OFFICE OF THE DEPUTY OMBUDSMAN FOR LUZON
3RD FLOOR, OMBUDSMAN BLDG., AGHAM ROAD, DILIMAN, QUEZON CITY
MARCELINO N. RAMOS, Complainant OMB-L-C-10-0020-A -versus- For: Violation of R.A. No 3019
ARNOLD C. MARAMAG, ET. AL., Respondent/s, x-------------------------------------------------x MARCELINO N. RAMOS, Complainant OMB-L-A-10-0030-A -versus- For: Violation of R.A. No 6713
CECILIO JACINTO, Respondent, x-------------------------------------------------x JOINT MOTION FOR BILL OF PARTICULARS
Respondent/s, unto this Honorable Office most respectfully states:
1. Respondents ARNOLD C. MARAMAG, FERNANDO S. MARAMAG, HERMINIA G. SALVADOR in OMB-L-C-10-0020-A, and CECILIO JACINTO in OMB-L-A-10-0030-A, respectively, received a copy of the Orders issued by this Honorable Office on April 31, 2010, ordering them to submit their respective Counter-affidavits in answer to the attached Affidavit-complaints and supporting documents.
2. That the respondents have been preparing their respective counter-affidavits, but are having difficulty in squarely answering the charges against them as the affidavit-complaint suffers from insufficient definiteness, which necessities this motion for bill of particulars.
3. That as provided in the affidavit-complaints in both OMB-L-C-10-0020-A and OMB-L-A-10-0030-A, the charge of the complainant is that the respondents committed a violation of Republic Act 3019, a violation of Republic Act 6713 and the crime of Falsification under the Revised Penal Code. Such complaints are not definite and that the respondents are not being properly informed of the charges against them.
4. That the affidavit-complaint failed to indicate what particular prohibited act under Republic Act 3019 has been violated. In the same vein, the affidavit-complaint does not indicate what