Republic of the Philippines

NATIONAL WATER RESOURCES BOARD

8th Floor NIA Building, Edsa, Quezon City

NATIONAL IRRIGATION
ADMINISTRATION, REGION
VI,
Oppositor/Protestant, WATER USE CONFLICT
Case Nos. 2018-136 and
2018-137

-versus-

PURO ORO H2O COMPANY, INC.,

Applicant/Protestee.
X-----------------------------------------------X

MOTION TO WITHDRAW PROTEST

COMES NOW, the NATIONAL IRRIGATION

ADMINISTRATION (NIA) Region 6, as Protestant through its
undersigned counsel, most respectfully states that:

1. At the onset, Protestant received the Water Permit

Application of CYRIL L. TAMARION., dated February 8, 2018 last
March 15, 2018. No exact coordinates were indicated in the location
of its diversion point and only stating Aganan River; Brgy.
Talongadian, 5025 San Miguel Iloilo as its source/location thus,
Protestant was prompted to file its water protest;

2. However, it was only during the Preliminary Conference

held last November 14, 2018 that Protestant was clarified of the exact
location of Applicant’s extraction point particularly described as
follows: Latitude 10° 46’ 56.54” N, Longitude: 122° 29’ 49.70” E;

3. A perusal of NIA Region 6’s Aganan Dam’s diversion

point which is described as follows: Latitude: 10° 46’ 47.22” N,
Longitude: 122° 27’ 5.13” E, would indicate that the Applicant’s point

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of extraction is located downstream of Protestant’s coordinates.
Moreover, the diversion point of Applicant is located at a
considerable distance of more or less 6 kilometers from NIA’s
diversion point;

4. Considering that there are no existing projects by NIA

Region 6 located downstream of the diversion point, the considerable
distance of the two diversion points, and the fact that the extraction
point of the Applicant is located downstream of the Aganan Dam, the
proposed application of Applicant would not thereby necessarily
hamper NIA’s service areas;

5. In view of all the foregoing, the Protestant, NATIONAL

IRRIGATION ADMINISTRATION Region 6, hereby withdraws its
Water Protest against Applicant CYRIL L. TAMARION.

WHEREFORE, it is most respectfully prayed that an order be

issued confirming the withdrawal of the Water Protest by
NATIONAL IRRIGATION ADMINISTRATION Region 6 against
CYRIL L. TAMARION in the above-entitled case.

Iloilo City for Quezon City. December 5, 2018.

ENGR. BENJAMIN P. SANCHEZ

Division Manager A
Engineering & Operations Division
NIA Region 6
Brgy. Tacas, Jaro, Iloilo City

Copy furnished:

CYRIL L. TAMARION
Applicant - Protestee
Nonoc, Municipality of Larena
Province of Siquijor

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Registry Receipt No. _______________
Date: ___________

EXPLANATION

This motion is being served by registered mail, personal service

being impracticable on account of the distance between the office of
the undersigned and the office/residence of opposing counsel/party
and/or the Court.

ENGR. BENJAMIN P. SANCHEZ