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Answer Labares Final

- Plt Lutgardo Y Labares is responding to an administrative case filed against him by the Philippine National Police for alleged offenses related to attending a cockfighting event while off-duty. - He argues the case should be dismissed due to forum shopping as he was already charged for the same offense in another district. - He denies the charges of grave irregularity in duty and neglect of duty, as he was off-duty at the time of the alleged cockfighting incident and not performing official functions or duties. - However, he acknowledges breaching internal discipline by entering the cockpit arena while off-duty and pledges not to repeat this mistake.

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Darwin Viadumang
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799 views

Answer Labares Final

- Plt Lutgardo Y Labares is responding to an administrative case filed against him by the Philippine National Police for alleged offenses related to attending a cockfighting event while off-duty. - He argues the case should be dismissed due to forum shopping as he was already charged for the same offense in another district. - He denies the charges of grave irregularity in duty and neglect of duty, as he was off-duty at the time of the alleged cockfighting incident and not performing official functions or duties. - However, he acknowledges breaching internal discipline by entering the cockpit arena while off-duty and pledges not to repeat this mistake.

Uploaded by

Darwin Viadumang
Copyright
© © All Rights Reserved
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

NATIONAL POLICE COMMISSION


NATIONAL HEADQUARTERS, PHILIPPINE NATIONAL POLICE
INTERNAL AFFAIRS SERVICE
Camp BGen Rafael T Crame, Quezon City

PHILIPPINE NATIONAL POLICE


Complainant,
ADMIN CASE NO. NIAS-NMP-20-015
-versus- For: Grave Irreg. in the Performance
of Duty/Less Grave Neglect of Duty and Conduct
Unbecoming of a Police Officer
PLT LUTGARDO Y LABARES
Respondent.
x----------------------------------x

RESPECTFUL ANSWER

Undersigned Respondent, assisted by counsel, unto the Honorable Office


of the Internal Affairs Service, most respectfully submit the instant Answer, and
in support thereof, state, that;
1. Before proceeding any further, the Respondent hereby states that the
instant complaint should have been dismissed on the ground of forum
shopping.
It is worthy to note that herein Respondent was already charged at
Southern Police District for Less Grave Neglect of Duty docketed as
NCRPO-SPD-DISTRICT HQS-No. 2019-0386 for the same offense that
is the subject of this administrative case. (Hereto attached and marked
as ANNEX “A” is the administrative case filed against the respondent at
Southern Police District)
2. Nonetheless, the Respondent categorically state that:
The charge of grave irregularity in the performance of duty has no
legal and factual basis. The Respondent was not on official duty on
October 4, 2019 when he was caught inside the cockpit arena. Hence,
the Respondent cannot in anyway commit an offense of irregularity in
the performance of duty simply because he is not carrying out an
order or performing official function at the time of alleged
cockfighting.
3. The charge of neglect of duty and conduct unbecoming a police officer
was also erroneous considering that the respondent did not disregard
or abandoned his duty as police officer. The Respondent was off duty
and was not performing or carrying out official function on the date of
the alleged cockfighting.
4. On the other hand, the Respondent most respectfully admit that he
had committed a breach of internal discipline when he entered the
cockpit arena. Respondent acknowledges his shortcomings and swore
that the same incident will never happen again.
5. In view of all the foregoing, the Respondent moved that the above
entitled case be dismissed on the ground of forum shopping.

In witness whereof, I hereunto affixed my signature this __ day of January


2020, at Bacoor City, Philippines.

PLT LUTGARDO Y LABARES


Respondent/Affiant

Assisted by:

Atty. Antonio T. Nicolas


Counsel for the Respondent
Poblacion Bacoor City, Cavite
ROLL No. 27875
P.T.R. No. 1632949/1-3-19 Bacoor
IBP No. 059037/1-11-19-Imus
MCLE- VI-0011370 8-17-18

Subscribed and sworn to, before me this ___ day of January 2020, at
Bacoor City, Philippines. This is further to certify that I have examined the
respondents and that they voluntarily executed and understood their given
affidavit.

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