Complainant,: Complaint Affidavit

Republic of the Philippines
CIVIL SERVICE COMMISSION

Regional Office No. 02
Tuguegarao City, Cagayan
NOEL CERBAS, Case no. _____________

Complainant,
-versus-
LOLITA A. TACMO,
NANCY G. PERALTA,
Respondenst.
x----------------------------------------x
COMPLAINT AFFIDAVIT
I, NOEL M. CERBAS, Filipino, of legal age, widower, and a resident of

Cabatacan East, Lasam, Cagayan, after having been sworn to in accordance
with law, hereby depose and state that:
1. I am executing this affidavit to file a complaint against LOLITA A.

TACMO and NANCY G. PERALTA who are both Rural Sanitary
Inspector I assigned at the Rural Health Unit of the Local
Government Unit of Lasam, Cagayan;
2. On August 27, 2019, I wrote a letter to our Municipal Health

Officer, Dr. Lorelie R. Remando complaining the pig pen
maintained by Mary Jane Rabanal located near the house of the
undersigned;
Attached and marked as Annex “A” is a copy of the letter complaint

dated August 27, 2019;
3. The undersigned complained among others the cleanliness of the

pig pen and its foul odor and questioned the permit of the piggery;
4. I made a follow up of my request on September 10, 2019 upon

which the above named inspectors entertained me but in harsh
manner. They shouted at me saying that I keep coming back in
their office when in truth it was my first time to follow up my letter
complaint;
5. On September 26, 2019, the RHU through Municipal Health

Officer Lorelue R. Remando, M.D issued a Sanitary Order with
listed Recommendations thereof;
Attched and marked as Annex “B” is a copy of the Sanitary Order

dated September 26, 2019;
6. Despite the Sanitary Order issued by the RHU, Mary Jane Rabanal
refused to obey the order and continued the operation of its
piggery, thus the undersigned again made a follow up of his
complaint on October 02, 2019. They informed him to just wait for
the actions to be taken by the RHU;
7. Thus on October 10, 2019 hoping that the inspectors will
understand his dilemmas considering that he already incurred
considerable amount for his medication and hospitalization due to
illness caused by the filthy piggery, he again went to the RHU for a
follow up where the two assigned inspectors entertained him and
he was shocked when they in chorus shouted at him and said that:
“Bakit anong alam ninyo sa trabaho namin? Bakit mas alam mo ba
ang trabaho namin? Bakit pabalik balik kayo dito?”
8. At that time I was with my nephew JOEL AMARLES so he

witnessed how these two government employees shouted and
humiliated me. Attached and marked as Annex “C” is the affidavit
of Joel Amarles;
9. Section 4 of RA 6713 or the CODE OF CONDUCT AND ETHICAL

STANDARDS FOR PUBLIC OFFICIALS AND EMPLOYEES (REPUBLIC
ACT NO. 6713) specifically paragraph (c) and (e) provide:
Section 4. Norms of Conduct of Public Officials and Employees. - (A)

Every public official and employee shall observe the following as
standards of personal conduct in the discharge and execution of
official duties:
(a) xxx
(b) xxx
(c) Justness and sincerity. - Public officials and employees shall

remain true to the people at all times. They must act with
justness and sincerity and shall not discriminate against anyone,
especially the poor and the underprivileged. xxx
(d) xxx
(e) Responsiveness to the public. - Public officials and employees

shall extend prompt, courteous, and adequate service to the
public. Unless otherwise provided by law or when required by the
public interest, public officials and employees shall provide
information of their policies and procedures in clear and
understandable language, ensure openness of information, public
consultations and hearings whenever appropriate, encourage
suggestions, simplify and systematize policy, rules and procedures,
avoid red tape and develop an understanding and appreciation of
the socio-economic conditions prevailing in the country, especially
in the depressed rural and urban areas.
10. I am executing this affidavit to support my complaint against

LOLITA A. TACMO and NANCY G. PERALTA for conduct
unbecoming in violation of RA 6713 particularly section 4 (c) and
(d) thereof and to attest to the truth of the foregoing and for
whatever legal purpose it may serve.
IN WITNESS WHEREOF, I have hereunto set my hand this
___________________ in Tuguegarao City, Cagayan.
NOEL M. CERBAS
Complainant-Affiant
SUBSCRIBED AND SWORN TO before me this ______________ in

Tuguegarao City.
ATTY. JOANNA MARIE M. ABEL

Public Attorney II
Pursuant to RA 9406
Noted by:
ATTY. RODELIO MATILA

OIC/Public Attorney III
VERIFICATION AND
CERTIFICATION OF NON-FORUM SHOPPING
I, NOEL M. CERBAS, Filipino, of legal age, widower, and a resident of Zone 5,

Cabatacan East, Lasam, Cagayan, after having been sworn to in accordance
with law, hereby depose and state that:
1. That I am the complainant in the above entitled case;
2. That I have caused the preparation of the foregoing Complaint;
3. That the allegations contained therein are true and correct of my

personal knowledge and belief, and based on authentic records
and/or documents;
4. That I have not commenced any other action or proceedings involving

the same issues before the Supreme Court, Court of Appeals, Regional
Trial Court and of any other judicial, administrative or quasi-judicial
bodies and/or any government authority;
5. That if I should learn of any cause, petition or complaint filed or

pending before the Supreme Court, Court of Appeals, Regional Trial
Court and of any other judicial, administrative or quasi-judicial
bodies and/or any other government authority, we undertake to
report such fact within five (5) days upon knowledge thereof.
In witness whereof, I have here unto affixed my signature this

___________________ in Tuguegarao City, Cagayan.
NOEL M. CERBAS
Complainant
Subscribed and sworn to before me this _________________ in Tuguegarao

City, Cagayan after complainants exhibited to me their proof of identification.
REPUBLIC OF THE PHILIPPINES)
PROVINCE OF CAGAYAN ) S.S.
CITY OF TUGUEGARAO )
x-----------x
AFFIDAVIT
We, JOEL P. AMARLES of legal age, Filipinos and resident of Zone 5,

Cabatacan East, Lasam, Cagayan after being duly sworn to in accordance with
law, hereby depose and state:
1. That I am presently residing at the house of my uncle Noel Cerbas at

Cabatacan East, Lasam, Cagayan;
2. That I knew that he submitted a letter to the LGU of Lasam, Cagayan

complaining the operation of a piggery owned by Mary Jane Rabanal
because of its foul odor which became the cause of my uncle’s illness;
3. On October 10, 2019 I accompanied my uncle the Rural Health Unit of

Lasam, Cagayan to follow up her complaint because apparently the
operations of the piggery owned by Mary Jane continued;
4. I was shocked when Lolita Tacmo and Nancy Peralta, the Rural Sanitary
Inspectors of LGU Lasam, Cagayan shouted at my uncle which caused
fear and humiliation to my uncle;
5. I am executing this Affidavit to attest to the truthfulness of the foregoing

and to support the case filed by Noel Cerbas against Lolita Tacmo and
Nancy Peralta.
IN WITNESS WHEREOF, we have hereunto set our hand this

_______________ at Tuguegarao City, Cagayan, Philippines.
JOEL P. AMARLES
Affiant
Subscribed and sworn to before me this _______________ in Tuguegarao

City, Cagayan after affiants exhibited to me their proof of identification.
ATTY. JHOANNA MARIE M. ABEL

Public Attorney II
(Pursuant to RA 9406)

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Republic of the Philippines

CIVIL SERVICE COMMISSION

NOEL CERBAS, Case no. _____________

I, NOEL M. CERBAS, Filipino, of legal age, widower, and a resident of

1. I am executing this affidavit to file a complaint against LOLITA A.

2. On August 27, 2019, I wrote a letter to our Municipal Health

Attached and marked as Annex “A” is a copy of the letter complaint

3. The undersigned complained among others the cleanliness of the

4. I made a follow up of my request on September 10, 2019 upon

5. On September 26, 2019, the RHU through Municipal Health

Attched and marked as Annex “B” is a copy of the Sanitary Order

8. At that time I was with my nephew JOEL AMARLES so he

9. Section 4 of RA 6713 or the CODE OF CONDUCT AND ETHICAL

Section 4. Norms of Conduct of Public Officials and Employees. - (A)

(c) Justness and sincerity. - Public officials and employees shall

(e) Responsiveness to the public. - Public officials and employees

10. I am executing this affidavit to support my complaint against

SUBSCRIBED AND SWORN TO before me this ______________ in

ATTY. JOANNA MARIE M. ABEL

ATTY. RODELIO MATILA

CERTIFICATION OF NON-FORUM SHOPPING

I, NOEL M. CERBAS, Filipino, of legal age, widower, and a resident of Zone 5,

1. That I am the complainant in the above entitled case;

2. That I have caused the preparation of the foregoing Complaint;

3. That the allegations contained therein are true and correct of my

4. That I have not commenced any other action or proceedings involving

5. That if I should learn of any cause, petition or complaint filed or

In witness whereof, I have here unto affixed my signature this

Subscribed and sworn to before me this _________________ in Tuguegarao

We, JOEL P. AMARLES of legal age, Filipinos and resident of Zone 5,

1. That I am presently residing at the house of my uncle Noel Cerbas at

2. That I knew that he submitted a letter to the LGU of Lasam, Cagayan

3. On October 10, 2019 I accompanied my uncle the Rural Health Unit of

5. I am executing this Affidavit to attest to the truthfulness of the foregoing

IN WITNESS WHEREOF, we have hereunto set our hand this

Subscribed and sworn to before me this _______________ in Tuguegarao

ATTY. JHOANNA MARIE M. ABEL

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