REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
Makati City
Branch 158

ERIC C. CONSUNJI
Petitioner,

-versus- Civil Case No. 123-45

FOR: Declaration of
KIMMY D. CONSUNJI Nullity with Demand for
Respondent. Support Pendente Lite

X ----------------------------------------- X

PRE-TRIAL BRIEF

Respondent, KIMMY D. CONSUNJI, represented

Republic of the Philippines

NATIONAL POLICE COMMISSION
PHILIPPINE NATIONAL POLICE
SURIGAO DEL NORTE SUR POLICE PROVINCIAL OFFICE
Tandag City

Philippine National Police, Admin Case No. SDSPPO 001-2013

Complainant,

-Versus- FOR: “Simple Neglect of Duty”

PO3 Retzniel C. Galanida,

Respondent.
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POSITION PAPER
for RETNIEL C. GALANIDA

Respondent, through ATTY. HONEY JOY R. MILLANO – CANTA acting as

Counsel hereof, unto the honourable body registers this Position Paper. Copy of the
Order to submit Position Paper within thirty days (30) was received on March 15, 2013,
thus submission of the same today is within the reglementary period, having the 30th day
fall on a Sunday. In support of this Position Paper, respondent hereby states –

On January 10, 2013, Regional Admin Division, PRO 13(CARAGA) issued Special Order
No.001 to PO3 Retzneil C. Galanida which contains his re-assignment to to Adlay Police
Station, Carrascal, Surigao del Sur. Galanida received his order of re-assignment of post
on January 20, 2013 which is Ten (10) days after the date of issue. Galanida boarded a
bus early the following day to report on his new assignment. Unfortunately the road was
not passable. Prompting him to go back to his old post and wait until the road was
declared safe to be travelled. it was on January 30, 2013 that Galanida were able to report
in his new assignment as the road was cleared from the boulders and mud brought by
the typhoon.
PNP filed a complaint against Galanida for the violation of NAPOLCOM MEMORANDUM
Circular 2007-001 otherwise known as “ Uniform Rules of Procedures Before The
Administrative Disciplinary Authorities and the Internal Affairs Service of the Philippine
National Police” particularly Sub-Para v, Para A “Simple Neglect of Duty” of Rule 21
of said Memorandum Circular which reads “ fail to report to a new assignment
within ten (10) days from the order of reassignment without sufficient reason”;