Memorandum

People of the Philippines v. Pedro C. Lim et. al.

Page 1 of 21
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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH 24
CITY OF MANILA

PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus- CRIM CASE NO.

TG2395-94 TG-23595-94-A
& TG-2396-94

PEDRO C. LIM, ET. AL,

Accused.
xx

MEMORANDUM FOR THE PROSECUTION

The People, by the undersigned prosecutors, and unto this

Honorable Court, respectfully submits this Memorandum as follows:

PREFATORY STATEMENT

In the evening of November 14, 1994, Atty. Eugene Tan, former

President of the Integrated Bar of the Philippines and his driver
Eduardo Constantino were abducted by the accused, acting in
conspiracy with one another. The victims were forcibly abducted in
Alabang, Muntinlupa and were brought to Cavite where they were
shot to death and found in a shallow grave. The accused were then
charged for kidnapping and two counts of murder. The prosecution
humbly states and takes the position that it has presented competent
witnesses, clear, convincing and sufficient evidence to prove beyond
reasonable doubt that accused are guilty of committing the crime
charged and that the accused miserably failed to present any evidence
that could even raise an iota of doubt as to their guilt of the offenses
charged. The Supreme Court has once said that violent death or
brutal killing not only steals from the family of the deceased his
precious life, deprives them forever of his love, affection and support,
but often leaves them with the knowing feeling that an injustice has
been done to them (People vs. Caraig, 400 SCRA 67).
 Memorandum
People of the Philippines v. Pedro C. Lim et. al.
Page 2 of 21
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I. STATEMENT OF FACTS

During the course of the trial, the Prosecution, through its

witnesses were able to establish the following facts:
1. On December 13, 1994 the Department of Justice issued a
resolution in the Preliminary investigation of the case docketed as IS
No. 94-557 finding probable cause against Pedro Lim, Bonifacio
Roxas, Rodolfo Ochoa, Reynaldo de los Santos, Venerando Ozores,
Toto Mirasol, Mariano Hizon, Eugenio Hizon, Capt. Alfred Abad and
Eugene Yu were charged with an information on November 14, 1994.
The said information read:
With intent to kill, qualified by
treachery, evident premeditation, taking
advantage of superior strength, with the
aid of armed men or by a band, or by
employing means or persons to ensure
or afford impunity and with the use of a
motor vehicle, consideration of price,
reward or promise, conspiring,
confederating and mutually helping one
another, did then there willfully,
unlawfully and feloniously abduct the
(two victims herein), and thereafter,
attack, assault and use violence upon the
persons by shooting with a firearm
thereby causing instantaneous death.

2. Subsequently, an amended Information was filed against

the same accused before this Honorable Court on December 16 and
17, 1994. While under the custody of the Presidential Anti-Crime
Commission (PACC) the accused Ochoa and De los Santos agreed to
become state witnesses and thereafter executed separate sworn
statements implicating Eugene Yu and the other accused as to the
latters participation in the crime. During the Preliminary
Investigation accused Reynaldo de los Santos and Rodolfo Ochoa
were discharged as state witnesses.
The discharge of Delos Santos and Ochoa were questioned
before the Court of Appeals and the Supreme Court by the other
accused. The Court of Appeals and the Supreme Court, however,
upheld the decision of the Department of Justice to discharge De los
Santos and Ochoa as state witnesses.
The gist of the testimonies of witnesses De los Santos and
Ochoa are as follows:
Accused Pedro Lim was the one who brought funds for the
operation. That he also provided the team led by accused Roxas with
the Nissan Datsun car sometime in September and November 1994 in
 Memorandum
People of the Philippines v. Pedro C. Lim et. al.
Page 3 of 21
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the surveillance operation made by the team against the alleged

financier ng pula who turned out to be the victim Atty. Eugene Tan.
That sometime in the first week of November 1994 they saw and
overheard accused Pedro Lim talking to Capt. Abad and Roxas about
their plan to finish the surveillance operation and get the financier
ng pula as soon as possible and that the same Datsun Car was used
by the same team in the abduction and the killing of the victims.
Sgt. Edgar Butch Abalon, an intelligence operative for the
Philippine Air Force, assigned to the 520th Air Base Wing, Office of
the Directorate for Intelligence ODI who was not included in the
information testified on the following matter. That he came to know
Peter Lim and Eugene Yu when he and his companions from the ODI
responded to a comrades distress call at the Sanctuario de San Jose
Church at Greenhills, San Juan, Metro Manila. The call was about a
conflict between siblings Atty. Gilda Lim and Pedro and Patricia Lim
on the other hand. Sgt. Abalon was told by his companions that some
of them were providing security services to Patricia Lim upon orders
of Capt. Abad.

After that incident in Sanctuario de San Jose church, Sgt.

Abalon was invited by the accused Peter Lim to meet with him and his
sister Patricia. He was told that his sister, Atty. Gilda Lim, was being
manipulated by a certain Atty. Eugene Tan in taking away all the
properties belonging to their family. On another occasion, Pedro Lim
asked Sgt. Abalon to be his security detail but Sgt. Abalon refused
because he has not received any order from his security officer.
On the witness stand he testified and confirmed his statement
executed before the PACC. He testified on the surveillance they
conducted as instructed by their superior officers. He also testified
that his superiors told him that the subject of the surveillance has a
standing warrant of arrest. That it took them many days to conduct
the surveillance that at one point he disguised himself as a repairman
of PLDT to gain access at the office of the financier ng pula. That he
was likewise ordered by the superior officers to immediately make the
necessary arrest of the financier ng pula upon coordination with
Bonifacio Roxas who was designated the leader as he was the one who
has knowledge of the financer ng pula.
Sgt. Abalon, as with Ochoa and De los Santos testified that in
the evening prior to November 14, 1994, they were instructed by
Captain Abad to effect the arrest of the Financier ng Pula. As per Sgt.
Abalons testimony, he said that in the early afternoon of the same
date, he and accused Roxas were instructed by Capt. Abad to effect
immediately the arrest of the financer ng pula because the latter was
already pestering Pedro Lim and the other members of his family.
That as per information of witness De los Santos and accused Roxas,
the subject was at his office at the Tan Manzano & Velez law office in
Makati City.
 Memorandum
People of the Philippines v. Pedro C. Lim et. al.
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When the group of Sgt. Abalon and Roxas were able to confirm
the victims presence at the said office because of the parked
Mercedes Benz at its reserved space which they earlier identified as
belonging to the financier ng pula, they prepared to execute the plan.

Being too early in the place they decided to watch a movie The
Shadow at the Makati Cinema Square, to while away the time. After
watching the movie, they all returned to their previous stations near
the office of their subject between 5:30 pm and 6:30 pm.
After failing at first to follow the victims vehicle when it left its
reserved parking space as they lost it in traffic, the group was able to
locate the car with the driver and its passengers in Bel-Air Village,
Makati City. They continued the stake-out and when the Mercedes
Benz car leave the said location with the two (2) victims on board,
they followed it using two vehicles. He (Abalon) was on board an
owner type jeepney driven by accused Ochoa and the other members
of the group were in a Datsun car driven by accused Roxas who is the
designated leader of the group.
Before reaching the Nichols exit, accused Roxas radioed Sgt.
Abalon who was on board the owner type jeep and told the latter that
they will carry out and start their operation after the Alabang Access
road exit which consist of their previous plan to abduct their subject
as hatched by accused Roxas, through a method where the Datsun car
being driven by accused Roxas will overtake the car.
To stop the Mercedes Benz, Roxas will bump the rear portion of
the car, which method was carried out by the group. When they and
their subject all passed by the Alabang Toll exit gate, they
immediately executed the plan. Roxas blocked the path of the car and
Mirasol bumped the Mercedes Benz and as soon as the victims
vehicle stopped on account of the operation and plan employed by the
group of the accused, Ochoa and Bonifacio Roxas immediately
alighted from their respective vehicles and pretended to examine the
damage caused by their vehicle to the Mercedes Benz. When the
driver of the Mercedes Benz carrying the victims opened the door,
Ozores, Mirasol and Delos Santos and the other members of the same
group went out of their respective vehicles and at that instance
accused Roxas and Mirasol grabbed, Eduardo Constantino, the driver
of the Mercedes Benz, and placed him inside the Datsun car.
Accused Ozores then went to the drivers seat of the same
Mercedes Benz car and boarded it. During the abduction of the
victims Sgt. Abalon remained inside the owner-jeep and watched his
companions abduct the two (2) victims. After getting the two victims,
they traveled along the Alabang-Zapote road towards the direction of
Cavite on board the Datsun car driven by Accused Roxas, with their
subjects driver and accused Mirasol as passengers, followed by the
Mercedes Benz car driven by accused Ochoa and carrying victim Tan
and accused De los Santos as passengers and the owner type jeep
driven by Sgt. Abalon.
 Memorandum
People of the Philippines v. Pedro C. Lim et. al.
Page 5 of 21
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When the subject reached a place fronting the Alabang Twin

cinema, accused Roxas ordered Sgt. Abalon over the radio to transfer
to the Mercedes Benz car in order that he could help accused Ochoa
in turning off the cars hazard light, which Sgt. Abalon did. When Sgt.
Abalon was inside the Mercedes Benz of the victim he radioed and ask
Roxas that they immediately proceed to their office at the Villamor
Air Base for the tactical interrogation of the victims but accused
Roxas insisted in bringing their subject to a safe house first. Roxas
informed Sgt. Abalon in the process that the safe house was already
cleared with Capt. Abad. Sgt. Abalon just kept silent and did not
insist. After a while, the victim, Tan inquired from Sgt. Abalon why
he was being arrested. The former informed him that a warrant for
his arrest was being executed by the group, he being Wilfredo De Los
Santos. To this, victim Eugene Tan responded that he is not Wilfredo
de los Santos. That victim Tan also told him that if it is money they
want, he could also give it. Sgt. Abalon just kept his silence.
When the group of Sgt. Abalon together with the two victims
reached a place in Dasmarias, Cavite, accused Roxas stopped the
datum car that he was driving, alighted from the car and proceeded
towards the Mercedes Benz car which similarly stopped. Accused
Roxas then forcibly dragged the victim Atty. Eugene Tan out of the
Mercedes Benz and told him Putang Ina mo, alam mo bang malaki
ang atraso mo kay Peter Lim?, halika nga dito. and placed the victim
Atty. Tan inside the Datsun car. Thereafter, the group of Sgt. Abalon
and accused Roxas drove away from the place using the same vehicle
but along the way, Sgt. Abalon attempted to convince accused Roxas
that they should bring the victims to the office of Capt. Abad for
tactical interrogation by flagging down the Datsun car being driven by
accused Roxas and when the Datsun car stopped and Bonifacio Roxas
rolled down its window glass, Sgt. Abalon saw at the back seat of the
same car, that Atty. Tan was already lying limped together with his
driver Eduardo Constantino.
Ochoa and De los Santos on the other hand testified that it was
Roxas who shot the victims in the head. This was in the first affidavit
of Roxas. Sgt. Abalon was instructed by Roxas to bring the car of the
victim to a place in Cavite. Before that incident he was able to see the
place where the bodies of the victims were brought and buried by
Roxas and company. He remembered it as a place in Silang Cavite.
Then the group went to see Capt. Abad in his house. After
informing Capt. Abad of what has happened, the former (Capt. Abad)
called up Pedro Lim on the phone saying Hello.Peter pleasePeter
LimSi Nonoy (nickname of Capt. Abad) O tapos na and place
down the receiver in the presence of Sgt. Abalon, Ochoa and Ozores.

II. STATEMENT OF THE CASE

In Criminal Cases Nos. TG-2395-94, TG-23595-94-A accused

Pedro Lim, Venerando Ozores, Bonifacio Roxas, Luisito Mirasol and
 Memorandum
People of the Philippines v. Pedro C. Lim et. al.
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Capt. Alfred Abad (currently at large) are charged for the murder of
the victims Atty. Eugene Tan and his driver Eduardo Constantino,
while Eugene Yu was cited as an Accomplice and the Hizons as
Accessories to Murder.
In TG-2396-94 the accused Pedro Lim, Venerando Ozores,
Bonifacio Roxas, Luisito Mirasol and Capt. Alfred Abad (currently at
large) are charged for the kidnapping of the victims Atty. Eugene Tan
and his driver Eduardo Constantino, while Eugene Yu was cited as an
accomplice.
Murder is punishable under Article 248 of the Revised Penal
Code which provides:
Art. 248. Murder. Any person who, not
falling within the provisions of Article 246
shall kill another, shall be guilty of murder
and shall be punished by reclusion temporal
in its maximum period to death, if committed
with any of the following attendant
circumstances:
1. With treachery, taking advantage of
superior strength, with the aid of armed men,
or employing means to weaken the defense or
of means or persons to insure or afford
impunity.
2. In consideration of a price, reward, or
promise.
3. By means of inundation, fire, poison,
explosion, shipwreck, stranding of a vessel,
derailment or assault upon a street car or
locomotive, fall of an airship, by means of
motor vehicles, or with the use of any other
means involving great waste and ruin.
4. On occasion of any of the calamities
enumerated in the preceding paragraph, or of
an earthquake, eruption of a volcano,
destructive cyclone, epidemic or other public
calamity.
5. With evident premeditation.
6. With cruelty, by deliberately and inhumanly
augmenting the suffering of the victim, or
outraging or scoffing at his person or corpse.

Kidnapping is punishable under Article 267 the Revised Penal Code

as:
 Memorandum
People of the Philippines v. Pedro C. Lim et. al.
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Art. 267. Kidnapping and serious

illegal detention. Any private individual
who shall kidnap or detain another, or in any
other manner deprive him of his liberty, shall
suffer the penalty of reclusion perpetua to
death:
1. If the kidnapping or detention shall have
lasted more than five days.
2. If it shall have been committed simulating
public authority.
3. If any serious physical injuries shall have
been inflicted upon the person kidnapped or
detained; or if threats to kill him shall have
been made.
4. If the person kidnapped or detained shall be
a minor, female or a public officer.
The penalty shall be death where the
kidnapping or detention was committed for
the purpose of extorting ransom from the
victim or any other person, even if none of the
circumstances above-mentioned were present
in the commission of the offense.

It has been proven that the elements of the crime of murder are
present in this case. All the principal accused, in conspiracy with one
another, with intent to kill, qualified by treachery, evident
premeditation, taking advantage of superior strength, with the aid of
armed men or by a band, or by employing means or persons to ensure
or afford impunity and with the use of a motor vehicle, consideration
of price, reward or promise, conspiring, confederating and mutually
helping one another, did then there willfully, unlawfully and
feloniously abduct the (two victims herein), and thereafter shot the
two victims which resulted in their death.
It has also been proven that the crime of kidnapping also took
place since the accused in conspiracy with one another forcibly
abducted Atty. Eugene Tan and Eduardo Constantino with the use of
a motor vehicle and fire arms and deprived them of their liberty for
an unspecified length of time and against their will.
Facts and circumstances indubitably show that the accused
Pedro Lim, Eugene Yu, Venerando Ozores, Bonifacio Rojas and
Luisito Mirasol acted in conspiracy with one another and are GUILTY
BEYOND REASONABLE DOUBT of the crime of MURDER, as
penalized under Article 248 of the Revised Penal Code, and
KIDNAPPING as penalized under Article 267 of the Revised Penal
Code. All the elements of the said offense enumerated and described
 Memorandum
People of the Philippines v. Pedro C. Lim et. al.
Page 8 of 21
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above are present, and have been proven and supported by both
testimonial and documentary evidence duly admitted by this
Honorable Court, during trial, as follows:
Abstracts of the testimonies of the prosecution witnesses.
As and by way of testimonial evidence, the prosecution presented five
(5) witness, as testified by:
1. Sgt. Edgar Allan C. Abalon that he, Sgt. Abalon is a
member of the Philippine Air Force under the Intelligence
520th ABW. To quote the witness, he was present when Patricia Lim
then accompanied by Eugene Yu and Peter Lim had an ongoing
argument with Gilda Lim. Patricia Lim was supposed to be physically
hauled to be subjected to psychiatric examination. Eugene Yu, who
was then the fianc of Patricia Lim, thwarted the attempt of Gilda Lim
with the help and timely arrival of some law enforcement agents. Sgt.
Abalon further testified that he met Pedro Lim six more times at their
office at the Villamor Air Base during which Pedro Lim always met
with Capt. Abad. Sgt. Abalon was allowed to testify as a State Witness
under the Witness Protection program of the government, thus he
further stated:

Sometime in October 1994, Capt. Abad ordered Sgt. Abalon

together with the other accused and state witnesses to conduct a
surveillance operation on one Wilfredo de los Santos, a financier
ng mga pula (NPA)- Alex Boncayao Brigade who in reality is one of
the victim Atty. Eugene Tan, who is demanding revolutionary tax on
Pedro Lim. He was also told that Bonifacio Roxas, one of the accused,
can point to him this Wilfredo de los Santos thus he was to
coordinate with Bonifacio Roxas. Bonifacio Roxas then was one of
their civilian assets and a protg of Capt. Abad. He, Roxas was
likewise assigned as a security man to Pedro Lim by Capt. Abad.
Sometime in the first week of November 1994, Capt. Abad,
Roxas and Pedro Lim were visibly impatient that they wanted
Wilfredo de los Santos picked up because there was already a
warrant for his arrest and Pedro Lim was being pressured to pay the
revolutionary tax. Pedro Lim told Sgt. Abalon Kailangan makuha na
Butch dahil tinatakot na ako.
On November 7, 1994 Sgt. Abalon, Bonifacio Roxas, Rudy
Ochoa, Venerando Ozores, Reynaldo de los Santos and Toto Mirasol
were close to getting Wilfredo de los Santos who they were trailing
while the latter was aboard his Nissan Patrol Car. Except for Toto
Mirasol who was Roxas man, Ochoa, Ozores and De los Santos were
all Capt. Abads civilian agents. Capt. Abads instruction was to take
Wilfredo de los Santos to his office for tactical interrogation.
On November 14, 1994, the alleged operatives got Wilfredo de
los Santos. After trailing Wilfredo de los Santos for sometime
starting from Makati with Roxas driving a Datsun Car along with
Reynaldo de los Santos and Toto Mirasol, blocked the path of
Wilfredo de los Santos Mercedes Benz car, 150 meters after the
 Memorandum
People of the Philippines v. Pedro C. Lim et. al.
Page 9 of 21
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Alabang Toll booth causing the car of the victim to stop and the owner
type jeep driven by Rudy Ochoa bumped the rear of the Mercedes
Benz.
Sgt. Abalon was riding the owner type jeep driven by Rudy
Ochoa and Venerando Ozores. Bonifacio Roxas then jumped out of
the Datsun car and strangled the victims driver, Eduardo
Constantino, for him to obey their instructions. Thereafter he was
put inside the Datsun car with Mirasols help. Venerando Ozores then
drove the Mercedes Benz while he and Reynaldo de los Santos sat
with the victim Atty. Eugene Tan at the back seat. Sgt. Abalon then
called Roxas to now proceed to the office of challenger, Capt. Abads
call sign, but Bonifacio Roxas, with the agreement of the others, said
they were taking the victims to the safe house.
Along the way Sgt. Abalon had a conversation with Wilfredo de
los Santos who inquired why he was being arrested. It was then that
Wilfredo de los Santos told Sgt. Abalon that they got the wrong guy
and that he was not Wilfredo de los Santos but Atty. Eugene Tan.
Sgt. Abalon remonstrated over the blunder but he later realized that
everyone in the team except he, knew the real identity of Wilfredo de
los Santos to be Atty. Eugene Tan and that they were not taking the
victims to Capt. Abads office but somewhere else. Sgt. Abalon was
helpless because everyone else in the team was armed except him.
Upon reaching Dasmarias, Cavite, Bonifacio Roxas alighted
from the Datsun car and forcibly dragged Atty. Eugene Tan out of the
car and said to the victim Putang ina mo, alam mo malaki atraso mo
kay Peter Lim? Halika nga dito! then forcibly loaded him aboard the
Datsun car and drove further. At this point Reynaldo Engine De Los
Santos transferred to the Datsun Car. Somewhere along the way he,
again tried to convince Bonifacio Roxas to bring Atty. Eugene Tan to
Capt. Abads office for tactical interrogation. That he flagged down
the Datsun car of Bonifacio Roxas who stopped, then rolled down the
window. Sgt. Abalon then saw the dead bodies of Atty. Eugene Tan
and his driver Constantino lying limp and bathed in blood. Bonifacio
Roxas then proceeded to the place of Eugenio Hizon in Silang, Cavite
to bury the bodies. Sgt. Abalon and Ozores followed and when they
reached the house the wife of Eugenio Hizon told them, Bonifacio
Roxas and his two companions left and said Dinala na nila,
implying that she knew that Bonifacio Roxas and company were going
to bury the bodies.
Sgt. Abalon and the other team members, except for Reynaldo
de los Santos, all went to see Capt. Abad at the house of Col. Abelardo
Abad. Sgt. Abalon immediately protested and told Capt. Abad Sir
bakit ganoon nangyari? Ginago nyo ako eh! But Capt. Abad told him
to keep quiet, not to pose a security risk and that he will be
compensated for the job.
Then Capt. Abad called someone in front of him Ochoa, and
Ozores. Capt. Abad called Pedro Lim by phone and the witness
 Memorandum
People of the Philippines v. Pedro C. Lim et. al.
Page 10 of 21
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overheard Capt. Abad say HelloPeter please Peter Lim Si

NonoyO, tapos na then hung the receiver.
3. For witness Reynaldo O. De los Santos alias
ENGINE A civilian agent of the 520 Airbase W-2 of the
Philippine Air Force which is headed by Major Gammad with accused
Capt. Alfred as second in command. As a civilian agent he gathered
intelligence outside the camp while personally doing his daily chore.
Together with other civilian agents he is brought along by the organic
personnel in intelligence operations like surveillance and arresting
wanted persons. Reynaldo De los Santos was granted immunity in
exchange for testifying as a state witness.

Reynaldo De los Santos testified that accused Bonifacio Roxas

was his fellow agent in the same unit who is very close to Capt. Abad.
All of Bonifacio Roxas request for security detail are issued a
corresponding Mission Order by their unit and signed by Capt. Abad.
Bonifacio Roxas was assigned by Capt. Abad as security of Eugene Yu,
Patricia Lim-Yu and accused Peter Lim. Bonifacio Roxas has his own
team of civilian agents who are accredited by Capt. Abad.
Reynaldo De los Santos first met Eugene Yu during the latters
wedding with Patricia Lim sometime in August or September 1994.
He was then one of those detailed by Capt. Abad to secure the
occasion because of some threat to disrupt the ceremony. During the
wedding he came to know accused Peter Lim.
Days after the wedding there were three occasions when
Reynaldo De los Santos was able to catch Eugene Yu having a
conference with Capt. Abad at the latters office. Reynaldo De los
Santos met Eugene Yu again on the day Capt. Abads father was
buried where Eugene Yu asked him if he was the security detail
assigned to them and he said no. Moments later Bonifacio Roxas
arrived and escorted Eugene Yu. Reynaldo De los Santos second
encounter with Eugene Yu was when he joined the surveillance team
sometime on the second week of October 1994 wherein Atty. Eugene
Tan was described as financier ng pula or an NPA financier.
Bonifacio Roxas was the team leader of the operation. The operation
also involved the participation of Sgt. Abalon, Rodolfo Ochoa,
Venerando Ozores, Toto Mirasol, Emong Samonte, Danilo Bonifacio,
William Domsao and a certain Abet Tangkad.
Reynaldo De los Santos alleges that the surveillance operation
of the NPA financier started in a closed door meeting among Capt.
Abad, Ozores and Roxas inside the office of Maj. Gammad. They were
later instructed to tail a light brown Nissan Patrol, a creamy Mercedes
Benz, and a blue Toyota Corolla. And they did so for a month. Two
weeks prior to November 14, 1994, Reynaldo De los Santos
accompanied Bonifacio Roxas in looking for a telephone as he wanted
to talk to Peter Lim and when Bonifacio Roxas called Peter Lim the
latter was apparently giving instructions. After the telephone
conversation their group went to Villamor Air base to talk to Capt.
 Memorandum
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Page 11 of 21
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Abad. Thereafter, Bonifacio Roxas brought Reynaldo De los Santos to

the house of Eugene Yu at Taft Avenue near De la Salle University to
see Yu where the latter handed to Bonifacio Roxas an envelope,
money and a piece of paper and they left. Bonifacio Roxas gave the
money to the two civilian agents assigned at Eugene Yus house and
also gave Reynaldo De los Santos and Ochoa for them to spend.
Bonifacio Roxas also showed a piece of paper which reads Tan
Manzano Law OfficePacific Bank Bldg. Ayala, Makati. Bonifacio
Roxas said that this is the place they will be closely working on since
the NPA financier was working there.
After that they reported back to the Villamor Air base, went
inside the office of Capt. Abad and Bonifacio Roxas handed the
envelope containing money. Capt. Abad took some cash from the
envelope and handed them to Bonifacio Roxas. Bonifacio Roxas gave
some money to Reynaldo De los Santos and Ochoa and said it was
their bonus.
Reynaldo De los Santos then testified that on November 14,
1994, they railed the NPA financier who was aboard a cream
Mercedes Benz from Makati all the way to Alabang. Reynaldo De los
Santos, Mirasol and Roxas were aboard the Datsun car while Ochoa
and Sgt. Abalon were aboard an owner type jeep. After passing the
Alabang exit they blocked the Mercedes Benz and Bonifacio Roxas
and handcuff the NPA financier. The driver Constantino was ordered
Reynaldo De los Santos to transfer to the Mercedes Benz transferred
to the Datsun. Ozores drove the Mercedes Benz and Sgt. Abalon sat
beside the NPA financier. The NPA financier asked them: Kanino ba
kayo nagtratrabaho? nobody answered. Kay Eugene Yu ba? and
introduced himself as Atty. Eugene Tan the former IBP President.
Kung magkano ang binayad sa inyo ni Eugene dodoblehin ko kung
magkaka-ayos tayo, hindi naman tayo magkakilala at wala naman ako
gagawin para mapahamak kayo Atty. Tan said. It was then that
Reynaldo De los Santos suspected that Atty. Eugene Tan was not the
NPA financier who was the subject of the surveillance.
When they reached Cavite, Bonifacio Roxas transferred Atty.
Tan to the Datsun. Ozores told Reynaldo De los Santos to join
Bonifacio Roxas at the Datsun. Somewhere in Silang, Cavite, Roxas
told him to drive the Datsun and drive towards Silang, Cavite. Along
the way, Bonifacio Roxas shot Atty. Eugene Tan and Constantino.
When Reynaldo De los Santos asked Bonifacio Roxas why he shot the
two when the instruction was only to arrest, Roxas answered
Directive ng opisina. After disposing of the bodies they returned to
Villamor Air base and reported to Capt. Abad.
On November 15, 1994 De los Santos met Roxas at the office
and asked him kung bakit tinira? and Roxas answered may
nagpatrabaho eh. Sino ba nagpatrabaho sa atin noong kahapon?
De los Santos persisted. Roxas answered Kilala mo, si Eugene Yu
pero si Peter and nakipag-usap kay Kapitan.
 Memorandum
People of the Philippines v. Pedro C. Lim et. al.
Page 12 of 21
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On November 22, 1994 at about six in the morning Reynaldo De

los Santos received a pager message stating Proceed to
Villamor/Wing 2 Office ASAPScorpio. Scorpio was Ozores code
name, Reynaldo De los Santos rushed to the office but did not see
Ozores so he proceeded to the house of Capt. Abad where he thought
he would see them and there he found Ozores, Ochoa and Emong
Samonte. It was there he learned that Roxas was arrested and that
they were all being hunted for the killing of Atty. Eugene Tan and
Constantino. Capt. Abad then ordered them to surrender all the
documents, firearms, MO/MR he issued to them. They stayed in the
house of Capt. Abad the whole day and were prevented from going
out of the house by Col. Abelardo Abad, who is Capt. Abads brother.
Reynaldo De los Santos does not know if money changed hands
but he does recall that a day or two after the operation inside the
house of Capt. Abad that he was talking to someone over the phone
and told him, Ozores and Ochoa that it was Maj. Gammad who he
talked to and Maj. Gammad was asking for a bonus for the successful
operation.
4. For witness Rodolfo M. Ochoa alias Rody who is also
a civilian agent or operative of the 520 Airbase W-2. Rodolfo Ochao
turned state witness gave his testimony before the Honorable Court
and was subjected to cross-examination.

Ochoa testified that he came to know of Peter Lim during the

wedding of Eugene Yu and Patricia Lim at a church in Greenhills
sometime in July 1994. He also came to know of Eugene Yu when the
latter attended a family planning seminar prior to his marriage.
Armed men were reportedly posting themselves near the site of the
seminar. So Capt. Abad immediately dispatched his operatives to
provide security.
The Last Mission Rodolfo Ochoa performed was surveillance on
an alleged financier ng pula who he does not know the identity since
it is their SOP that only the team leader, in this case Bonifacio Roxas,
who knows the identity of the subject. Rodolfo Ochoa knows that the
surveillance operation had something to do with Eugene Yu because a
day or two before the operation Eugene Yu came to the office of Capt.
Abad. They then went to the office of Maj. Gammad and told Rodolfo
Ochoa to fix them coffee. When he went inside the room he heard
Eugene Yu tell Capt. Abad. Dapat magconcentrate na iyong mga bata
sa trabaho para matapos na.
About half a week prior to November 14, 1994, Bonifacio Roxas
brought Rodolfo Ochoa to the house of Eugene Yu at Taft Avenue
near De la Salle University to see Eugene Yu where the latter handed
Bonifacio Roxas an envelope, money and a piece of paper and they
left. Bonifacio Roxas gave the money to the two civilian agents
assigned at Eugene Yus house and also gave money to Rodolfo
Ochoa to spend. Bonifacio Roxas also showed a piece of paper which
reads Tan Manzano Law OfficePacific Bank Bldg. Ayala, Makati.
 Memorandum
People of the Philippines v. Pedro C. Lim et. al.
Page 13 of 21
x-----------------------------------x

Bonifacio Roxas said that this is the place they will be closely working
on since the NPA financier was working there.
A day or two after Eugene Yus meeting with Capt. Abad, the
latter ordered all operatives involved in the operation of the
Financier ng Pula to concentrate on this operation. Thereafter
Rodolfo Ochoa told Capt. Abad Siguro sir malaking huli ang gagawin
tungkol sa Financier ng Pula kaya kailangan madaliin. Capt. Abad
replied Kailangan mahuli agad ninyo iyon subject sapagkat
nangingikil iyan ng mga pamilya ng instsik tulad ni Eugene. Sinong
Eugene? Rodolfo Ochoa asked again. Si Eugene Yu, kilala mo siya di
ba? Capt. Abad retorted.
On November 14, 1994, they railed the NPA financier who was
aboard a dirty white Mercedes Benz from Makati all the way to
Alabang. Rodolfo Ochoa was driving his owner type jeep with Sgt.
Abalon and Ozores as passengers. When they reached Cavite,
Bonifacio Roxas transferred Atty. Tan to the Datsun. Ozores told
Reynaldo De los Santos to join Bonifacio Roxas at the Datsun.
Somewhere in Silang, Cavite, Roxas told him to drive the Datsun and
drive towards Silang, Cavite. Along the way, Bonifacio Roxas shot
Atty. Eugene Tan and Constantino. After disposing of the bodies they
returned to Villamor Air base and reported to Capt. Abad. He then
heard Sgt. Abalon and Capt. Abad arguing. Capt. Abad just told them
to keep quiet and not pose a security risk.
On November 22, 1994, Rodolfo Ochoa proceeded to the house
of Capt. Abad where he thought he would see them and there he
found Ozores, Ochoa and Emong Samonte. It was there he learned
that Roxas was arrested and that they were all being hunted for the
killing of Atty. Eugene Tan and Constantino. They stayed in the house
of Capt. Abad the whole day and were prevented from going out of the
house by Col. Abelardo Abad, who is Capt. Abads brother who told
them wag lang isasabit si Nonoy referring to Capt. Abad. They
stayed in the house for the whole day as they were prevented to leave
allegedly for security reasons. Sensing that something may happen to
them, they all escaped around 9:00 in the evening without the
knowledge of Capt. Abad.
5. Cynthia Tan, the widow of the late Eugene Tan testified that
she and the victim have five (5) children. That the happiness of the
family was cut short by the unjustified killing of her husband. She
likewise testified on the anguish and pain that she and her children
suffered; the loss of the monetary support that her husband
provides. The loss of the life of the husband cannot be compensated
in terms of money only but the justice of putting behind bars the
perpetrators and conspirators of the crime. She likewise testified on
the expenses incurred for the burial of the husband and the earning
capacity of the husband who was a senior partner of the TAN,
MANZANO law offices.

6. Eunice Tan the third of the five children likewise narrated

how she felt with the loss of her father. Of how the love and support
 Memorandum
People of the Philippines v. Pedro C. Lim et. al.
Page 14 of 21
x-----------------------------------x

of their father was snatched by the grisly murder of their father and
his driver for which accused must suffer the consequence.

For EDUARDO CONSTANTINOS part. Defense stipulated on

the death of the said victim. They likewise agreed to stipulate the
heirs left by the said victim and the expenses incurred in the burial.
7. Dr. Rosaline O. Cosidon, MEDICO LEGAL, CAMP
CRAME testified on the cause, facts and circumstances of death of
EUGENE TAN and EDUARDO CONSTANTINO, both of which are
un-rebutted. The identities were duly established.

8. Chief Superintendent Rodolfo Tor on the other hand

testified that he was one of the arresting officer of PEDRO LIM. That
Lim was arrested because of the affidavit of Bonifacio Roxas pointing
to him as one of the mastermind in the killing of Atty. Eugene Tan.

Abstracts of the testimonies of the witnesses of the

accused.

ACCUSEDS evidence on the other hand consist mostly of alibi

and denials. PEDRO LIMS testimony bear no weight as ruled upon
by the late Judge Eleuterio Guerrero when the latter denied the
petition for bail. As earlier stated it is mere denials and alibis. The
admission of accused Roxas of his participation in the crime as
embodied in his affidavit and the people behind the murder is a
strong proof of conspiracy committed by all of the accused. Except for
Roxas, Ozores and Mirasol were not presented in the witness stand
for their defense. Thus the testimonies against them are un-rebutted.
The participation of PEDRO LIM and EUGENE YU in the
planning and execution of the crime were vividly testified to by their
cohorts who became state witnesses. Accused brothers Hizon died
during the trial, thus were discharged of any personal liability as
accessories to the crime.
Bonifacio V. Roxas Roxas in his statement declared that he
is a resident of Victory Reyes, Dasmarias Cavite, who was employed
as driver and security of the accused Pedro Lim. Roxas claims that he
was recommended to Pedro Lim by Capt. Abad sometime in August
1993. Bonifacio Roxas declared that it was Pedro Lims plan to kill
Atty. Eugene Tan for a consideration of P500,000.00. In his extra-
judicial confession given on November 22, 1994 at TF Habagat he ,
thus stated:

In the first week of September 1994, Roxas and Peter Lim

agreed for the former to conduct a surveillance of victim Atty. Eugene
Tan and for this purpose he was given by Peter Lim the amount of
P2,400.00 weekly allowance and a Datsun car that he will use in the
surveillance mission. Roxas conducted surveillance for more than a
month so he was given the allowance four or five times. Finally on
 Memorandum
People of the Philippines v. Pedro C. Lim et. al.
Page 15 of 21
x-----------------------------------x

November 14, 1994, he and the other accused carried out their plan to
abduct and kill Atty. Eugene Tan. Bonifacio Roxas identified Sgt.
Edgar Abalon, civilian agent Rudy Ochoa, agent Engine and civilian
agent Veneracion among those who carried out the actual abduction
of Atty. Eugene Tan and his driver Constantino.
Bonifacio Roxas narrated in detail that on November 14, 1994 at
about 9:00 pm accused Rudy Ochoa was driving an owner jeep with
Sgt. Abalon on board and proceeded to bump the Mercedes Benz of
Atty. Eugene Tan. Accused Veneracion Ozores took over the wheels of
the Mercedes Benz and then dragged the victims outside the
Mercedes Benz and placed them inside the Datsun car. Between
10:30 to 11:00 pm while they were cruising along the highway of
Silang, Cavite, Bonifacio Roxas confessed that using a .38 caliber
provided by Engine who was driving the a Datsun car he shot the
victim Atty. Tan once on the forehead and the victim Constantino on
the right side of the head at close range while the two were seated at
the back seat of the Datsun car.
Thereafter, together with Rudy Ochoa, Engine and Toto Mirasol
they proceeded to Silang, Cavite, where they buried the victims in a
shallow grave which Mariano Hizon dug earlier for a fee of P500.00.
On November 21, 1994, Bonifacio Roxas drove the Datsun car to
Villamor and thereafter took it to the Shell station at the corner of
Libertad and Harrison for cleaning. Bonifacio Roxas tried to collect
the P500,000.00 from Lim but the latter told him to wait. After a
week he called up accused Lim twice for the P500,000.00 and to get
the salary but was unable to get the money. Bonifacio Roxas stated
that if the money was paid he will divide it evenly among Abalon,
Ochoa, Engine, Veneracion and himself. Toto Mirasols share will be
taken cared of.
Bonifacio Roxas likewise testified that he has no motive to kill
Atty. Eugene Tan aside from the money of P500,000.00. That as far
as he knows, Peter Lim and Gilda Lim have a bitter dispute over their
properties with Atty. Eugene Tan, who he said is having an affair with
Gilda Lim and who instigated the latter to take over the family
business.
PEDRO LIM just adopted his evidence presented during the
petition for bail as part of his evidence in chief.
OZORES and MIRASOL did not present anything for their
defense except collateral documents consisting of land titles and
other collateral documents completely irrelevant to the case.
EUGENE YU on the other hand presented his secretary and a
former employee who testified on the character of Eugene Yu. Both of
which are completely irrelevant and will not suffice to overturn the
positive assertion and identification of the prosecution witnesses.
Testimonies of witnesses not presented can not be admitted as part of
the evidence.
 Memorandum
People of the Philippines v. Pedro C. Lim et. al.
Page 16 of 21
x-----------------------------------x

DISCUSSION

The confessions of the accused, the testimonial and

documentary exhibits of the Prosecution and the witnesses who
positively identified and narrated the participation of the accused
Pedro Lim, Venerando Ozores, Bonifacio Roxas and Luisito Mirasol
and that of Captain Abad, who in conspiracy with one another clearly
committed two counts of murder (except for Yu and Hizon who were
charged as Accomplice and Accessory) for the killing of Atty. Eugene
Tan and his driver Eduardo Constantino.

The accused committed treachery and evident

premeditation, taking advantage of their superior
strength, with the aid of armed men or by a band.

From the testimony of the witnesses and admission of other

accused it is clear that the murder of the two victims were qualified
with treachery and evident premeditation. Treachery was clearly
present because the victims were not given the opportunity to defend
themselves. Accused Bonifacio Roxas had the two victims handcuffed
and placed at the back seat of the car. The act ensured the prosecution
of the crime. The victims were defenseless. The suddenness in the
shooting of the victims would clearly show that treachery was present.
The Supreme Court in a number of decisions has stated that there is
treachery when:
For treachery to exist, two conditions must be found: (1) that at
the time of the attack the victim was not in a position to defend
himself; and (2) the offender consciously adopted the particular
means, method or form of attack employed by him. (People vs.
Avendano, 396 SCRA 309)
There is treachery when the offender employs means, methods,
or forms in the execution of the crime which tends directly and
specially to insure its execution without risk to himself arising from
the defense which the offended party might take. (People vs. Caloza,
Jr., 396 SCRA 329)
Clearly, evident premeditation was obtained in the
circumstances. Upon the evidence of the prosecution and accuseds
own admissions they conspired with one another to kill Atty. Eugene
Tan and his driver. The digging of the grave by Mariano Hizon
showed that the murder was pre-meditated. The Supreme Court has
held that for Evident Premeditation to qualify a crime the following
must be proven:
(a) the time when the offender has determined to commit the crime;
(b) an act manifestly indicating that the offender has clung to his
determination;
 Memorandum
People of the Philippines v. Pedro C. Lim et. al.
Page 17 of 21
x-----------------------------------x

(c) an interval of time between the determination and the execution

of the crime enough to allow him to reflect upon the consequence of
his act. (People vs. Castillano, Sr., 400 SCRA 401).
According to the testimony of the witnesses, they admitted that
the accused conducted surveillance operations and observed Atty.
Eugene Tan prior to the November 14, 1994 incident. From the
testimony of the witnesses, Eugene Yu and Peter Lim were already
plotting with Capt. Abad and coordinating with the other accused to
kill Atty. Eugene Tan. This can be also be determined from the action
of the accused when the Datsun car was provided by Peter Lim and
monies given by Eugene Yu and Peter Lim to the operatives.
When the incident occurred on November 14, 1994 all of the
accused waited for the victims to leave the office, followed the vehicle
and even concocted a plan to stop the vehicle of the victims by having
the Datsun car driven by Roxas to cut the vehicle of the victims and
then the owner type jeep driven by Ochoa to bump the rear of the
vehicle. Accused Roxas let go of his actual motive when he shouted at
Atty. Eugene Tan that putang ina mo alam mo ba malaki atraso mo
kay Peter Lim!. Likewise the fact that the accused even had a burial
site prepared in the property of Eugenio Hizon clearly shows that
there was evident premeditation on the part of the accused and they
carefully planned the entire operation for more than one month.
According to the witnesses there were six operatives who
conducted the operation on November 14, 2007 and all of them were
armed except for Sgt. Abalon. Roxas acting in concert with his cohorts
used their superior strength and their arms in order to abduct and kill
the two victims.

The accused committed the crime of murder qualified by

the use of a motor vehicle.

As testified by the witnesses, Peter Lim provided the Datsun car

with the owner type jeep which they used in abducting the victims.
Aside from this, the accused used their vehicles as a means to stop the
vehicle of Atty. Eugene Tan. After which the Datsun car was used in
abducting the victims where they were also eventually killed. The
vehicles were used by the accused in transporting and killing the
victims.

Eugene Yu and Peter Lim committed murder by arranging

the killing and kidnapping of Atty. Eugene Tan for a
consideration of price, reward or promise

The Supreme Court has ruled that the person who has received
the price or reward or who accepted a promise of price or reward
would not have killed the victim if not for that price, reward or
promise. Such person is a principal by direct participation. The one
 Memorandum
People of the Philippines v. Pedro C. Lim et. al.
Page 18 of 21
x-----------------------------------x

who gave the price or reward or who made the promise is a principal
by induction. When these circumstances are alleged in the
information for murder and proven by the prosecution, accused are
guilty as principals by inducement for the crime of murder (U.S. vs.
Alim 38 Phil. 1).
From the testimony of the witnesses and the extra-judicial
confessions executed given by the other witnesses, Bonifacio Roxas
and the rest of the operatives were promised a reward by Eugene Yu
and Peter Lim. From the testimonies of the prosecution witnesses
and by accused Roxas, vehicle and monies were provided by accused
Lim and Yu for the entire operation and also coordinated with the
superior of the accused named as Captain ABAD. Bonifacio Roxas
testified that he was ordered to kill Atty. Eugene Tan for the amount
of P500,000.00.

The accused in conspiracy with one another committed the

crime of kidnapping

There is no denying that the plan of the accused was to abduct

Atty. Eugene Tan and his driver Constantino.
It has also been proven that the crime of kidnapping also took
place since the accused in conspiracy with one another forcibly
abducted Atty. Eugene Tan and Eduardo Constantino with the use of
a motor vehicle and fire arms and deprived them of their liberty for
an unspecified length of time and against their will. Furthermore, the
kidnapping done by the accused was qualified because they simulated
their public authority as members of the Philippine Air Force. They
presented themselves to the victims as members of the Philippine Air
Force and testified that the abduction was part of their surveillance
operation on Atty. Eugene Tan as an alleged financier ng pula. The
crime of kidnapping is further qualified because the accused
threatened to kill the victims.

All the accused acted in conspiracy with one another in

mutual aid of one another in order to kidnap and kill Atty.
Eugene Tan and his driver Eduardo Constantino

The accused conspiring, confederating and mutually helping

one another, did then there willfully, unlawfully and feloniously
abduct Atty. Eugene Tan and his driver and thereafter handcuffed
their hands at the back kill them by shooting each one in the head and
buried them in a shallow grave to cover the crime.
Under Article 8 of the Revised Penal Code, there is conspiracy if
two or more persons agree to commit a felony and decide to commit
it. Conspiracy must be proven on the same quantum of evidence as
the felony subject of the agreement of the parties. Conspiracy may be
proven by direct or circumstantial evidence consisting of acts, words,
 Memorandum
People of the Philippines v. Pedro C. Lim et. al.
Page 19 of 21
x-----------------------------------x

or conduct of the alleged conspirators before, during and after the

commission of the felony to achieve a common design or purpose.
The Supreme Court has held in the case of Preferred Home
Specialties, Inc. vs. Court of Appeals, 478 SCRA 387, 414-415 that:
It is a common design which is the essence of conspiracy. The
conspirators may act separately or together by commission on
different manner but always leading to the same unlawful act. The
character and effect of a conspiracy are not to be judged by
dismembering it and viewing its separate parts but only by looking at
it as a whole. Acts done to give effect to the conspiracy may be, in fact,
wholly innocent acts. Yet, if they are parts of the sum of the acts
which are relied upon to effectuate the conspiracy which the law
forbids, they lose that character. Such acts become a public wrong if
the result is harmful to the public or to the individual against whom
the concerted action is directed.
Clearly, all the accused acted with one criminal intent and
design. They all agreed to conduct an operation to abduct Atty.
Eugene Tan by blocking his vehicle, with the purpose of killing them
and to ensure that no resistance will be put up by the victims
handcuffed their hands and thereafter shot both victims in the head.
Thus, all the accused clearly committed the crime of MURDER. In
conspiracy, the act of one is the act of all. Overwhelming evidence
has been presented to prove conspiracy. In the case of People vs.
Bulan, 459 SCRA 550 held:
If conspiracy is proved, all the conspirators are criminally liable
for the crime charged and if proved the act of one is the act of all.
It can be seen by the Honorable Court during that course of the
trial that the prosecutors have sufficiently established that the
accused Pedro Lim and Eugene Yu in consonance with Captain Abad
ordered the abduction and murder of Atty. Eugene Tan. Motive was
sufficiently proven as confirmed by the sudden outburst of accused
Roxas when he confronted the victim during the abduction.
The witnesses presented by the Prosecution are credible enough
to warrant the conviction of the accused. Sgt. Abalons testimony was
straightforward. De los Santos and Ochoa, whose qualification to
become state witnesses was favorably decided by the Honorable
Supreme Court itself are more damaging for they themselves
participated and were present when they and their colleagues
abducted and killed the victims.
While the defense points to some inconsistencies in the
testimonies of the other witnesses, as a rule however, inconsistencies
in minor details and collateral matters, does not affect the credibility
of the witnesses nor the veracity or weight of their testimonies
(People vs. Santos, 420 SCRA 37).
The Supreme Court has ruled that even one witness is sufficient
to convict an accused for murder. The Prosecution has presented
more than five (5) credible witnesses who were subjected to cross-
 Memorandum
People of the Philippines v. Pedro C. Lim et. al.
Page 20 of 21
x-----------------------------------x

examination questions by the defense counsels of the accused and all

their testimonies prove that all the accused acted in conspiracy with
one another to kill Atty. Eugene Tan and Eduardo Constantino.

The accused are liable for civil damages to the heirs of the
victims

The heirs of Atty. Eugene Tan have spent the amount of

P450,000.00 as funeral expenses evidenced by the Official Receipt
No. 55493 of the Loyola Memorial Chapels, Inc. (Exhibit K of the
Prosecution) and P141,000.00 for the entombment at the St. Jerome
Emiliani & St. Susana Parish as evidenced by Certificate of Payment
issued by the St. Jerome Emiliani & St. Susana Parish (Exhibit L of
the Prosecution).
The heirs of Atty. Eugene Tan are also entitled to damages
because of the loss of his earning capacity due to his untimely demise.
At the time of his death Atty. Eugene Tan was making at least
P1,446,976.75 annually as evidenced by Tan Manzano & Velez Law
Office Statement of Partners Equity (Exhibit J of the Prosecution).
The Honorable Court should also award the heirs of Eduardo
Constantino the amount of not less than 300,000.00 or as the court
may deem wise as actual and moral damages.
The Heirs of Atty. Eugene Tan and Eduardo Constantino are
also entitled to exemplary and moral damages because of the violent
manner in which the two victims were killed.

PRAYER

WHEREFORE, Prosecution respectfully prays that a Decision

be rendered finding the Accused Pedro Lim, Captain Alfred Abad,
Venerando Ozores, Bonifacio Roxas and Luisito Mirasol and Eugene
Yu guilty beyond reasonable doubt for the crime of KIDNAPPING and
TWO (2) counts of MURDER for the abduction and killing of Atty.
Eugene Tan and Eduardo Constantino, as penalized under Article 248
of the Revised Penal Code, and be adjudged civilly liable to indemnify
the heirs of their victims.

Other reliefs just and equitable in the premises are likewise

prayed for.

Makati City for Tagaytay City, 18 March 2008

JURILLA, ARREOLA & MAIBO LAW OFFICE

Private prosecutors
5/F PHILSTEEL Tower
 Memorandum
People of the Philippines v. Pedro C. Lim et. al.
Page 21 of 21
x-----------------------------------x

140 Amorsolo St., Legaspi Village

Makati City
Tel # 8942875 Fax # 8103222

EILEEN KAY A. MAIBO

PTR#0921243;1/07/2008; Pasay City
IBP# 733978;1/8/2008; Manila IV
Roll No. 3828

MARK C. JURILLA
PTR#0921244;1/07/2008; Pasay City
IBP# 727385;1/07/2008; Pasay
Roll No. 34508

With my conformity:
________________
Jose Velasco
Public Prosecutor
Copy furnished:
GARAYBLAS GARAYBLAS DELA CRUZ CAIRME LAW OFFICE
Counsel for accused Eugene Yu
Suite 301 & 302 Amarcemca Building
107-A Kalayaan Avenue, Quezon City.

FORNIER FORNIER & LAGUMBAY

Counsel for Accused Venerando Ozores, Bonifacio Roxas and Luisito
Mirasol
St. Thomas Moore Law Center
12th floor, G.E. Antonino Bldg.
TM Kalaw cor. J. Bacobo Street
Ermita, 1000 Manila

Jose Manuel I. Diokno

Room 101m Alumni Center, Magsaysay Avenue
University of the Philippines Campus
Diliman 1101, Quezon City.

Sanidad Abaya Te Viterbo Enriquez & Tan Law Firm

Counsel for the Accused Pedro Lim
2nd Floor, Transorient Maritime Building
66 Timog Avenue, Quezon City 1100

EXPLANATION

The foregoing Memorandum is being served on the Counsels of the

accused by registered mail due to time and personnel constraints.

EILEEN KAY A. MAIBO