Republic of The Philippines Regional Trial Court Makati City, Branch 139

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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


Makati City, Branch 139

Datu Ana Mejares, CIVIL CASE No. 3-07


Claimant,

-versus-

National Gold Mining


Respondent.
---------------------------------------/

JUDICIAL AFFIDAVIT
OF DR. JUAN TABOTABO

I, DR. JUAN TABOTABO, of legal age, single, and a resident of


Amorsolo Street, Legaspi Village, Makati, Metro Manila, Philippines after
having been sworn to in accordance with the law do hereby depose and
state that:
PRELIMINARY STATEMENT

The person examining me is ATTY. DOROTHY TALIDRO with


office address at Bgen Felix T Pestana (Ret) Bldg., AFPOVAI Phase III,
Deigo Silang St., Western Bicutan, Taguig City.
I am answering the questions herein fully conscious that I do so
under oath and that I may be criminally liable for false testimony or
perjury.

PURPOSE: This affidavit / testimony of, DR. JUAN TABOTABO, is


being offered to prove that he is a medical doctor who works for the
Humanity & Environment Health Organization (HEHO), and has personal
knowledge about the unsafe and unsanitary practice made by the Northern
Gold Mines which led to the death of the several tribes and members of
Mannagadjans who fell ill.

EXAMINATION PROPER
Consequently numbered, the following questions were asked of me
and I gave my corresponding answers, as follows:

Q1: Do you swear to tell the truth and nothing but the truth?
A1: Yes, Attorney.

Q2: Please state your name and other personal circumstances for the
record.
A2: I am DR. JUAN TABOTABO, a medical doctor who works for the
Humanity & Environment Health Organization located in Makati.

Q3: What is your relationship with Datu Ana?


A3: I, as a doctor of Humanity & Environment Health Organization
(HEHO), was called to determine the cause of the death and illness of the
tribes of Mannagadjans.

Q4: What do you know about the project conducted by the Northern Luzon
Gold Mines?
A4: The project conducted by the Northern Luzon Gold Mines was a mining
operation by virtue of the Financial and Technical Agreement executed by
the President with NLMC.

Q5: When did the Northern Luzon Gold Mine started its operation?
A5: As far as I know, the mining operation started in January 2017.

Q6: What happened to the tribes in Mannagadjans? How does it connect to


the mining operations made by the Northern Luzon Gold Mines?
A6: On March 28, 2018, I was called to conduct a health examination
between the members of the tribe who fell ill and was also there to
determine what could be the reason behind the death of the other members
of the tribe.

Q7: Upon the conduct of your examination, what did you find out?
A7: I discovered that there is a common pattern between those who fell ill
and those who died. The cause of their illness was due to the exposure to
mercury and had high levels of cadmium in their system. Scientifically,
once that happens, the person who gets exposed will also suffer from acute
lung damage, which may lead to his or her death. The same thing happened
between the tribes who got affected on such unfortunate incident.

Q8: Do you think that the mining operations is attributable to their illness?
A8: Yes. In fact, I believe that the mining operations done by the Northern
Luzon Gold Mines was unsafe and unsanitary which led to exposure of
airborne respirable dust and high levels of cadium resulting to high
potential risk factor among the tribe.

Q10: What could possibly happen if this was not acted upon?
A10: This could result to more numbers of death among the tribes of
Mannagadjans.

Q11: Do you have anything else to say?


A11: None Attorney. I have nothing else to say.
IN WITNESS WHEREOF, I hereunto set my hand below this 10th day of
March, 2021 at Amorsolo Street, Legaspi Village, Makati, Metro Manila,
Philippines.

DR. JUAN TABOTABO


Affiant

SUBSCRIBED AND SWORN to before me this 30th day of April,


2021 at Amorsolo Street, Legaspi Village, Makati, Metro Manila,
Philippines, by affiant who personally appeared before me and exhibited to
me his competent evidence of his identity consisting of Passport No.
P01551596K. Further, I certify that I personally examined the herein affiant
that he voluntarily executed and fully understood her statements.

ATTESTATION OF LEGAL COUNSEL

I, ATTY. ANNE MARIE CABASE, of legal age, Filipino, with office


address Unit 308, Aurora Arcade Building, 1740 Alabang–Zapote Road,
Almanza Uno, Las Pinas, Metro Manila, after having been sworn to in
accordance with the law do hereby depose and say:

1. That I have faithfully recorded and translated into his Local Dialect
the questions asked of him and the corresponding answers that he gave in
response to the questions asked;

2. That I have not, nor any other person present or assisting coached
the witness regarding the witness’ answers; and

3. That I fully understand that any false attestation shall subject me to


disciplinary action, including disbarment.

IN WITNESSWHEREOF, I have hereunto affixed my signature this


30th day of April 2021 in Makati City, Philippines.

ATTY. ANNE MARIE CABASE


Legal Counsel for Claimant

SUBSCRIBED AND SWORN to before me, Affiant, showing to me


his competent proof of identity, who is personally known to me as the same
person who personally signed the foregoing instrument before me and
avowed under penalty of law to the whole truth of the contents of said
instrument.

Doc No. 5;
Page No. 19;
ATTY. DOROTHY C. TALIDRO
Book No. 5; Notary Public for Taguig City
Bgen Felix T Pestana (Ret) Bldg., AFPOVAI Phase III,
Series of 2021
Deigo Silang St., Western Bicutan, Taguig City
IBP No. 654000; 01/10/05 – Manila
PTR No. 765111; 01/10/20 – Manila
Roll No. 876222; 5/05/05
MCLE No. I – 987246; 10/10/20
MCLE No. II – 098765; 09/09/20
Series No. of Commission M-303

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