Republic of the Philippine SUPREME COURT Manila ORIGINAL SANLAKAS Marie Marguerite M. Lopez. Petitioner, ~ versus - GR. No RODRIGO R. DUTERTE, as For: CERTIORARI and President and Commander-in- PROHIBITION with Chief of All the Armed Forces, Prayer for T.R.O. SENATE, and HOUSE OF REPRESENTATIVES, Respondents. PETITION PETITIONER SANLAKAS, by counsel, to this Honorable Supreme Court, states -- Prefatory Statement “It is dangerous to be right in matters on which the established authorities are wrong.” - Voltaire PARTIES 1. Petitioner is a party-list organization and multi-sectoral people's alliance organized and existing under the laws of the Republic of the Philippines with official address at 23-B Marunong Street, Brey. Central Quezon City. Founded in 1993, Sanlakas has been a Member of the House of Representatives for two (2) terms, in the 11th and 12th Congress, when it was represented by Congressman Renato Magtubo, Congressman Mario Cruz, and Congressman J.V. Bautista, It is represented in this petition by its President, Marie Marguerite M. Lopez; 2. Respondent Rodrigo R. Duterte is the President of the Republic of the Philippines with office address at Office of the President, MalacaiangPalace, Manila, where he may be served with summons, copy of this petition and such other process from this Supreme Court. As President, he signed into law Republic Act No, 11479 or The Anti-Terrorism Act of 2020 on July 3, 2020; and as Chief Executive and Commander-in-Chief of all the armed forces of the country, respondent will enforce and implement the said statute, 3. Respondent Senate is the Upper Chamber of the Congress of the Republic of the Philippines, which is the legislative branch of the govern- ment under Section 2, Article VI of our Constitution, and holds office at Senate, GSIS Building, Pasay City, where it may be served with summons, copy of this petition and such other process from this Supreme Court. Under its Constitutional functions, it will appropriate funds, with the House of Representatives, for the enforcement and implementation of Republic Act No. 11479 or The Anti-Terrorism Act of 2020; 4. Respondent House of Representatives is the Lower Chamber of the Congress of the Republic of the Philippines, which is the legislative branch of the government under Section 5, Article VI of our Constitution, and holds office at House of Representatives, Batasan Hills, Quezon City, where it may be served with summons, copy of this petition and such other process from this Supreme Court. Under its Constitutional functions, it will appropriate funds, with the Senate, for the enforcement and implementation of Republic Act No. 11479 or The Anti-Terrorism Act of 5. Since its founding in 1993, petitioner Sanlakas, thru its thousands of members, has been a staunch advocate of social, political, economic, cultural, and environmental changes in Philippine society, with the objective of improving the living conditions of the marginalized sectors, viz., workers, farmers, and urban poor community dwellers, and creating a just and equitable society; 6. In the process of this advocacy and its dissent against official government policies and actions, petitioner Sanlakas, thru its thousands of members, resort to mass actions, public rallies and demonstrations, workers’ strikes or stoppage of work, and such other popular mobilizations for protest and dissent, with the end in view of empowering the people and pressuring the government to enact laws and policies favorable to the Filipino masses and marginalized sectors; 7. Members of petitioner Sanlakas resort to mass actions and mobiliz- ations in the exercise of their Constitutional rights to peaceably assemble and their freedom of speech and of expression under Section 4, Article IIT of the 1987 Constitution, as a vehicle to publicly ventilate their advocacies, dissent, and, legitimate demands and to mobilize public opinion grievanceETITIONPage to support the same, and to oppose policies and actions of the government Which are detrimental to the rights of citizens and the welfare of the people. especially the marginalized masses: THE CASE 8. This is a petition for certiorari under Rule 65 of the 1997 Rul I Procedure assailing the validity on Constitutional grounds of R. 9 or The Anti-Terrorism Act of 2020, which was signed into law by respondent on July 3, 2020 with grave abuse of discretion amounting to a lack or exces of jurisdiction; 9. Further, this is a petition for prohibition under Section 2, Rule 65 of the 1997 Rules of Civil Procedure (0 command respondent to desist from enforcing and/or implementing R.A. No. 11479 or The Anti-Terrorism Act of which was signed into law by respondent and will thereafter be enforced and implemented with grave abuse of discretion amounting to a lack or excess of jurisdiction, and allocated public funds by way of budgetary appropriation by respondents Senate and House of Represent- atives with grave abuse of discretion amounting to a lack or excess of jurisdiction; 10. There is no appeal or any plain, speedy, and adequate remedy available to petitioner in the ordinary course of law, except the filing of this petition: 11. At the same time, this petition secks the issuance of Temporary Restraining Order (I.R.O.) against the respondents as members of petitioner Sanlakas stand to suffer grave injustice and irreparable damage which calls for the issuance of said Order under Section 5, Rule 58 of the 1997 Rules of Civil Procedure: MATERIAL ALLEGATIONS AND ARGUME Section 4 of R.A.No. 11479 Is Void For Being In Violation of Section 4, Article IIT of the 1987 Constitution And Under the Void-for-Vagueness Principle 12. The Anti-Terrorism Act of 2020, specifically under its Section 4, declares "advocacy, protest, dissent, stoppage of work, industrial or massPETITIO NPage 04 action, and other similar exercises of civil and political rights" as a crime of terrorism when such is "intended to cause death or serious physical harm to a person, to endanger a person's life, or to create a serious risk to public safer" and when its purpose "is fo intimidate the general public or a segment thereof, create an atmosphere or spread a message of fear, 10 provoke or influence by intimidation the government or any international organization, or seriously destabilize or destroy the fundamental political, economic, or social structures of the country, or create a public emergency or seriously undermine public safety". This is the practical effect of the double negative formulation in Section 4 of the The Anti-Terrorism Act of 2020 which defines the crime of "terroris 13. Advocacy, protest, dissent, stoppage of work, and industrial or actions are the forms and vehicles of free speech and expression mass utilized by the people, including petitioner Sanlakas, in the exercise of their rights as citizens under under Section 1, Article II of the 1987 Constitution, declaring the Philippines as "a democratic and republican state" whe "sovereignty resides in the people and all government authority emanat from them", 14, Advocacy, protest, dissent, stoppage of work, industrial or mass actions, and other similar exercises of civil and political rights are the forms taken in the exercise of the people's freedom of speech and expression and freedom of assembly categorically protected by Section 4, Article HI of the 1987 Constitution which commands that "no law shall be passed abridging ihe freedom of speech, of expression, or of the press, or the right of the people peaceably to assemble and petition the government for redress of grievance: 15. Th ‘errorism Act of 2020, however, considers "advocacy protest, dissent, stoppage of work, industrial or mass actions, and other similar exercises of civil and political rights" as the objective feature or overt act (actus reus) of the crime of terrorism if united with the subjective feature or intention (mens rea) "to cause death or serious physical harm to a person, to endanger a persons life, or to create a serious risk to public safety" and purpose (e.g., fo provoke or influence by intimidation the government, ete.) This creates the dangerous situation where the very acts protected and guaranteed by the 1987 Constitution can actually be, as applied on the ground, interpreted or assumed --due to the vagueness of the subjective feature-- by the police and military operatives to be the crime of terrorism: 16. The subjective features of the crime of terrorism in this case (viz., intention and/or purpose) will be highly dependent on the perception of the situation or facts by the law enforcement agent or military personnel authorized in writing by the executive and all-powerful / nti-TerrorismCouneil (ATC). And the absence of standards leaves such a wide latitude of discretion to law enforcement to determine whether “advocacy, protest, dissent. stoppage of work, and industrial or mass actions" are intended to cause the harms which the law seeks to abate. It is a fact of our life, based on long actual experience, that the police and military agents of the state have so frequently abused and misused their armed authority, especially when it comes to thei dealings with workers in the picket lines, urban poor community dwellers in demolition sites, farmers demanding land ownership, and demonstrating students. Since "intent" and "purpose" are a state of the mind. they become casily susceptible to various interpretations, oftentimes, to suit a particular agenda on the part of the police and military agents, if not the government itself, 17. By way of example, since the Anti-Terrorism law makes "advocacy, protest, dissent, etc." criminal as an act of terrorism if coupled with the purpose "Yo provoke or influence by intimidation the government xx X or seriously destabilize or x x x seriously undermine public safety”, what if a person, as his way of protest, denounces the President, respondent herein, on social media for his poor handling of the pandemic, the act of that person can be perceived as putting the President's life in danger (because of the public hatred it will tend to generate), thereby intending to “provoke” the government, which will place the act within the law’s definition of terrorism: 18, In another scenario of a worker's strike, if the labor union stages a lawful strike against their employer who locks himself up in the establishment where the strike is taking place, the act of the labor unionists can be viewed as “intending” to endanger their employer's life or to create a serious risk to public safety, and may therefore be considered an act of terrorism, making the workers liable under the draconian law. There can be myriad of examples, and much of them will be dependent on the fertile imagination of the ATC and its police and military personnel: 19. The glaring lack of standards to definitely gauge what constitutes, “provocation”, “influence”, “intimidation”, ot even destabilization, will take free speech, free expression, and free assembly to the realm of unlawful acts should such actions put government to task, say, for its ineptitude to contain the spread and rise of covid19 contamination, if recklessly or otherwise interpreted as “creating an atmosphere or spreading a message of fear, to provoke the government": 20. Acts of advocacy, protest, dissent, stoppage of work, industrial or mass action, and other similar exercises of civil and political are inherently driven by individual or collective intent. The intention of advocacy is to promote a cause. The intention of protest and dissent is to express disapproval. The intention of stoppage of work, industrial or mass action, iseee a ————-™”~™”™-—sur— eset eettst—‘—~é~=zr PETITIONPage 06 to seek better wages and conditions of work for the working class or redress of their grievances. They are acts which are precisely intended to bring about a desired result, including the change or reform of government policies. decisions, and actuations. More importantly, these are acts which served the Filipino people well in the dark days of the martial law regime and won them their precious freedoms. How can these Constitutionally protected and guaranteed acts now be dragged and considered as crimes of terrorism if accompanied by intent and purpose which are vague, not clearly defined, bereft of standards, and susceptible to the self-serving and gratuitous interpretations of police and military enforcers? 21. When the Anti-Terrorism law included acts which are Constitutionally protected (viz., advocacy, protest, dissent, etc.), its definition of the crime of terrorism under its Section 4 fails to meet the Constitutional threshold of actus reus conduct of a crime. In The Anti- rrorism Act of 2020, the respondents Senate and House of Representatives enacted a statute allowing law enforcement agents or military personnel to second guess the intent and purpose of a suspected person, punishing criminal intent and purpose which if made to accompany the acts protected and guaranteed under Section 4, of Article IIT of the 1987 Constitution, transforms these acts into the crime of terrorism; 22. The explicit inclusion of these constitutionally protected acts under Section 4 renders the subsequent provisions of the law --Sections 5 to 12 which define new crimes; Section 16 which authorizes surveillance on suspected terrorists; Section 25 on the designation of terrorist individuals, groups or organization; Section 29 on warrantless arrests of suspected terrorists; and Section 34 on the restriction of the right to travel and the incommunicado house arrest for suspected terrorists-- discretionary on the part of law enforcement and thus subject to abuse; 23. Thus, the far-reaching consequences of the definition of terrorism in Section 4 invade into the domain of liberties and freedoms guaranteed under the present Constitution that to allow its operation would not only ultimately silence dissent but would open a Pandora’s box of all forms of human rights violations against the targeted dissenter, R.A, No. 11479 Being a Statute On Free Speech, Expression, and Assembly, It is Susceptible to A Facial Challenge; It is On Its Face Void for Vagueness 24. The rule established in our jurisdiction is, only statutes on freePETITIONPage 07, speech, religious freedom, and other fundamental rights may be facially challenged, to the exclusion of ordinary penal statutes. It is humbly and respectfully submitted to this Honorable Supreme Court that the subject matter of the instant petition is not merely an ordinary penal statute, but one that crosses into the Constitutionally protected areas of free speech, free expression, and free assembly, thereby making R.A. No. 11479 vulnerable and susceptible to a facial challenge: must be struck down as void for vagueness, specifically of its provisions in Section 4. In the 2015 United States case of Johnson v, United States!, the US Supreme Court citing its earlier rulings in Kolender? and Conally, ruled that the Fifth Amendment provides that “[n]o person shall ... be deprived of life. liberty. or property, without due process of law.” These cases establish that the Government violates this guarantee by taking away someone's life, liberty, or property under a criminal law so vague that it fails to give ordinary people fair notice of the conduct it punishes, or so standardless that it invites arbitrary enforcement. The prohibition of vagueness in criminal statutes “is a well-recognized requirement, consonant alike with ordinary notions of fair play and the settled rules of law,” and a statute that flouts “violates the first essential of due process.” The US Supreme Court has, thus, applied the vagueness doctrine to strike down penal laws for being vague as this constitutes a clear affront to the due process clause as enshrined in the Fifth Amendment. The same argument should uphold the invitation for this Honorable Supreme Court, in the exercise of its judicial review powers, to declare any penal law unconstitutional should it be infested with vague provisions that could translate into ordinary people being deprived of fair notice as to the conduct it punishes or for lack of clear and well-defined standards that it invites arbitrary enforcement; 26. The right and duty of the state to combat the scourge of terrorism must be recognized: but this can not be at the expense of our people's hard eared and hard fought Constitutional rights and freedoms. Our Constitution nis the basic and paramount law to which all other laws must conform and to which all persons, including the highest officials of the land, must defer. No act shall be valid, however nobly intentioned, if it conflicts with the Constitution. The Constitution must ever remain supreme. All must bow to the mandate of this law. Expediency must not be allowed to sap its strength nor greed for power debase its rectitude. Right or wrong, the Constitution must be upheld as long as it has not been changed by the sovereign people Vo. 13-7120, June 26, 2015 2 Kolender v. Lawson, 461 U.S. 252, 357-358 (1983) 3 conally vs. General Construction Company, 269 U.S. 385, 391 (1926)lest its disregard result in the usurpation of the majesty of the law by the Pretenders to illegitimate power.4 Given its extreme ‘atures which border on overkill, the Anti-Terrorism law may be likened to indiscriminately firing @ sub-machine gun at a crowd of innocent civilians in order to neutralize a few terrorists who are interspersed with them: 27. This Honorable Supreme Court stands as the guarantor of Constitutional and human rights of all persons within its jurisdiction and must see to it that the rights are respected and enforced. In the dark days of martial law in the '70s till the mid-'80s, the Supreme Court had, in many occasions in many cases, let our people down. Petitioner Sanlakas now runs to this Supreme Court as a court of last resort to protect it, its members, and the Filipino people from a law that will run roughshod over their rights and freedoms by declaring courageous acts of advocacy, protest, dissent, and mass actions by the Filipino people to be acts of terrorism. As the final bastion of our people's liberty and freedom, this Honorable Supreme Court now finds itself once again in the historic crossroads to restrain the heavy hands of government and protect the people's rights. RAYER PREMISES CONSIDERED, petitioner Sanlakas respectfully prays of this Honorable Supreme Court to give DUE COURSE to this petition, and after due notice and hearing, ISSUE the writ of certiorari and DECLARE and STRIKE DOWN Section 4 of RA. No_ 11479 or The Anti-Terrorism Actof 2020 as NULL and VOID for being in violation of Section 4, Article IH of the 1987 Constitution. and for being a vague provision violative of the due process rights guaranteed in the 1987 Constitution, thereby having been signed into law by respondent President Rodrigo R. Duterte with grave abuse of discretion amounting to lack or excess of jurisdiction IT IS FURTHER prayed that a writ of prohibition ISSUE command- ing respondent President Rodrigo R, Duterte to DESIST from enforcing or implementing Section 4 of RA No. 11479 or The Anti-Terrorism Act of 2020, and commanding respondents Senate and House of Representative to DESIST from allocating public funds by way of budgetary appropriation for the enforcement and implementation of the said statute IT IS FINALLY prayed that, after due notice and hearing, a Temporary Restraining Order (T.R.O.) be ISSUED enjoining respondent President Rodrigo R. Duterte from enforcing or implementing Section 4 of No_11479 or The Anti-Terrorism Act of 2020, and respondents Senateand House of Repre ae ative from allocating public funds by way of budsetary appropriation for the enforcement and implementation of the said statute. Pasig City for Manila, July 13, 2020. Pasig City 160: Roll of Atiomeys No. 33657 PTR No. CBN1350717 (12-26-2019) IBP Lifetime No. 01457 MCLE Exemption No. VI-000431 As Dean of Law Valid Until 04-14-22 AMANUEL horn ie ‘ourfsel for Petitioner Suite 906 The Richmonde Plaza el Ave. cor. Lourdes Ave. Ortigas Center, Pasig City 1605 Roll of Attorneys No. 36523 PTR No. 6523077 / 1-22-20 Pasig City IBP No. 111464 / 1-21-2020 Manila IV MCLE Compl. No. V1-0026380 (5-8-19) JOSE AARON PEDROSA, JR C Counsel fir Petitioner 23-B Marunong Street y Central Quezon City Attorney's Roll No. 61770 PTR No. 9270359 / 01-02-20 Quezon City IBP No, 094900 / 11-14-19 Pasig City MCLE Compl. No, V1-0029316VERIFICATION AND CERTIFICATION OF NON-PENDENCY OF SIMILAR SUIT I, MARIE MARGUERITE M. LOPEZ, of legal age, Filipino, with address at $9 Mariano Cuenco Street, Brgy. Sto. Domingo, Quezon City, afier being duly swom to law depose and say ~ (a) I am the representative duly authorized by petitioner to sign and file the above petition; (b) I have d and understood all the allegations in the petition; (¢) the nd correct based on my personal knowled; (d) the petition is not filed to harass, cause unnecessary delay, or needlessly increase the cost of litigation; and (¢) the factual allegations therein have evidentiary support or, if specifically so identified, will likewise have evidentiary support after a reasonable opportunity for discovery rea the petition are true on authentic document FURTHER, I hereby certify ~ (a) that I have not heretofore com- menced any action or filed any claim involving the same issues in any court, tribunal or quasi-judicial agency; (b) to the best of my knowledge, no such other action or claim is pending therein; and (c) if I should thereafter learn that the same or similar action or claim has been filed or is pending, I shall report that fact within five (5) calendar days therefrom to the court wherein such aforesaid complaint or initiatory pleading has been filed ature this IN WITNESS HEREOF, I have hereunto affixed my si ot of July 2020 at Quezon City, MARG'! SUBSCRIBED AND SWORN to before me ls | 3 2920 of July 2020, the affiant exhibiting to me her competent document of identity which is OSCA ID No. 03583-T. Notary Public ie Doe. No a 2 pynteeeribySiON No. 2020 Page No Oran PUP fo una) 12/31/2023 MANA Fe ps MALATE, MANIL Book No. 1 im 57 Tate ANF AND ne 3 1200 Series of 2020 Fast No. A janice / TIN 104063310 PTH Aba $1 a 0 WHeBnndaD VALE 2028 cae coPETITIONPage 11 Explanation Copies of the above pleading were served the respondents by means of LBC Courier Service instead of the preferred means of service by personal delivery by reason of the number of parties to be served and the limitations and restrictions on physical movement 0c sioned by the community quarantine. Polk I COPY SERVED BY LBC COURIER SERVICE: neGisTRY RECE! Emsa Posi President Rodrigo R. Duterte Letter/Phekage No Respondent tenrea by 13 JUL 200 20 Office of the President ear penne 5422, Malacajfiang Palace, Manila EAE an TE TE Wout Postmaster Teller Senate of the Philippines AEGISTAY RECEIPT, Preser RE 240 647 535 27 A Postmaster Teller House of Representatives Respondent Batasan Pambansa Building Batasan Hills, Diliman, Quezon C REGISTRY RECEIPT pout on anor Ptpkage Woe d | —1-tue-20z0 # we zig eur e722 i UL ANC 1 0 MME AE post onbe Registered hall FE = stinquiry inquiry1, FEDERICO PUNZAL, of legal age, married and a resident of Quezon City, after having been duly sworn to law hereby depose and say that: 1. On 13 July 2020, I caused the service of a copy of the Petition dated dated July 13, 2020 in Sanlakas v, Rodrigo Duterte, et al. to: President Rodrigo R. Duterte Office of the President Malacanang Palace, Manila ee Senate of the Philippines GSIS Building, Pasay City House of Representatives Batasan Pambansa Building Batasan Hills, Diliman Quezon City fit by means orkid 2. Ihave executed this affidavit to attest to the truth and ver: foregoing statements. ye services. 43 ww NESS WHEREOF, I have hereunto affixed my signature this JUL day of July 2020 at __crry OF MANILA _— F ERICO PUNZAL : JUL 13 2029 SUBSCRIREDANPMAYQBN 10 before me this es it 2020 by the afliant who pre Ut Bt Notary Publi ra foo un 1/34 R0R AMR ae inst avy, wAATE MAMKA 9IE Dave N Ae uieyn ke 70/5200 Doe. No22S Page NoLF re i OST MAMA fT LAOS Book NoS1 Series of 2020 eee earn a BARRE y of July unit 237EPUBLIC OF THE PHILIPPINES) City of Manila )Ss. addre: =CRETARY’S CERTIFICATE JOSE AARON PEDROSA, JR., of legal age, Filipino, and with office at 23-B Marunong Street, Barangay Central, Quezon City 1100, after being duly sworn in accordance with law, depose and state that: 1 authorized to bring, file, initiate, and i 1am the duly elected Secretary-General (Secretary-equivalent) of NLAKAS, an organization duly organized and existing under and by virtue of the laws of the Republic of the Philippines, with office address at 23-B Marunong Street, Barangay Central, Quezon City 1100; Tam the custodian of records of Sanlakas, including the Minutes and Resolutions of its National Council (Board of Trustees-equivalent): and At the special meeting through videoconferencing of the National Couneil of Sanlakas held on 8 July 2020, during which a quorum was present and acted throughout, the following resolution was unanimously adopted: Resolution RESOLVED, that MARIE MARGUERITE M. LOPEZ is hereby stitute a Petition for Certiorari and Prohibition against President Rodrigo Duterte, the Senate of the Philippines and the House of Representativ Act 11479 or the Anti assailing the constitutionality of Republic rrorism Act of 2020 with Prayer for Issuance of Temporary Restraining Order, and other available and appropriate remedies, before the Supreme Court, with full and special power and authority to: a. : and authorize the preparation and filing of all pleadings, motions, memoranda, affidavits, and such other papers or documents as may be needed in the course of the proceedings: b. Sign and execute all verifications and certifications of non- forum shopping and other procedural requirements for pleadings filed on behalf of Sanlakas; c. Appear for and in behalf of Sanlakas in all mediation sdings and judicial dispute resolution hearings or similar d. Enter into ami able settlements or compromis & Submit to alternative modes of dispute resolution; f Enter into stipulations or admissions of facts and of documents; 2 Exercise acts enumerated under Section 2, Rule 18 of the Revised Rules of Court; h. Appoint and secure the services of legal counsel or attorney-at- law to represent Sanlakas in the above-mentioned actions; andi. Do and perform all and every act and thing whatsoever requisite and necessary to be done in and about the premises. HEREBY GIVING AND GRANTING unto the said person full power and authority to do and perform all and every act and thing whatsoever requisite and necessary to be done in and about the premises and hereby ratifying and conforming all that the said person has done or ¢ to do and shall lawfully do or cause to be done by virtue of this authority RESOLY FINALLY, that the legal services of J.V. BAUTISTA, IMANUEL R. JABLA AND JC AARON M. PEDROSA, JR. are hereby engaged for the above-mentioned actions. 4. The said Resolution is still in force and has not been amended and revoked; 5. Lam executing this Certificate for whatever legitimate purpose it may serve. IN WITNESS WHEREOF, I have hereunto affixed my signature on 13 July 2020 at Manila, Philippine: JOSE AAI EDROSA, JR. Affitnt SUBSCRIBED AND SWORN to before me, a Notary Public for Manila on 13 July 2020 at Manila, Philippines, by affiant, who personally appeared before me and exhibited his competent evidence of identity: Passport No. which will expire on 31 May 2021. A rant s oc. No, ¢Z “ 0 Doe. Nos OLA; aeny ros mS NS Page No. 5 yous nou) MALATE, MANIA Book No.: G ‘wait 237 THK ve Ne 2022/15-12:00 oe wntaeiaana wcee coms Series of 2020. Sn 0003 ania 188 wiserVERIFIED DECLARATION |, JV. BAUTISTA, hereby declare that the PETITION hereto submitted contained in a USB flash drive in PDF format in accordance with A.M. Nos, 10-3-7-SC and 11-9-4-SC is a complete and true copy of the document filed with the Supreme Court. JuL 13 2320 SUBSCRIBED AND SWORN TO before me on this __ day of July 2020 by the affiant who presented to me her IBP Roll No. 33657. Notary Public 4 WEL E PAMER = desea ot ©1y2-4 7028 Une 12/31/2071 MANILA Book No. “Uma 237 Tram KiAgT Av! LATE, MANILA Series of 2020 ‘poll to. 44089 *18Pitenme Ma, 2022/15-12-00 perma 4120231/91-92-2020 AAANILA f THB 10653810 Teccs COMMLANGE Ne, VIABLAIZ YO AE U2