Republic of the Philippines

SUPREME COURT

Manila City

NUTT O. RIOUSE

Petitioner,

- versus -

GRAFT AND CORRUPT PRACTICES BOARD

Respondent.

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MEMORANDUM FOR THE RESPONDENT

COMES NOW RESPONDENT, through the undersigned counsel,
unto this Honorable Supreme Court, most respectfully submit and present
this MEMORANDUM in the above-titled case and aver that:

THE PARTIES
1. Plaintiff, NUTT O. RIOUSE (hereafter be called Nutt for brevity), is
40 years old, Filipino, married with residence at Block 67 lot 11 Gloria Diaz
BF classic, Manila city, where he may be served with legal processes and
notices issued by this Honorable Court;

2. Respondent, GRAFT AND CORRUPT PRACTICES BOARD

(hereafter be called Board for brevity), a government agency created by the
Congress, has an office located at # 143 One Rizal Park, Manila where it
may be served with legal processes and notices issued by this Honorable
Court.

PRELIMINARY STATEMENT

Every state in the world has to deal with their internal problems and
come up with ways to cleanse and free them from the disease of
corruption. Comes now, the issue on corruption in the Philippines that has
been time and time again considered to be one of the most corrupt country
in the world.

The state through its government took the initiative of creating the
Graft and Corrupt Practices Board with the unification of the branches of
the Government working together in order to cleanse and address this
ordeal which hampers the image of our beloved country the Philippines.
However, this method of eradicating and disciplining cannot come to
fruition without it first being question by concern individuals or by persons
who may be subject of investigation by this board.

On the contrary, the creation of the board is in line with the

parameters set forth in our Constitution and Jurisprudence. The strict
prohibition in the encroachment of the powers of the different branches of
the Government was observed and based on existing law which other
executive agencies were created.
 The cooperation of the branches of the government was aimed to
ensure that the composition of the board is screened and vetted to avoid
any political bias and ensure the integrity of the members composing the
board. It is also enshrined under the 1987 Constitution’s Accountability of
Public Officers which provides the qualification of public officers before it
can assume office. Article XI, Section 1 provides:

Public office is a public trust. Public officers and

employees must at all times be accountable to the people,
serve them with utmost responsibility, integrity, loyalty,
and efficiency, act with patriotism and justice, and lead
modest lives.

In line with this, the help of the Judicial and Bar Council to vet and
screen the nominees of the board can guarantee that its members possesses
the qualifications which can serve and execute the mandate of the law in
dealing with errant government officials and employees for graft and
corruption.

Lastly, this case will once and for all settle the questions and doubts
against the creation of the board which will serve notice to the public that
the board was created in line with the Constitution and Jurisprudence
without violating any rights of individual who may be subject of the
investigation of the Graft and Corrupt Practices Board.

FACTUAL BACKGROUND

ISSUES OF THE CASE

ARGUMENTS

A.

B.
 DISCUSSION

A.

B.

PRAYER

ATTY. JOHN BRIAN CO

Counsel for Respondent

c/o Mendez, Mabanta, Co, Sarmiento, and Alfonso Law Office

Unit 99, Philippine Stock Exchange Tower, 5th Ave cor, 28th St, Taguig,
Kalakhang Maynila

Roll of Attorneys No. 456789

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Tel. No. 478-9994

jbco@gmail.com