Petition For Writ of Kalikasan (Marj)

Republic of the Philippines
SUPREME COURT
Manila
JOAN MESIA, ROY VILLARINO

BIANCA PAGUIAN, RENALYN
MAGAT, PRINCE CALO,
RUFFA PARAYNO, ARIANNE
CANTILLERO, PAULA GONO
and KALEY SANTIAGO,
collectively referred to as the
CONCERNED CITIZENS OF
STO. TOMAS, BATANGAS,
Petitioners,
SC G.R. SP No._________
Petition for Writ of Kalikasan
with a Prayer for TEPO
- versus -
HON. EUGENE DIZON, in his

capacity as Secretary of the
DEPARTMENT OF
ENVIRONMENT AND
NATURAL RESOURCES,
LILIBETH RAMIREZ, in her
capacity as the Regional Director of
ENVIRONMENTAL
MANAGEMENT BUREAU-
REGION IV, HON. MIGUEL SY
in his capacity as Mayor of the
MUNICIPALITY OF STO.
TOMAS, BATANGAS, the
SANGGUNIANG BAYAN OF
STO. TOMAS, SANGGUNIANG
BARANGAY OF ARKANGEL,
STO. TOMAS, BATANGAS and
EVERLASTING ENERGY
CORPORATION,
Respondents,
X----------------------------------------X
PETITION FOR WRIT OF KALIKASAN

(With a Prayer for the Issuance of a Temporary Environmental
Protection Order)
Petitioners, by the undersigned counsel, to this Honorable Court, most
respectfully aver:
PREFATORY STATEMENT
Water is the essence of life. Without water, the Earth will not be able
to sustain life. Without water, humans and all living things on Earth will
perish and die. Furthermore, water is our daily companion; we use it every
day and almost in every activity, from bathing to drinking, water is the basic
and most essential of all human needs.
It is therefore no laughing matter when an activity endangers the

cleanliness and palatability of water, especially when it is of such magnitude
as to affect several communities and hundreds of inhabitants and thousands
from generations yet to be unborn.
NATURE AND URGENCY OF THE PETITION
1. This is a petition for the issuance of a Writ of Kalikasan with a

prayer for the issuance of a Temporary Environmental Protection Order
(TEPO) under the Rules of Procedure for Environmental Cases, urgently
seeking to enjoin the unsanitary dumping of discarded waste and expired
stocks of inventory composing mostly of batteries along the coastline of
Sabagang Beach in Brgy. Arkanghel, Sto. Tomas, Batangas.
2.
THE PARTIES
1. The following are the Petitioners:
PRAYER
WHEREFORE, premises considered, it is respectfully prayed of this
Honorable Court that a Writ/Order be issued to respondents to bring the
person of JOSELITO DELA CRUZ to this Honorable Court at the hour and
date to be set by this Honorable Court, and thereafter, to immediately
ORDER his release from the illegal detention committed and being
committed by the respondents.
Petitioner also prays for other reliefs as may be deemed just and
equitable in the premises.
Calamba City for the City of Manila, 11th March 2018

ATTY. MARJORIE CAMILLE FLORES
Counsel for the Petitioner
Unit 209 Page 1 Bldg. Calamba City
Roll No. 155427
IBP No. 22561
PTR No. 8712560
MCLE Compliance No. 0091269
Tel. Nos. 853-4322; 853-4355
Republic of the Philippines)

Calamba City ) s.s.
VERIFICATION AND CERTIFICATION OF

NON-FORUM SHOPPPING
I, JENNIFER DELA CRUZ, of legal age, Filipino, married and with

address at #123 San Antonio Compound, Barangay Uno, Calamba City, state
under oath that:
1. I am the petitioner in the above-entitled case;
2. I have caused the preparation of the foregoing Petition on my own

behalf and on behalf of my husband who is being illegally detained
and I have read and understood its contents, including its annexes, and
the same are true and correct to the best of my knowledge and/or
based on authentic records.
3. That I have not commenced any action of proceeding involving the

same issue in the any other court, tribunal or agency; that to the best
of my knowledge, no such action or proceeding, involving the same
parties and the same facts and issues, is pending in the any court,
tribunal or agency, and that, if I should learn thereafter that a similar
action or proceeding has been filed or is pending before these courts,
tribunal or agency, I undertake to report that fact to this Honorable
Court within five (5) days therefrom.
IN WITNESS WHEREFORE, I Have hereunto set my hand this 5th day of

October, 2015.
JENNIFER DELA CRUZ

Affiant
SUBSCRIBED AND SWORN to before me on the same date above, at

Manila City, affiant exhibiting to me her Driver’s License with ID No.
98776125 issued by the Land Transportation Office Quezon City on January
10, 2016 valid until January 12, 2019.
ATTY CHRISTIAN MESIA

Notary Public
Unit 11 A Bldg. Quezon City
Roll No. 899427
IBP No. 097561
PTR No. 11152560
MCLE Compliance No. 0091269
Serial No. of Commission M-1264
Valid Until December 20, 2020
Doc No._______
Page No:______
Book No.______
Series of 2018

Petition For Writ of Kalikasan (Marj)

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Republic of the Philippines

JOAN MESIA, ROY VILLARINO

HON. EUGENE DIZON, in his

PETITION FOR WRIT OF KALIKASAN

It is therefore no laughing matter when an activity endangers the

NATURE AND URGENCY OF THE PETITION

1. This is a petition for the issuance of a Writ of Kalikasan with a

1. The following are the Petitioners:

Calamba City for the City of Manila, 11th March 2018

Republic of the Philippines)

VERIFICATION AND CERTIFICATION OF

I, JENNIFER DELA CRUZ, of legal age, Filipino, married and with

1. I am the petitioner in the above-entitled case;

2. I have caused the preparation of the foregoing Petition on my own

3. That I have not commenced any action of proceeding involving the

IN WITNESS WHEREFORE, I Have hereunto set my hand this 5th day of

JENNIFER DELA CRUZ

SUBSCRIBED AND SWORN to before me on the same date above, at

ATTY CHRISTIAN MESIA

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