office Baguio City, failed to perform their

functions to safeguard and protect the Camp 8 Watershed, Baguio City by allowing
construction of a building within the water reserve;
8. That defendant, City Buildings And Architecture Office of Baguio City, overstepped its
authority when it issued or did not regulate the construction of a building within the
Camp 8 Watershed, a natural resource of the State;
9. That there are illegal settlers residing within Camp 8 Watershed when it is specifically
prohibited by the Baguio Water District.
10. That a farm is being cultivated within Camp 8 Watershed;
11. That other acts such as dumping of garbage and other debris, tree-cutting, gardening,
quarrying, pasturing, treasure hunting, wildlife hunting, and forest production harvesting
are prohibited to be performed within the water reserve;
12. That the Camp 8 Watershed is withdrawn from sale and settlement and remains to be part
of the public domain.
WHEREFORE, premises considered, it is most respectfully prayed unto this Honorable
Court that, after hearing, judgment be rendered ordering the defendant:
1. Department of Environment and Natural Resources and City Environment And Parks
Management Office Baguio City to immediately order the illegal settlers within the water
reserve to leave the area and insure the water quality within the watershed is maintained
and protected from further sale or settlement;
2. City Buildings And Architecture Office of Baguio City to immediately or as soon as
practicable to demolish any structures within the water reserve;

VERIFICATION/CERTIFICATION OF FORUM SHOPPING

Republic of the Philippines )
City of Manila
) S.S.

1.
2.
3.
4.

5.

WE, Leomarie F. Hirang, Giancarlo Federico T. Tabangin, Rufino Velasco, Abrillius Raffy C.
Laguesma, Philip Rey B. Ameling, of legal age, Filipino citizens, single and resident of Baguio City,
after having been duly sworn to in accordance with law do hereby depose and say:
That we are the plaintiff in the above-entitled case;
That we have caused the preparation of the foregoing complaint and have read the
allegations contained therein;
The allegations in the said complaint are true and correct of our own knowledge and
authentic records;
We hereby certify that we have not commenced any other action or proceeding involving the
same issues in any court, tribunal or quasi-judicial agency and, to the best of our knowledge, no
such other action or claim is pending therein;
That if we should learn thereafter that a similar action or proceeding has been filed or is
pending, we hereby undertake to report that fact within five (5) days therefrom to the court or agency
where the original pleading and sworn certification contemplated herein have been filed;

6.

We executed this verification/certification to attest to the truth of the foregoing facts and to
comply with the provisions of Adm. Circular No. 04-94 of the Honorable Supreme Court.
IN WITNESS WHEREOF, I have hereunto affixed my signature this 17 of November 2014, in
the City of Baguio
Leomarie F. Hirang
Giancarlo Federico T. Tabangin
Rufino Velasco
Abrillius Raffy C. Laguesma
Philip Rey B. Ameling

SUBSCRIBED AND SWORN to before me this 17th day of November 2014, in the City of Baguio,
affiant exhibiting to me his Drivers License No. 12345 issued by the Land Transportation Office on
April 8, 2014 at the City of Baguio.

ATTY. Juanito De Los Santos

Notary Public
My Commission Expires Dec. 31, 2015
Roll of Attorney No. 34567
IBP No. 12345/2-5-12/Manila
PTR No. 87654/12-22-11/Manila