Republic of the Philippines

Department of Justice
National Prosecution Service
Office of the City Prosecutor
Dipolog City

NESTOR B. ILARDE, I.S NO IX-03-INV-15L-03212

Complainant, For Libel and Oral Defamation

-versus-

ELIODORO A. YUSON,
Respondent.

x-----------------------------------------x

MOTION FOR RECONSIDERATION

of the Resolution dated February 2, 2016

COMPLAINANT, through counsel unto this Honorable Office,

most respectfully avers that:

I. TIMELINESS OF THE MOTION

On February 9, 2016, complainant received a copy of the
Resolution dated February 2, 2016 (“Resolution”) signed by the
Honorable Assigned Investigating Prosecutor and approved by the
Honorable City Prosecutor, the dispositive portion of which reads:

“In view of the foregoing, we find no probable cause to

indict herein respondent Eliodoro A. Yuson, Jr. alias “Joy” of the
crime of Libel and respectfully recommend for dismissal of the
above-captioned complaint..’’

II. THE RESOLUTION

A plain reading of the assailed Resolution reveals that the

dismissal was primarily anchored on the proposition that the
complainant was not sufficiently identified in the alleged
defamatory statements made by the respondent citing MRVS
Publications, Inc. et al. vs. Islamic Da’wah Council of the Philippines, Inc.
G.R. No. 135306, January 28, 2003. Thus:

1
 “A perusal of the records show that it is apparent that the
third element is lacking to justify complainant’s filing of the
instant complaint.

xxx.

Moreover, the second afore-quoted remark is so broad and

sweeping that the person allegedly defamed could not be
identifiable.

xxx.

Be that as it may, this group of ministers – whether we

consider the remarks to have been addressed to those ministers
holding higher positions in the INC, such as those senior
ministers holding higher positions in the INC, such as those
senior ministers comprising the Lupon ng Sanggunian, in
particular, or those district ministers administering ecclesiastical
districts of the church, or those ministers employed in the
various offices of the church, in general – is so large and poorly
defined to support a finding that herein complainant was singled
out for personal attack.

To guide us, the case of MVRS Publications, Inc. et al. vs.

Islamic Da’wah Council of the Philippines, Inc. et al., is
instructive. xxx.

Declarations made about a large class of people

cannot be interpreted to advert to an identified or
identifiable individual. Absent circumstances
specifically pointing or alluding to a particular
member of a class, no member of such class has a right
of action without at all impairing the equally
demanding right of free speech and expression, as well
as of the press, under the Bill of Rights. Thus, in
Newsweek, Inc. v. Intermediate Appellate Court, we
dismissed a complaint for libel against Newsweek,
Inc., on the ground that private respondents failed to
state a cause of action since they made no allegation in
the complaint that anything contained in the article
complained of specifically referred to any of them.

Finally, even if all the evidence of the complainant be

taken together, i.e., the interview with Ms. Karen Davila and the
respondent’s letter published in his website

2
 https://joselakas.wordpress.com, the identity of the complainant
still cannot be established,”

With all due respect, the above dismissal is erroneous in view

of the following considerations.

III. ARGUMENTS

In view of the above finding showing presence of the other

elements of libel, the discussion in this motion will be focused on
whether the malicious statement published by respondent
specifically identify or refer to any particular individuals.

The facts that shall be considered are as follows:

1. Complainant as District minister or Tagapangasiwa ng

Distrito belongs to an individual member of a group
((District ministers of the Iglesia Ni Cristo) within a group
(Iglesia Ni Cristo).

2. The respondent did not submit his counter-affidavit.

For the Honorable Investigating Prosecutor to determine if

there exists a well-founded belief that a crime has been committed,
and that the suspect is probably guilty of the same, the elements of
the crime charged should, in all reasonable likelihood, be present.

In Aguilar v. Department of Justice1, the Supreme Court laid

down the general principles for finding probable cause:

“A finding of probable cause needs only to rest on

evidence showing that more likely than not a crime has been
committed by the suspects. It need not be based on clear
and convincing evidence of guilt, not on evidence
establishing guilt beyond reasonable doubt, and
definitely not on evidence establishing absolute
certainty of guilt. In determining probable cause, the
average man weighs facts and circumstances without
resorting to the calibrations of the rules of evidence of
which he has no technical knowledge. He relies on common
sense. What is determined is whether there is sufficient
ground to engender a well-founded belief that a crime has been
committed, and that the accused is probably guilty thereof and
1
GR No. 197522, September 11, 2013

3
 should be held for trial. It does not require an inquiry as to
whether there is sufficient evidence to secure a
conviction.
Apropos thereto, for the public prosecutor to
determine if there exists a well-founded belief that a
crime has been committed, and that the suspect is
probably guilty of the same, the elements of the crime
charged should, in all reasonable likelihood, be present.
This is based on the principle that every crime is defined by
its elements, without which there should be, at the most, no
criminal offense.” (Emphasis supplied)

In the instant case, it is clear that the Honorable Investigating

Prosecutor is asking the Complainant to produce evidence of guilt
with a higher degree of certainty as that required by law.

Contrary to the findings of the Honorable Investigating

Prosecutor, the person defamed is identifiable. In Vasquez v. Court of
Appeals (314 SCRA 460) the Supreme Court held that:

“There is publication if the material is communicated to a

third person. It is not required that the person defamed has
read or heard about the libelous remark. What is material is
that a third person has read or heard the libelous statement,
for a man’s reputation is the estimate in which others hold
him, not the good opinion which he has of himself.

“On the other hand, to satisfy the element of

identifiability, it must be shown that at least a third person
or a stranger was able to identify him as the object of
the defamatory statement.” (Emphasis and underlining
supplied)

The witnesses of the Complainant have personal knowledge

about the Respondent and Complainant, as well as the circumstances
surrounding the utterances, they being INC members themselves.
They are competent to testify as to their judgment and opinion as to
the identity of the person meant and the application and meaning of
the statements.

In Worcester v. Ocampo (22 Phil. 42), the Supreme Court held:

4
 “The rule laid down in 2 Stockey on Slander (p. 51) is that
the application of the slanderous words to the plaintiff and
the extrinsic matters alleged in the declaration may be
shown by the testimony of witnesses who knew the parties
and circumstances and who can state their judgment and
opinion upon the application and meaning of the terms used
by the defendant. It is said that where the words are
ambiguous on the face of the libel, to whom it was intended
to be applied, the judgment and opinion of witnesses, who
from their knowledge of the parties and circumstances are
able to form a conclusion as to the defendant’s intention and
application of the libel is evidence for the information of the
jury.”

Mr. Odgers, in his work on Libel and Slander (p. 567),

says:
The plaintiff may also call at the trial his friends or others
acquainted with the circumstances, to state that, in reading
the libel, they at once concluded it was aimed at the
plaintiff. It is not necessary that all the world should
understand the libel. It is sufficient if those who know the
plaintiff can make out the he is the person meant.”
(Underlining supplied)

Whether a man is called by one name or whether he is called by

another or whether he is described by a pretended description of a
class to which he is known to belong, if those who look on know well
who is aimed at, the very same injury is inflicted, the very same thing
done as would be done if his name and Christian name were ten
times repeated.2

Concerning the applicability of the ruling of the Honorable

Supreme Court in the MVRS case, Complainant respectfully holds
that the main ruling therein is not applicable to the instant complaint.
Moreover, Respondent has not yet even submitted his Counter-
Affidavit.

In MVRS, the Supreme Court held that:

2
Cited in The Revised Penal Code by Ramon C. Aquino 1988 edition Volume Three, at pages 537-
538, with the following footnote: Per Campbell, C.J. Le Fanu v. Malcohusen, 1 H.L.C. 668 cited in
Jakosalem case. See Corpus v. Cuaderno, 123 Phil. 651.

5
 “[D]eclarations made about a large class of people cannot be
interpreted to advert to an identified or identifiable individual.
Absent circumstances specifically pointing or alluding to
a particular member of a class, no member of such class has
a right of action without at all impairing the equally
demanding right of free speech and expression, as well as the
press, under the Bill of Rights.” (Emphasis supplied)

Notably, such circumstances already require matters aliunde or

extraneous facts, which are evidentiary in nature to be properly
ventilated during the trial proper.  In the meantime, it suffices to note
that the Judicial Affidavit-Complaint of private omplainant
sufficiently alleges that the defamatory remarks of Respondent were
directed at him as a District minister of the Iglesia Ni Cristo.

Moreover, in MVRS, the Complainants therein (Islamic Da’wah

Council of the Philippines and individual Muslims) were allowed to
go to trial and present their evidence. It was only after trial on the
merits in the lower courts that the Supreme Court made the
pronouncement that “declarations made about a large class of people
cannot be interpreted to advert to an identified or identifiable
individual.”

In the present case, private complainant was not given the

opportunity to present his evidence in court “specifically pointing or
alluding to a particular member of a class”. Nonetheless, it must be
noted that private complainant made more than sufficient allegations
in his Judicial Affidavit-Complaint already pointing to these facts.

In the MVRS case, the published malicious statement was

against the Muslims. The group, referring to Muslims, is too vast as
to readily ascertain who among the Muslims were particularly
defamed. In this case, the group, referring to ministers of the Iglesia
Ni Cristo, is one that is small, cohesive and restricted within another
group of persons, that is, the religious organization, Iglesia Ni Cristo.

The subject of the malicious statement in the MVRS case were

Muslims in general not the preachers of the doctrines of Islam. In this
case, the malicious statement was directed to the ministers, not the
members, of the Iglesia Ni Cristo.

In MVRS, the Supreme Court held:

“In the instant case, the Muslim community is too

vast as to readily ascertain who among the Muslims were

6
 particularly defamed. The size of the group renders the
reference as indeterminate and generic as a similar attack on
Catholics, Protestants, Buddhists or Mormons would do.
The word “Muslim” is descriptive of those who are believers
of Islam, a religion divided into varying sects, such as the
Sunnites, the Shiites, the Kharijites, the Sufis and others
based upon political and theological distinctions. “Muslim”
is a name which describes only a segment of the Philippine
population, comprising a heterogenous body whose
construction is not so well defined as to render it impossible
for any representative identification.”

xxx

The Muslim population may be divided into smaller

groups with varying agenda, from prayerful conservative to
the passionately radical. These divisions in the Muslim
population may still be too large and ambiguous to provide
the reasonable inference to any personality who can bring a
case in an action for libel. (at p. 223, Emphasis supplied) “

By contrast, the ministers (particularly District Ministers) of the

Iglesia Ni Cristo are just small, cohesive and restricted groups of
persons within a single religious organization. It is susceptible to
representative identification like in this case. The Iglesia Ni Cristo
has no sects like in the case of Islam, which is a religion divided into
sects.

In MVRS, the Supreme Court extensively discussed some

guiding principles on libel, as follows:

1. “Declarations made about a large class of people cannot be

interpreted to advert to an identified or identifiable individual.
Absent circumstances specifically pointing or alluding to a
particular member of a class, no member of such class has a right
of action”. (at p. 219)

2. “One guiding principle in group libel is that defamation of a large

group does not give rise to a cause of action on the part of an
individual unless it can be shown that he is the target of the
defamatory matter”. (at p. 221)

3. “There are groupings which may be finite enough so that a

description of the body is a description of the members.” (at p. 222)

7
 4. “If the defamatory statements were directed at a small, restricted
group of persons, they applied to any member of the group, and an
individual member could maintain an action for defamation. When
the defamatory language was used toward a small group or class,
including every member, it has been held that the defamatory
language referred to each member so that each could maintain an
action. This small group or class may be a jury, persons engaged
in certain businesses, professions or employments, a restricted
subdivision of a particular class, a society, a football team, a
family, small groups of union officials, a board of public officers, or
engineers of a particular company.” (at p. 225)

5. “A prime consideration, therefore, is the public perception of the

size of the group and whether a statement will be interpreted to
refer to every member. The more organized and cohesive a group,
the easier it is to tar all its members with the same brush and the
more likely a court will permit a suit from an individual even if the
group includes more than twenty-five (25) members.” (at p. 226)

In dismissing the complaint, the Honorable Investigating

Prosecutor, with due respect, failed to take into account the foregoing
principles provided by the Supreme Court precisely to guide not only
the courts, but also the prosecutors, in the appreciation of facts and
evidence.

The Honorable Investigating Prosecutor failed to appreciate

allegations in the Judicial Affidavit-Complaint to be actually proving
the following:

1. Circumstances specifically pointing or alluding to a

particular member of a class (District Ministers of the Iglesia
Ni Cristo);

2. The private complainant is the target of the defamatory

matter being a District Minister of the Iglesia Ni Cristo;

3. The group, District Ministers of the Iglesia Ni Cristo, is a

group which is finite enough so that a description of the
body is a description of the members;

4. The group, District Ministers of the Iglesia Ni Cristo, is

small, restricted set of persons such that the libelous
statement of Respondent was directed to the Complainant
being one of the members of the group. Thus, giving him the
right to maintain a suit against Respondent;

8
 5. The group, District Ministers of the Iglesia Ni Cristo, is one
that is organized and cohesive.

Indeed, the group, District Ministers of the Iglesia Ni Cristo,

and the individual District ministers defamed are identifiable.
Respondent directed the libelous statement against them. The
defamatory remark is so sweeping and all-embracing so as to include
each and every minister of the Iglesia Ni Cristo. Hence, a minister,
specifically the District Minister like the private complainant can
bring an action for libel against respondent.

In addition, the Investigating Prosecutor did not consider the

defamatory statements of respondent in the subject letter which
should be considered in its entirety. What was taken into
consideration only was the interview by Karen Davila;

The defamatory statements in the subject letter are quoted as

follows:

“Subalit hindi napigil sa ganitong pangyayari ang

pagkauhaw ni Ka Jun sa salapi. Ipinagpapatuloy po niya
ang kaniyang nasimulan at matatag na pinagkakakitaan
niya ng salapi ng iglesia ang ukol sa pagbili ng mga lupa
at ari-arian ng iglesia. Kasabwat niya sa maling gawaing
ito ang noon ay iilan pa lamang na mga tiwaling mga
Tagapangasiwa (emphasis supplied) sa mga
lalawigan. Ang mga ari-ariang nakatakdang bilhin ng
iglesia na nagkakahalaga ng mga malalaking halaga ay
pinapupuntahan niya sa kaniyang mga sariling ahente
upang sila ang makikipag-usap sa mga may-ari nito at
nang sa ganon ay mapatungan nila ang presyo at
makakuha ng porsiyento.”

The issue in this case is whether district ministers belong to a

large group such that the identity of the person defamed cannot be
determined;

From these statements in the letter of respondent, he accused

Glicerio Santos, Jr. or Ka Jun of conniving and conspiring with
District Ministers or Tagapangasiwa sa mga lalawigan in profiting in
the purchase of properties, real or otherwise, by the Iglesia Ni Cristo
or INC.

9
 The INC has a total of one hundred thirty six (136)
ecclesiastical districts in the whole world (not 130 in the Philippines
and 102 in other countries as cited to in the Resolution). Every
ecclesiastical district is headed by a District Minister. This group of
district ministers is a small, restricted group of persons like the Chief
Prosecutors Association of the Philippines, the group of chief
prosecutors and the State Prosecutors Association, the group of state
prosecutors.

Complainant is the District Minister of the ecclesiastical district

of Zamboanga del Norte which comprises the province of
Zamboanga del Norte, Dipolog City and Dapitan City.

The defamatory statements of respondent definitely pertain to

the involvement of Ka Jun and the District Ministers specifically in
the provinces in the purchase of properties by the INC. He did not
allude to just any INC minister or the ministers who are members of
the Sanggunian or the Advisory Council. Members of the Advisory
Council are not District Ministers. And the transaction specifically
mentioned was the purchase of properties by the INC.

A person interested in selling his property to the INC observes

and complies with strict procedures. Attached hereof as Annex “A” is
the Affidavit of Bro. Brandon T. Calunia, District Land Registration
Officer of the INC, Zamboanga del Norte Eccelesiastical District,
shedding light of these transactions.

The final decision to buy any property, more specially a real

property, is given by the INC Executive Minister. Glicerio Santos, Jr.
or the District Minister does not intervene in whatever capacity.
There is no way for them to gain or profit in the approval of the sale
and in the subsequent payment or in the language of respondent
“mapatungan nila ang presyo at makakuha ng porsiyento”.

It is our contention that with these arguments, the element of

identity is sufficiently established. The unfounded accusations of
respondent specifically pointed to him. He was the target of
respondent’s defamatory statements. He has established personal
reference to himself. He has an individual cause of action for this case
to prosper. Complainant’s reputation as District Minister has been
hurt and his standing in the community has been impaired.

Worthy to be observed also is the fact that the complaint is

anchored on the following pronouncements made by the respondent
aired during the interview with Ms. Karen Davila. Thus:

10
 “Pero ang mga ministro po ngayon na nasa posisyon ay
makikita ninyo nakahilera sa kanilang bahay ang iba’y itinago
na ngayon mula ng sila ay maibulgar, nakahilera at paibaba ang
mga luxury cars. Anakakahalaga ng 30g kanilang mga asawa ay
mga signature ang mga sout na mga damit, mga bags, na ng
P30,000, P100,000, P500,000 bags pa lang. Ang mga
ministrong ito ay pabalik balik sa kung saan saang bahagi ng
daigdig para magbakasyon kasama ng boung pamilya. Doon po
ay makikita na ninyo ang korapsyon.”

Likewise, the respondent has published a letter in his website

https://joselakas.wordpress.com, pertinent portion of which reads:
“May mga text messages po akong natanggap,
impormasyon ng ilang kapatid na nagmamalasakit at ang sabi
ay magtago ako dahil ipinahahanap at ipinapapatay. Ito raw po
ay naririnig nila sa pag-uusap ng ilang mga ministro.”

The private complainant alleged that the above

pronouncements are, on its face, scurrilous and defamatory.

The publication has sufficiently identified the complainant

As shown above, the scurrilous publication has sufficiently

identified the private complainant since it is undisputed that he is
one of the ministers of the Iglesia ni Cristo “nasa posisyon”. Hence,
such malicious imputation clearly includes the private complainant;

The dissertation made by this Honorable Office that such phrase

“suggest a lot of meanings” and it could also refer: a) to those who
are holding higher positions in the INC, such as those senior ministers
which comprises the Church Economic Council or Lupon ng
Sanggunian”, or b) to the “district ministers” or c) to “all the ministers
who are working at the Central Office of the INC”. On the basis thereof,
this Honorable Office concludes that “the aforementioned remark is
so broad and sweeping that the person allegedly defamed could not
be identifiable”.

But, what this Honorable Office has failed to appreciate is the fact
that under the afore-quoted jurisprudence, the Supreme Court has
made this fine distinction that the dismissal of the complaint for libel
was anchored “on the ground that private respondents failed to state
a cause of action since they made no allegation in the complaint that
anything contained in the article complained of specifically referred
to any of them.”

11
 Simply put, the dismissal was not based on the proposition that
the scurrilous remark or article was “so broad and sweeping that the
person allegedly defamed could not be identifiable” but that the
complaint itself made no allegations that such scurrilous remark or
article specifically referred to the complainant as one of the persons
being alluded to.

In the instant case, the complainant has made the following

allegations, to wit:

“3.
Q – Please state your personal circumstances.

A – I am NESTOR B. ILARDE, of legal age,

married, Filipino and presently residing at INC
Compound, 089 Magsaysay Street, Dipolog,
Zamboanga del Norte. I am the District Minister
of Iglesia Ni Cristo for Zamboanga del Norte.

xxx.

9.
Q – Do you remember what the interview of Karen
Davila to Eliodoro “Joy” Yuson, Jr. all about?

A – It was an interview wherein Mr. Yuson

mentioned that the Ministers of Iglesia Ni Cristo
were corrupt;

xxx.

14.
Q – What was your reaction on that interview of
Karen Davila to Mr. Yuson?

A – I got mad with the accusations of Eliodoro

“Joy” A. Yuson, Jr. to the ministers of Iglesia ni
Cristo. A am very affected mentally and
emotionally. I could not even think of any reason
why would Eliodoro “Joy” A. Yuson, Jr. say those
accusations when he knew very well the kind of life
we have as ministers of the gospel because he was
once our colleague in the ministry.

12
15.
Q – Continue further.

A – as a minister of Iglesia Ni Cristo who is in the

position, I am directly affected by the accusations of
Eliodoro “Joy” A. Yuson, Jr. because deep within
me, I know that it is not true. Eliodoro “Joy” A.
Yuson, Jr. fabricated stories to put not only the
minister of the INC but the entire church in a
blatant shame.

16.
Q – Continue further.

A – Eliodoro “Joy” A. Yuson, Jr. initiated the

interview because he was one who called and
contact DZMM Teleradyo, he knew for a fact that
many people may be able to watch his interview on
TV hoping that many people will believe in his
stories and subsequently cause doubts to a lot of
people who respects us.

17.
Q – Mr. Yuson mentioned in his interview that
ministers who are in position possess different
luxury cars, do you have any luxury car?

A – None Sir. I do not have even (1) luxury car.

18.
Q – It is also mentioned in his interview that the
wives of the ministers wear signature dresses and
bought bags ranging from Php30,000.00,
Php100,000.00 and Php500,000.00, is it true?

A – No Sir. I vehemently deny that allegation of

Eliodoro “Joy” A. Yuson, Jr. against the wives of
the INC ministers.

19.
Q – Did you happen to go on vacation abroad?

A – No Sir. Not even once, Mr. Yuson’s accusation

of corruption against us, the ministers of the INC

13
 were all lie, baseless, fabricated and a product only
of his hallucinations;

xxx.

28.
Q - Do you admit the accusation of Mr. Yuson in
his letter?

A – No Sir. I vehemently deny the accusation of

Mr. Yuson in his letter. The statement of Mr.
Yuson “ipinahahanap ako at ipinapapatay” was a
clear accusation of a crime that we, the INC
ministers will never do. He said these accusations to
destroy our reputation not only to our brothers and
sisters in the church but to the community who
respects us.

29.
Q - What else do you want to say?

A – As one of the Ministers who hold a position in

our District, I am loved and valued by my brothers
and sisters but due to these malicious and
unfounded accusations of Mr. Yuson against the
ministers of INC, I was put in a blatant shame;”

Clearly, the above allegations in the complaint filed with this

Honorable Office has unmistakably indicated that the complainant is
one of the ministers of the Iglesia Ni Cristo being alluded to in the
defamatory remark or article made by the herein respondent;

Not only did the complainant alleged that he is the District

Minister of the Iglesia Ni Cristo, but more importantly, he made
several allegations that he is a minister who hold a high position in
the church hierarchy and that he felt aggrieved and alluded to as one
of the ministers mentioned in the defamatory remarks and article
subject of the instant complaint. Hence, the dismissal based on the
lack of identity of the person defamed cannot be justified.

PRAYER

14
 WHEREFORE, premises considered, it is most respectfully
prayed of the Honorable Investigating Prosecutor that the Resolution
dated February 2, 2016 be SET ASIDE and a new one be ENTERED,
recommending the filing of the Information for Libel in court.

Complainant prays for such other reliefs and remedies

available under the premises.

Dipolog City, 19 February 2016.

ATTY. EULOGIO L. LAGUDAS, JR.

Counsel for Private Complainant
IBP NO. 939541 1-4-16
PTR NO. 5216827 1-4-16
ROLL OF ATTYS. NO. 56396
MCLE COMP. NO. V-0018672 4-7-14
G/F, Philja Bldg., Calibo St., Dipolog City

VERIFICATION

15
 I, NESTOR B. ILARDE, of legal age, married, Filipino and
presently residing at INC Compound, 089 Magsaysay Street,
Dipolog, Zamboanga del Norte., after having been sworn to in
accordance with law hereby depose and state:

1. I am the complainant in this case for Libel against

Eliodoro Yuson docketed as I.S. NO. IX-03-INV-15L-03212
filed in the Office of the City Prosecutor, Dipolog City;

2. I have caused the filing of the Motion for Reconsideration

and that I have read the same and that the allegations
therein are true and correct of my own personal
knowledge and based on authentic documents.

IN WITNESS WHEREOF, I have hereunto set my hand this

19th
day of February 2016 in the City of Dipolog.

NESTOR B. ILARDE
Affiant

SUBSCRIBED AND SWORN to before me this 19th of February

2016 in the City of Dipolog affiant exhibiting his
_______________________________ as valid proof of his identity.

NOTICE OF HEARING

Office of the City Prosecutor

Dipolog City

16
Eliodoro Yuson
Respondent
No. 36 Tandang Sora Avenue, New Era,
Quezon City

Greetings!

Please be informed that the foregoing Motion will be heard on

March 4, 2016, at 2:00PM for the consideration and approval of the
Honorable City Prosecutor without appearance of counsel and
further arguments.

EULOGIO L. LAGUDAS, JR.

EXPLANATION

The foregoing Motion is served through mail due to distance

and lack of personnel to effect personal service.

EULOGIO L. LAGUDAS, JR.

Copy furnished:

Eliodoro Yuson

Reg. Rec. N0.

Date:

17