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Petition To Revisit Denial of AIPO Renewal PDF
Petition To Revisit Denial of AIPO Renewal PDF
04 March 2019
Page 1 of 35
04 March 2019
“Petitioner Sevilla” was the Founding Vice Chairman of the Board of Trustees of
“PhilRES” upon its accreditation as the “AIPO” for the real estate service – the
heretofore Accredited and Integrated Professional Organization (hereinafter
referred to as “AIPO”) for the real estate service under the supervision of the
Professional Regulatory Board of Real Estate Service (hereinafter referred to as
“PRBRES”), a regulatory board of the Professional Regulation Commission
(hereinafter referred to as “PRC”).
“Petitioner Sevilla” was also the Founding Incorporator and Founding President of
“PhilRES” Premiere and First Local Chapter - the “PhilRES” Quezon City Chapter,
Inc.
1. On October 21, 2011 pursuant to the provisions of “PRC” Res. 2004-178 the
“PRC” approved “PhilRES” petition to be the Accredited and Integrated
Professional Organization (“AIPO”) for the real estate service thru the issuance of
“PRC” Resolution No. 019 Series of 2011” (Please see Annex “B” to “B-7) which was
published in the November 14, 2011 issue of the Official Gazette.
Local Government Assessors’ Organizations who possess PRC real estate Appraisers
Licenses into “PhilRES”.
Presently, “PhilRES” boasts of more than fifty (50) local chapters whose members
include many regular members of these various Local Government Assessors’
Organizations who possess PRC Real Estate Appraisers Licenses and with a general
membership base of more than twelve thousand (12,000) bona fide members.
2. Upon the accreditation of an (“AIPO”) for the real estate service pursuant to
the provisions of Par. 2, Sec. 34, Art IV RA 9646 and pursuant to the provisions of
Par. 2, Sec. 34, Rule IV “PRBRES” Res. No. 2 Series of 2010 (Implementing Rules
and Regulations of R.A. 9646) which are exactly and similarly worded, to wit:
“A real estate service practitioner duly registered with the Board shall
automatically become a member of the accredited and integrated
professional organization of real estate service practitioners, and
shall receive the benefits and privileges appurtenant thereto;”,
ALL real estate service practitioners including the Members of the “PRBRES” are
required to apply and become members of “PhilRES” the “AIPO” for the real estate
service in order for these real estate service practitioners to practice the profession
legally.
Similar to the law profession where all lawyers must voluntarily apply be a member
of the Integrated Bar of the Philippines (“IBP”) to practice the profession of law in
the Philippines, Real Estate Service Practitioners e.g. (1) real estate brokers; (2) real
estate appraisers; real estate brokers; and (4) real estate salespersons are required
to voluntarily apply and become members of “PhilRES” the “AIPO” for the real
estate service in order for these real estate service practitioners to practice the real
estate service profession legally.
Except for Hon. “PRBRES” Member Bansan Choa, none of the other members of
the “PRBRES” namely:
complied with this provision of the law and and volunatarily applied for regular
membership with “PhilRES” and therefore were practicing their profession and
serving as Members of the “PRBRES” in violation of law. (Emphasis supplied)
4. On January 16, 2016, or 436 days from the date of submission of the
“PhilRES” “Petition for Renewal’ of its “AIPO” status in timely compliance of
RULE3 of the provisions of “PRC” Res2004-178 - the “PRC” and “PRBRES” illegally,
capriciously, unconstitutionally, without due process and hearing and without any
legal basis of law approved, adopted, and signed “PRBRES” Resolution No. 05
Series of 2016” (Please see Annexes “C” to “C-2”) and MERELY DENIED “PhilRES”’
petition for renewal of its accreditation as AIPO on the following grounds, to wit:
“PRBRES” RESOLUTION NO. 5 SERIES OF 2016 VIOLATES RULE3 and RULE4 “PRC”
RESOLUTION NO. 2004-178.
....
More specifically, PRC Commissioner Arch. Yolanda David Reyes has been
entertaining the Philippine Federation of Real Estate Service Professional Inc.
(PFRESPI) whose total general membership comprise less than twenty percent
(20%) of the total general membership of “PhilRES”. Moreover, PFRESPI does not
command the support of the various Local Government Assessors’ Organizations,
more specifically the (1) Philippine Association of Local Treasurers & Assessors, Inc.
(PHALTR.A.); (2) the Philippine Association of Municipal Assessors, Inc. (PAMAS);
(3) the Philippine Association of Assessing Officers, Inc. (PAAO); and, the Institute of
Public Sector Appraisers of the Philippines, Inc. (IPSAP) as best demonstrated by the
Sec. 3 (i) Rule 1 “PRBRES” Res. No. 2 Series of 2010 (Implementing Rules and
Regulations of R.A. 9646) defines “Interim AIPO” to wit:
Despite knowledge of the provisions law and of the Implementing Rules and
Regulations of R.A. 9646 “PRC” Commissioner Arch. Yolanda David Reyes is
conducting these meetings with other real estate service organizations and in
particular with the Philippine Federation of Real Estate Service Professional Inc.
(PFRESPI) with the end in view of creating a new organization that shall be
accredited as an “Interim AIPO” or a “new AIPO” and therefore in willful violation
of law.
“PhilRES” has already been previously accredited as the “AIPO”. Activities and
meetings being conducted by PRC Commissioner Arch. Yolanda David Reyes
leading to the Appointment and Naming of a new “Interim AIPO” violates this
provision of Sec. 3 (i) Rule 1 “PRBRES” Res. No. 2 Series of 2010 (Implementing
Rules and Regulations of R.A. 9646).
“PRC” actions for the purpose of forming a “new AIPO” is also violative of “PhilRES”
and its general collective membership’s legal and Constitutional Rights as a
juridical person pursuant to the provisions of Section 1, Article III 1987 Philippine
Constitution, to wit:
While the general rule is that an unconstitutional law or resolution is void and
produces no rights, imposes no duties and affords no protection and therefore has
no legal effect, the same should be questioned and its legality challenged.
Being null and void ab inition its promulgation or adoption must be reversed,
rescinded and voided. Actions to render such unconstitutional law or resolutions
cannot prescribe and can be questioned and its legality challenged anytime.
The pre-incorporation acts and corporate acts of “PhilRES” were greatly influenced
and coordinated with the tacit and implied consent by “PhilRES” from directives
and suggestions emanating from both “PRBRES” and “PRC” as borne out by
communications emanating from both “PRBRES” and “PRC” (Please see Annexes “E” to
“E11”).
While “PhilRES” is admittedly a creation by both “PRBRES” and “PRC” upon the
approval of its Articles of Incorporation and By Laws by the Securities and Exchange
Commission “PhilRES” has acquired its own distinct and separate personality - a
juridical personality with Inherent Constitutional Rights guaranteed by the
Constitution of the Republic of the Philippines.
Upon the accreditation and grant of “AIPO” status thru the issuance of “PRC”
Resolution No. 019 Series of 2011” by “PRBRES” and “PRC” on October 21, 2011
pursuant to the provisions of “PRC” Res. 2004-178 “PhilRES” and its general
collective membership has acquired the equivalent of “property and privilege” not
readily and easily granted and bestowed to many.
“PhilRES” general membership comprise and greatly outnumber more than all the
combined memberships of the other real estate service organizations and
associations combined.
“PRC” cannot legally supplant and replace “PhilRES” as the “AIPO” for the real
estate service on the basis of the illegal and unconstitutional resolution (“PRBRES”
Resolution No. 05 Series of 2016”) passed by the “PRBRES” and subsequently
approved by the “PRC”.
Moreover, “PRC” cannot legally supplant and replace “PhilRES” as the “AIPO” for
the real estate service with a new replacement AIPO organization like the
Philippine Federation of Real Estate Service Professional Inc. (PFRESPI) whose
total general membership comprise less than twenty percent (20%) of the total
general membership of “PhilRES” and who does not command the support of the
various Local Government Assessors’ Organizations, more specifically the (1)
Philippine Association of Local Treasurers & Assessors, Inc. (PHALTR.A.); (2) the
Philippine Association of Municipal Assessors, Inc. (PAMAS); (3) the Philippine
Association of Assessing Officers, Inc. (PAAO); and, the Institute of Public Sector
Appraisers of the Philippines, Inc. (IPSAP) as best demonstrated by the very low
number of licensed real estate government appraiser/assessors in their general
membership base.
It is therefore very curious and very suspect as to why despite PRC Commissioner
Arch. Yolanda David Reyes’ knowledge of the (1) great disparity in the general
membership base; (2) total number of local chapters created by “PhilRES” ; and,
the (3) provisions of law in as far as the rights of “PhilRES” and its general
membership are - PRC Commissioner Arch. Yolanda David Reyes has been
entertaining the Philippine Federation of Real Estate Service Professional Inc.
(PFRESPI) whose (a) total membership base; (b) total number of local chapters
created; and, (c) whose total number of government appraiser/assessor
membership base greatly pales in comparison with “PhilRES”.
It is simply a naked and brazen attempt to supplant the rights of the few over the
rights of the many which is undemocratic to say the least.
While inarguably, there are flaws in “PhilRES” Articles of Incorporation and New By
Laws for there is no perfect Articles of Incorporation and By Laws that exists –
there exists NO legal proceedings nor judicial body that determined the infirmity or
illegality of any of the provisions of “PhilRES” Articles of Incorporation and New By
Laws that would justify, compel or necessitate “PhilRES” to amend any provisions
of its Articles of Incorporation and New By Laws or that would justify the DENIAL
of its petition to renew its “AIPO” status for the real estate service.
Any effort or attempt to amend any provisions of its Articles of Incorporation and
New By Laws must be the result of formal and legal proceedings.
Whatever and if any flaws exist within its New By Laws, “PhilRES” and its general
collective membership which comprises a majority of the total number of “PRC”
licensed real estate service practitioners should be given all the opportunity to
“cure and correct” these flaws, if any.
“Mere Denial” without due process and hearing as required by provisions of (1)
“PRC” Res2004-178; is unjust, illegal, immoral an unconstitutional. “PRBRES” and
“PRC” cannot simply throw away its “love child” and replace it with a new one
because it (the “love child”) did not turn out to be as they had planned it to be.
More so when the “love child” represents a major percentage of the total number
of “PRC” licensed real estate service practitioners. The issuance of “PRBRES”
Resolution No. 05 Series of 2016” greatly affects a large majority of the total
number of “PRC” licensed real estate service practitioners who compose the
general collective membership of “PhilRES”.
PRAYER/PETITION
In view of all the foregoing, as a Member, Incorporator and Founding Vice
Chairman of the Philippine Institute of Real Estate Service Practitioners
(“PhilRES”) Incorporated and therefore a “Legal-Party-In-Interest” in this Petition,
“Petitioner Sevilla” has shown and demonstrated that “PhilRES” has dutifully
complied with and conformed with the provisions of “Rule3 “PRC” Res. 2004-178”
and that since its Certificate of Accreditation as the AIPO for the Real Estate Service
has never been cancelled or revoked after due notice and hearing.
“Petitioner Sevilla” respectfully prays that His Excellency Rodrigo Roa Duterte
Grant this Petition for Motion For Consideration To Order the “PRBRES” and the
“PRC” to Revisit “PRBRES” Resolution No. 5 Series of 2016 and investigate the
allegations and complaints stated herein this Petition for violation of, to wit:
“Petitioner Sevilla” respectfully prays that His Excellency Rodrigo Roa Duterte
when evidence/s merit to Order that “PRBRES” Resolution No. 05 Series of 2016”
be withdrawn, cancelled and be declared Unconstitutional, Illegal, Null and Void
and “PhilRES” be issued its renewal certification as the “AIPO for the Real Estate
Service”.
Lastly, “Petitioner Sevilla” petitions His Excellency Rodrigo Roa Duterte to order
the “PRC” and the “PRBRES” to reinstate the AIPO status of “PhilRES” due to
violation by the “PRC” and the “PRBRES” of the constitutional rights of “PhilRES”
to due process.
In support of this Petition, “Petitioner Sevilla” has attached hereto an (1) Executive
Brief, History, Background, Synopsis of Events with Annexes.
“Petitioner Sevilla” trusts that His Excellency Rodrigo Roa Duterte shall see the
legal, moral and justness of this Petition and favorably grant the prayers requested
for herein. Thank you.
Respectfully Submitted,
#4 A. De Legaspi St., Bgy. Milagrosa, Proj. 4, Quezon City Metro Manila 1109
Email: ricosevilla@yahoo.com
Tel. Nos: 09062989305 09198090236
Copy Furnished:
Hon. Atty. Teofilo S. Pilando, Jr.
Chairman
Professional Regulation Commission (“PRC”)
EXECUTIVE BRIEF
1. On April 28, 2010 the “PRBRES” invited more than twenty-five (25) Securities
and Exchange Commission registered national real estate service associations and
national real estate service organizations which comprise more than seventy-five
percent (75%) of the formally organized stakeholders in the Philippine Real Estate
Industry to the “APO Organization Meeting” at the Ballroom 1 (GF) of the Hyatt
Hotel & Casino, 1588 Pedro Gil St. cor. M. H. Del Pilar St., Malate, Manila.
4. On July 15, 2011 after a further series of meetings with the “PhilRES” official
National Directorate representatives including the undersigned “Petitioner Sevilla”
and “PRBRES” members and/or its representatives for the purpose of introducing
and amending “PhilRES”’ By Laws to tailor suit it to comply with the provisions of
RA8981, RA9646, RA9646 IRR and several “PRC” Resolutions, the “PRBRES” finding
the submitted proposed New By Laws submitted by “PhilRES” acceptable -
officially indorsed “PhilRES” New By Laws” to the “SEC” for its processing and
approval (Please see Annex “G”).
7. On December 7, 2011 “PhilRES” officially became the “AIPO” for the real
estate service, and thereafter to be officially known as “PhilRES”-AIPO”.
9. Thereafter, despite the absence of any legal basis and without due notice
and hearing, several directives were issued by the “PRBRES” and “PRC” ordering
“PhilRES” to postpone “PhilRES”-AIPO”’s 1st Regular National Elections and amend
its By Laws in violation of the Transitory Provisions of its New By Laws (Please see
Annexes “J” to “J-5“).
11. On January 16, 2016, or 436 days from the date of submission of “PhilRES”-
AIPO”’s “Petition for Renewal’ of its “AIPO” status in timely compliance of RULE 3
of the provisions of “PRC” Res2004-178 - the “PRC” and “PRBRES” illegally,
capriciously, unconstitutionally, without due process and hearing and without any
legal basis of law approved, adopted, and signed “PRBRES” Resolution No. 05
Series of 2016” (Please see Annexes “C” to “C-2”) and MERELY DENIED “PhilRES”’
petition for renewal of its accreditation as AIPO on the following grounds, to wit:
12. Even prior to the issuance of “PRBRES” Resolution No. 05 Series of 2016”,
despite the absence of any cancellation or revocation of the accreditation of
“PhilRES” as the “AIPO” for the real estate service and in the absence of any on-
going formal proceedings filed against “PhilRES” and in the absence of any legal
ground or basis, the PRC Commissioner Arch. Yolanda David Reyes has been
conducting a series of meetings up to the present with other real estate service
organizations with the end in view of creating a new organization that shall be
accredited as an “Interim AIPO” or a “new AIPO” (Please see Annex “D” to “D-2”) to the
damage and injury to the legal rights and constitutional rights of “PhilRES”.
DISCUSSION
Verily, “PhilRES” is a creation of the “PRBRES” and the “PRC”.
The pre-incorporation acts and corporate acts of “PhilRES” were greatly influenced
and coordinated with the tacit and implied consent by “PhilRES” from directives
and suggestions emanating from both “PRBRES” and “PRC” as borne out by
communications emanating from both “PRBRES” and “PRC”.
2. The accredited professional organization no longer served the best interest of the
profession for which it was accredited.
6. The accredited professional organization and/or its chapter organizations has not
submitted audited financial statements thereof.
(Emphasis Supplied)
2. Provisions of both “Rule3 and Rule4, “PRC” Res. 2004-178” provides that “a
certificate of accreditation of an accredited professional organization shall be
cancelled or suspended by the Commission or by the concerned professional
regulatory board upon approval or concurrence by the Commission only after
due hearing”.
(Emphasis Supplied)
3. No hearing was ever conducted by the “PRBRES” and “PRC” as provided for
by “Rule 3 and Rule4, “PRC” Res. 2004-178” and therefore violates the
provisions of said “Rule 3 and Rule4, “PRC” Res. 2004-178” but, more
importantly and more profoundly the constitutional right of “PhilRES” to
due process as provided for in Sec. 1, Art. III 1987 Philippine Constitution.
“PhilRES” was denied of its constitutional right to fully exercise its right to
possess “property” in the form of its accreditation of as the “AIPO for the
real estate service” an accreditation which was illegally taken from
“PhilRES” without due process and therefore denied the constitutional right
to liberty to function and act as the “AIPO for the real estate service”.
There has been no legal process that has determined that any of the
provisions of “PhilRES”-AIPO’s New By Laws violates any provision of
law.
5.2 “b. Breach of its Mandate to Integrate ALL Real Estate Service
Practitioners Into ONE (1) National Organization” (Emphasis
supplied);
5.3 “c. Sanctioning the incorporation and continued existence of four (4)
organizations under its auspices”
(Emphasis supplied);
The “PRBRES” and “PRC” have just very recently approved the
Amended Articles of Incorporation and New By Laws of “PhilRES” as
evidenced by “PRBRES” letter dated July 15, 2011 after a further series
of meetings with the “PhilRES” official National Directorate
representatives and “PRBRES”’ members and/or representatives for
the purpose of amending “PhilRES”’ By Laws to tailor suit it to comply
with the provisions of RA8981, RA9646, RA9646 IRR and several “PRC”
Resolutions, the “PRBRES” finding the submitted proposed New By
Laws submitted by “PhilRES” acceptable to the “PRBRES”, the
“PRBRES” officially indorsed “PhilRES” New By Laws” to the SEC for its
processing and approval and likewise the contents and provisions of
“PRC” Resolution No. 19 Series of 2011” issued on 21 October 2011
when “PRBRES” and “PRC” granted “AIPO” status to “PhilRES”.
More specifically, PRC Commissioner Arch. Yolanda David Reyes has been
entertaining the Philippine Federation of Real Estate Service Professional Inc.
(PFRESPI) whose total general membership comprise less than twenty percent
(20%) of the total general membership of “PhilRES”. Moreover, PFRESPI does not
command the support of the various Local Government Assessors’ Organizations,
more specifically the (1) Philippine Association of Local Treasurers & Assessors, Inc.
(PHALTR.A.); (2) the Philippine Association of Municipal Assessors, Inc. (PAMAS);
(3) the Philippine Association of Assessing Officers, Inc. (PAAO); and, the Institute of
Public Sector Appraisers of the Philippines, Inc. (IPSAP) as best demonstrated by the
very low number of licensed real estate government appraiser/assessors in their
general membership base.
“PhilRES” has already been previously accredited as the “AIPO”. Activities and
meetings being conducted by “PRC” Commissioner Arch. Yolanda David Reyes
leading to the Appointment and Naming of a new “Interim AIPO” violates this
provision of Sec. 3 (i) Rule 1 “PRBRES” Res. No. 2 Series of 2010 (Implementing
Rules and Regulations of R.A. 9646).
“PRC” actions for the purpose of forming a “new AIPO” is also violative of “PhilRES”
and its general collective membership’s Constitutional Rights as a juridical person
pursuant to the provisions of Section 1, Article III 1987 Philippine Constitution.
1. On June 29, 2009 RA 9646 otherwise known as the “Real Estate Service Act
of the Philippines” (hereinafter referred to as “RESA”) was signed into law by
President Gloria Macapagal Arroyo and created “PRBRES” - the 44th
profession and professional regulatory board, under the control and
supervision of the Professional Regulation Commission (hereinafter referred
to as “PRC”).
2. On July 15, 2009 RA 9646 was published in the Philippine Daily Inquirer and
took effect fifteen (15) days following its publication on August 1, 2009.
Except for Mr. Florencio C. Diño, all the other first members of the “PRBRES”
were confirmed to be possessors of at least one (1) valid real estate licenses
On March 26, 2010, the first “PRBRES” was created with the members
thereof being inducted at oath taking ceremonies held at the Professional
Regulation Commission main office.
ALL “PRC” licensed real estate service practitioners (i) real estate brokers;
(ii)real estate appraisers including LGU assessors; and, (iii) real estate
consultants without exception are required to be members of the AIPO to
legally practice their profession.
5. On April 28, 2010 the Professional Regulatory Board on Real Estate Service
(“PRBRES”) invited SEC formally organized stakeholders in the Philippine Real
Estate Industry to the “APO Organization Meeting” with the members of the
“PRBRES” seating en banc to be held on April 28, 2010 at the Ballroom 1
(GF) of the Hyatt Hotel & Casino, 1588 Pedro Gil St. cor. M. H. Del Pilar St.,
Malate, Manila (Please see Annex “K” to “K-2”).
These are composed of the following esteemed and distinguished ladies and
gentlemen of:
5.25 SIRCRO
Arnulfo Canaria
6. On April 30, 2010 “PRBRES” Resolution No. 01” otherwise known as the
“Registration As Real Estate Practitioners Of The First Chairperson and Four
(4) Members Of The Professional Regulatory Board of Real Estate Service
(The Board)” was adopted and approved by the first members of the
“PRBRES” namely Dr. Eduardo Gutierrez-Ong, Bansan C. Choa, Ramon C. F.
Cuervo III, Florencio C. Dino and, Rafael M. Fajardo and conferred and
granted ALL real estate professional licenses for real estate broker, real
estate appraiser and real estate consultant licenses unto themselves –
licenses which not all of them possessed, except for Mr. Rafael M. Fajardo, at
the time of their appointment as Members of the “PRBRES”.
8. On 20 May 2010, “PhilRES” filed for the formal application for recognition
and accreditation by the “PRBRES” as the AIPO for the real estate service
pursuant to the provisions of RA9646 and “PRC” Res. 2004-178 Series of
2004.
10. On June 15, 2011, the “PRBRES” formally communicated to “PhilRES” that
during “PRBRES” 50th Board Meeting held on June 01, 2011, it (the
“PRBRES”) unanimously approved the recognition of “PhilRES” as the
“AIPO” for the real estate service (Please see Annexes “L” to L-2”).
11. On July 15, 2011 after a further series of meetings with the “PhilRES” official
National Directorate representatives and “PRBRES” members and/or
representatives for the purpose of amending “PhilRES”’ By Laws to tailor suit
it to comply with the provisions of RA8981, RA9646, RA9646 IRR and several
“PRC” Resolutions, the “PRBRES” finding the submitted proposed New By
Laws submitted by “PhilRES” acceptable to the “PRBRES”, the “PRBRES”
officially indorsed “PhilRES” New By Laws” to the SEC for its processing and
approval (Please see Annex “G”).
13. On October 21, 2011 the “PRC” approved “PhilRES” petition to be the
“AIPO” for the real estate service thru the issuance of “PRC Resolution No.
019 Series of 2011” (Please see Annex “B” to “B-7”) which was published in the
November 14, 2011 issue of the Official Gazette. The actual publication date
of the Official Gazette was released publicly on November 22, 2011 and
became effective on December 7, 2011.
14. On December 7, 2011 “PhilRES” officially became the “AIPO” for the real
estate service, and thereafter to be officially known as “PhilRES-AIPO”.
Pursuant to the provisions of Par. 2 Sec. 34 Article IV RA9646 ALL real estate
service practitioners without exception (including the members of the
15. On December 14, 2011 the “PRBRES” called for a “Dialogue Regarding AIPO
Matters and Plans and Activities for 2012” at the “PRC” PAPRB Lounge was
attended by Messrs. Dr, Eduardo G. Ong, Bansan C. Choa and Rafael M.
Fajardo of the “PRBRES”, several Members of the Board of Trustees of
“PhilRES-AIPO” and by Dr. Cerila L. Eden of the “PRC” Standards and
Inspection Division.
Exactly seven (7) calendar days after officially becoming the AIPO for real
estate service, the “PRBRES” the verbally demands that “PhilRES-AIPO” not
to implement the Transitory Provisions of Article XXX of “PhilRES” New By
Laws more particularly the formation of local chapters from “PhilRES”
Member Applicants – in effect ordering the “PhilRES” National Directorate to
violate the Transitory Provisions of its New By Laws which the “PRBRES” had
direct participation in its amendment and crafting.
16. On January 6, 2011 exactly thirty-one (31) days since its formal accreditation
as the AIPO for the real estate service, the “PRBRES” formally threatens
“PhilRES” of suspension or dis-accreditation as the AIPO for the real estate
service in the absence of any formal verified complaint filed with the Legal
Division of “PRC” as required by the Rules, if “PhilRES” fails to comply with
its letter demand “not to implement certain provisions of “PhilRES”
Transitory Provisions as provided for in Article XXX thereof” (Please see Annex
“M”).
Thereafter despite the absence of any legal basis and without due notice and
hearing, several directives were issued by the “PRBRES” and “PRC” ordering
“PhilRES” to postpone “PhilRES-AIPO”’s 1st Regular National Elections in
violation of the Transitory Provisions of its New By Laws(Please see Annexes “K”
to “K-5”).
19. On January 16, 2016, or 436 days from the date of submission of “PhilRES-
AIPO”’s “Petition for Renewal’ of its AIPO status in timely compliance of
RULE 3 of the provisions of “PRC” Res2004-178 - the “PRC” and “PRBRES”
illegally, capriciously, unconstitutionally, without due process and hearing
and without any legal basis of law approved, adopted, and signed “PRBRES”
Resolution No. 05 Series of 2016” (Please see Annex “C to “C-2)”) and MERELY
DENIED “PhilRES”’ petition for renewal of its accreditation as AIPO on the
following grounds, to wit:
20. Prior to the issuance of “PRBRES” Resolution No. 05 Series of 2016, despite
the absence of any legal ground or basis, the “PRC” and “PRBRES” have been
conducting a series of meetings with “PhilRES” and other real estate
organizations with the end in view of creating a new organization that shall
be accredited as the “new AIPO” (Please see Annex “D”).
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