REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

National Capital Judicial Region
Branch 1
Manila

JUAN DELA CRUZ,

Plaintiff,
Special Civil Action No. 12345
-versus-

H.E. PRES. BENIGNO

SIMEON C. AQUINO III,
In his capacity as President
Of the Republic of the Philippines;
Atty. Dominique Q. Roque, in his capacity
As Executive Secretary; and
MACARIO O MACALINTAL, in his capacity as
Secretary of the Department of Budget
And Management,
Defendants.
x-----------------------------------------x

COMPLAINT

Plaintiff, through the undersigned counsel, respectfully avers that:

1. Plaintiff Juan dela Cruz, employee of PHILTHEALTH, single, and a resident of 1

Recto Ave., Manila and; defendant Benigno Simeon C. Aquino III is the President
of the Republic of the Philippines (Pres. Aquino) while defendant Atty. Dominique
Q. Roque is the Executive Secretary of the President of the Republic of the
Philippines and Defendant Macario O. Macalintal as Secretary of the Department
of Budget and Management.
2. Defendant issued Executive Order 7 which precluded the Board of Directors,
Trustless and/or Officers of GOCCs from granting and releasing bonuses and
allowances to members, and from increasing salary rates of and granting new or
additional benefits and allowances to their employees;
3. The plaintiff claims that as a Phil Health employee, he is affected by the
implementation of EO 7, which was issued with grave abuse of discretion
amounting to lack or excess of jurisdiction, for the same has not ripened into law
for lack of publication.
4. That the execution of such law without the necessary publication will be inimical
and greatly prejudice his rights to his compensation and benefits;
5. The plaintiff trust that the declaration by the court on this question is necessary
and would terminate the uncertainty or controversy, which gave rise to the action.

WHEREFORE, it is respectfully prayed of this Honorable Court to determine the

validity of the Executive Order in question and to declare plaintiff’s rights and duties
thereunder.

City of Manila, Philippines, March 4, 2016.

 ATTY. JUANICO FRANCISCCO
Counsel for Defendant
Unit 1, X Building, Recto, Manila
IBP No. 123456; 01/10/10 – Manila
PTR No. 1234567; 01/10/10 – Manila
Roll No. 12345; 5/05/05
MCLE No. I – 001234; 9/09/09
MCLE No. II – 115678; 9/09/09

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