there is no bank in the whole world that can stand a large scale bank run by Bh6Ako8


									                                                Republic of the Philippines
                                             OFFICE OF THE OMBUDSMAN
                                             Ombudsman Building, Agham Road
                                             Government Center, North Triangle
                                                   Diliman, Quezon City


         - versus -                                                                   OMB-ADM-0-00-0867
RAFAEL B. BUENAVENTURA,                                                               FOR: Violation of Sec.4, R.A.6713
Governor                                                                              and Sec. 16, R.A. 7653
Deputy Governor
Managing Director
General Counsel
         All of the Bangko Sentral ng Pilipinas
         BSP Complex, Roxas Boulevard
         Ermita, Manila

                                  MOTION FOR RECONSIDERATION

        COMPLAINANT TEODORO C. BORLONGAN, by counsel, respectfully moves for the
reconsideration of the Order of this Honorable Office dated 2 July 2002 and received only on 10 July 2002, on the
grounds that:




                                                PREFATORY STATEMENT

        Lest the Honorable Office be misled into thinking that the instant action is for the purpose of questioning
the decision of the Monetary Board ordering the closure of Urban Bank, Inc.(UBI) and its related companies,
complainant is compelled to reiterate and/or clarify the basis of this action.

        The Complaint herein does not charge the Monetary Board for the closure of UBI, Urbancorp
Development Bank (UDB), and Urbancorp Investments, Inc. (UII). Rather, it charges BSP officials for their
gross negligence, partiality, lack of diligence, and bad faith in causing the preparation of the three (3) BSP-SES
(Supervision and Examination Sector) Reports that recommended their closure. What complainant seeks is a
redress of the breach of the norms and standards that respondents should have observed in the discharge of their
duties and responsibilities as officers of BSP. The norms and standards that they are and were enjoined to observe
are contained in Section 4, Republic Act No. 6713 and in Section 16, Republic Act No. 7653 (New Central Bank
Act). The instant action was in no way intended to be a substitute of the remedy of certiorari as provided under
Section 30 of Republic Act No. 7653, as respondents depict this action to be.
       The Honorable Office should therefore adjudge the issue of whether or not those norms and standards
have been observed by respondents, especially in the light of the misleading statements and blatant falsehoods and
misrepresentations of respondents relative to the true financial condition of UBI and its related companies.



        Since the filing of the instant case, complainant Teodoro C. Borlongan unearthed additional pieces of
evidence that point to (a) breach of respondents' commitment to the public interest as well as the norms of justice
and sincerity as enjoined under Section 4, Republic Act No. 6713; and (b) negligence and failure to exercise
extraordinary diligence under Republic Act No. 7653.

         It bears stressing that complainant was not given the opportunity of filing a Reply-Affidavit in the instant
proceedings, despite the clear tenor of the Rules of Procedure of this Office. Some of the admissions in
respondents' Counter-Affidavits may therefore be said to constitute new evidence insofar as complainant is
concerned. As far as complainant knows, some of the declarations of respondents in the instant case are novel and
entirely new, hence these are newly discovered.

          This Office may consider the following new pieces of evidence:

                 NEW EVIDENCE NO. 1 – BSP CIRCULAR NO. 156 PROVES

        In their Counter-Affidavits, respondents averred to the truthfulness of the three SES Reports. This Office
may recall that in order to bolster the recommendation for the closure of Urban Bank, Inc. (UBI), it was alleged in
the SES Report that UBI's capital deficiency was one of three financial bases to depict UBI's “precarious”
financial condition. UBI’s alleged capital deficiency was stated also in the counter-affidavits of respondents
Buenaventura, Reyes, and Aure.

          In their Supplement to Opposition dated 22 October 2001 (Paragraph 3), respondents Reyes and Aure

                 "3. No untruthful statement allowed.- The three (3) SES Reports, which Respondents
                 allegedly conspired among themselves to falsify, were actually based on verified findings of
                 the BSP. . ..
                                   xxx              xxx              xxx
                 "3.2. UBI’s capital deficiency known to the Monetary Board prior to UBI closure…"

        In the SES Report on UBI, UBI’s capital was stated as amounting to P2.184 to P2.201 billion from
January to March 2000, allegedly short of the P2.400 billion minimum capital required by BSP.

         Complainant calls the attention of the Honorable Office to BSP Circular No. 156 dated 19 March 1998
(hereto attached as Annex "A"), providing for the applicable capital requirement of banks at the time of UBI’s
closure. BSP Circular No. 156 stated:

                 "Commercial banks which are existing…are hereby allowed the following time frame within
                 which to meet the minimum capital requirement:

                         P2.000 billion on or before December 24, 1998
                         P2.400 billion on or before December 31, 1999
                         P2.800 billion on or before December 31, 2000.

                         xxx               xxx              xxx
                "Provided further, That commercial banks which are listed in the Philippine Stock
                Exchange…shall have an additional six (6) month period to meet the minimum capital
                requirement." (Emphasis supplied)

         The BSP Circular leaves no room for interpretation: while UBI’s required minimum capital was only
P2.000 billion, it was not capital-deficient at the time of its closure. In fact, as a publicly-listed bank, UBI was
entitled to an additional period of six (6) months from 31 December 1999 within which to meet the increased
minimum capital requirement. That UBI is a publicly listed bank is evidenced in UBI’s audited financial
statements, attached hereto as Annex "B".

         At the time of UBI's closure, said Circular was still in effect and had not been superseded by any other
circular or issuance of the BSP.

        Respondents ignored BSP Circular No. 156 which granted publicly-listed banks additional time to meet
the increased capital requirement, and falsely stated in the SES Report that UBI was deemed capital-deficient.
This was insisted on by respondents in their respective Counter-Affidavits. Despite their presumed knowledge of
said Circular and of the fact that UBI was a publicly-listed bank, respondents, either in gross inexcusable
negligence, obvious partiality, or utter bad faith, found UBI to be capital deficient.

         Actually, respondents Buenaventura, Reyes and Aure must be found liable for perjury. The foregoing
further suggests a manifest intention to suppress BSP Circular No. 156.

                /ASSERTION OF A FALSITY.

       UBI provided more than sufficient loan-loss reserves to cushion UBI’s past-due loans, a fact known to
respondents when they prepared the SES Report but which they maliciously concealed. The ratio of UBI's past-
due loans exceeding industry average in December 1999 to February 2000 was cited as a one of three bases
employed to highlight UBI’s “precarious” financial condition.

        Loan-loss reserves are funds taken from (deducted from) a bank’s income or capital surplus and are set-
aside to meet potential losses from probable bad loans. On 22 November 1999, BSP-SES required UBI to
provide a total of P572-million (P558.3-million plus P13.3-million in specific and general reserves, respectively)
in such reserves for loans and other risk assets, based on its 1999 examination of the bank’s loan portfolio (Annex
“C” hereof). Instead, UBI voluntarily provided P920-million in reserves, or sixty-one percent (61%) more than
what BSP required.

         The amount of P920-million in loss-reserves is clearly stated in UBI’s audited financial statements as of
31 December 1999, and contained in the Independent Public Accountants’ Report by Sycip Gorres Velayo and
Company (SGV) dated 25 February 2000 (Annex B”). The same amount in loss-reserves is likewise stated in
UBI’s Report to BSP on Compliance with General Loan Loss Provision as of 31 March 2000 (Annex “D”

       The attention of the Honorable Office is called to BSP’s receiving stamp-mark on said Report (Annex
“D”). The Department of Commercial Banks II received said Report on 14 April 2000. It may be noted that said
Report was received two (2) weeks prior to the preparation of the subject SES Report, and by no less than Aure's
own department.

        In his Counter-Affidavit (Paragraph, respondent Aure misleads the Honorable Office and
attempts to obfuscate the facts regarding UBI’s loss-reserves by crossing incongruous dates of booking, reporting,
and accounting effectivity.

        From the evidence herewith submitted and from Aure’s own admissions, the facts clearly are:

1.      UBI provided enormous loss-reserves, more than what BSP had required as a result of BSP’s examination
        of UBI and as contained in BSP’s Report of Examination with covering letter dated 22 November 1999;

2.      The loss-reserves in the amount of Php 920 million are indicated in the SGV-audited financial statements
        of UBI as of 31 December 1999, copy of which BSP received.

3.      Aure’s own department was in receipt of UBI’s Report to BSP indicating the excess loss-reserves, two
        weeks prior to preparation of the SES Reports.

4.      In citing in the relatively high past-due loans depicting UBI’s “precarious” financial condition,
        respondents purposely and maliciously omitted, with bad faith or evident partiality, this material and
        offsetting fact in the SES Report.

         Respondent Aure is guilty of having declared a falsity for declaring in his Counter-Affidavit (Paragraph that “Borlongan’s claim in his Complaint-Affidavit that the non-performing loans had adequate reserves
greater than that required by BSP is erroneous…Likewise, Borlongan’s claim that UBI provided P920 million as
of December 31 1999… is also false.”


        The SES Report on UBI cited UBI's alleged chronic illiquidity ostensibly to support UBI's closure. In
their Counter-Affidavits, respondents Buenaventura, Reyes and Aure stated that the BSP and Monetary Board had
long known the “precarious financial condition” of UBI, citing their actions since 1998. The Honorable Office
may note that like the SES Reports, said respondents' Counter-Affidavits are eerily one-sided and totally ignores
other reports and findings to the contrary.

        The attention of the Honorable Office is called to the following counter-circumstances of UBI’s financial
condition that respondents maliciously concealed or inexcusably ignored, and the events that betray their malice
and partiality:

1.      In 1998 just prior to UBI’s voluntary downgrade from an expanded commercial bank to a regular
        commercial bank, BSP cited UBI for its overall performance in solvency, liquidity, and management. The
        SLIM (Solvency, Liquidity, and Management) rating was BSP’s tool to measure a bank's health as against
        the entire expanded commercial banking system. BSP rated UBI with a score of 82.89 points, as against
        industry average of 76.09 points. This means that BSP rated UBI’s financial position to be better than
        more than half of the other universal banks in the country, in terms of solvency, liquidity and

2.      In 1999, BSP-SES conducted a thorough, regular examination of UBI. In its Final Report of Examination
        which SES provided UBI only in November 1999 (Annex “C”), said report concluded:

                OVERALL CONCLUSION:
                Urban Bank, Inc. showed satisfactory financial condition as of March 31, 1999…

                For the last three (3) years, its operations continued to be profitable despite recent financial
                turmoil in the Southeast Asian region. It managed to maintain its solvency and liquidity
                during the period under review…

                Bank’s composite CAMELS rating of “3” indicated that UBI may be vulnerable to business
                fluctuations and other outside economic factors but failure is unlikely. Bank had
                substantially complied with banking laws, BSP rules and regulations except for some
                violations/exceptions and weaknesses detailed in Annex A.

3.      In 1999, UBI granted a Php 3-billion one-year loan facility to the National Food Authority, to finance its
        food procurement and inventory. In that year, Urban booked Php2.4 billion of loans to NFA, about
        Php2.0 billion of which was lent in December 1999, making UBI one of the largest, if not the largest,
        private lenders to NFA during that year. This fact was known by respondent Buenaventura, who sits as
        member of the NFA Council.

4.      In addition in 1999, UBI lent Php921-million of mortgage loans to the housing sector under the guaranty
        of the government’s Home Insurance and Guaranty Corporation (HIGC), benefiting some 30 developers
        and countless homebuyers. For that year, UBI became one of the largest, if not the largest, lenders
        under the HIGC program (Annex “E” hereof).

5.      In the month of January 2000, UBI was one among the large bank lenders in the interbank loan market,
        in terms of net daily average for the whole month. This fact and UBI’s other lending activities in March
       and April 2000 were stated in the Complaint (Vide Page 15)

6.      Yet, during a run caused by BSP’s irresponsible and malicious statements to media about UBI’s
        downgrading, UBI and UII made good about Php3 billion of withdrawals in the 5 weeks prior to their
        closure. And even at the time of closure, UBI still had about Php2 billion left in liquid and non-risk
        assets. It did not borrow a single centavo from BSP or Philippine Deposit Insurance Corporation (PDIC).

7.     It therefore is highly questionable that the SES Report would recommend permanent closure for reason of
       illiquidity, after UBI declared a temporary bank holiday to halt the run (Annex C of Complaint). As
       clearly stated in UBI’s letter to respondent Buenaventura dated 25 April 2000 (Annex B of Complaint):

               "Dear Governor Buenaventura:

                    "Please be informed that in view of media reports of our downgrading to a thrift bank
               which created liquidity problems, Urban Bank is declaring a bank holiday effective at the
               close of business hours today April 25, 2000."

8.     In a congressional hearing investigating into UBI’s closure and conducted by the House Committee on
       Good Government on December 6 2000, Reyes was asked, “Kapagka nagkaroon ng crisis of confidence,
       there is no bank in the whole world that can stand a large scale bank run, di po ba?” Reyes answered,
       “That’s right.”

9.     In his Counter-Affidavit (Paragraph 4.2.4), Reyes stated: “The legal basis for the closure of UBI is its
       illiquidity which became apparent when Borlongan and Bartolome asked for emergency assistance.” Yet
       after UBI’s closure, BSP granted enormous liquidity assistance to numerous banks such as Philippine
       Bank of Communication, International Exchange Bank, Philippine National Bank, and Equitable-PCI
       Bank which likewise suffered from illiqudity and requested for emergency assistance from BSP. These
       banks were not recommended closed by BSP-SES.


       In their defense that the immediate closure of UBI and UDB because of illiquidity was regular and
precedented, Respondents Reyes and Aure cited four (4) small rural banks that were ordered closed by the
Monetary Board and the SES memoranda (reports) that recommended their closure because of similar liquidity

               “Notably, the closure of UBI for illiquidity is not without precedent. Earlier other banks were
               also closed by the Monetary Board for incurring liquidity problems.

               “The closure of UBI for illiquidity arising from a bank holiday was not the first closure
               undertaken by the Monetary Board. On several occasions, the Monetary Board had placed a
               bank under receivership because of illiquidity but not on the basis of insolvency. In the years
               1999 and 2000, the following banks were placed by the BSP under receivership on the ground
               of illiquidity, to wit: Rural Bank of Santander (Cebu), Inc.; Rural Bank of Gumaca (Quezon),
               Inc.; Rural Bank of Bocaue (Bulacan), Inc.; and Rural Bank of San Teodoro, Inc. Copies of
               the Memoranda recommending the closure of the above-enumerated banks under receivership
               due to illiquidity are herewith attached as ANNEXES 1, 1-A, 1-B, and 1-C, and made integral
               parts hereof.” (Supplement to Opposition by Reyes and Aure, dated 22 October 2001,
               Paragraph 5)

       Unfortunately for respondents, Reyes and Aure did them all in by incriminatingly identifying banks that
would only prove that respondents had discriminatory and capricious intentions to close UBI with UDB and UII.
Excerpts of the four (4) SES memoranda (reports) that recommended closure of these banks are as follows:

        1.     Rural Bank of Santander (Cebu), Inc.
               SES Report dated September 6, 2000.

                         “The bank has insufficient realizable assets, as determined by the Bangko Sentral ng
               Pilipinas, to meet its liabilities. Net realizable assets as of March 31, 2000 is P14.951 million
               less than liabilities of P67.180 million.”
                                             xxx                xxx               xxx
                         “In a meeting held on August 24, 2000, it was emphasized that infusion of fresh
          capital should be adequate to cover capital deficiency and solve the liquidity problems…

                   “On August 28, 2000, the (BSP) Department received Resolution No. 27 dated
          August 25, 2000 adopted by the (rural bank’s) board of directors and controlling stockholders
          voluntarily surrendering the operation/affairs of the bank.”

     2.   Rural Bank of Gumaca (Quezon), Inc.
          SES Report dated August 9, 2000.

                   “The bank has insufficient realizable assets, as determined by the Bangko Sentral ng
          Pilipinas, to meet its liabilities. Net realizable assets as of April 30, 2000 is computed as
          follows (in million) … (P9.644).”
                             xxx                xxx                xxx
                   “The realizable value of the bank’s assets is P11.218 million less than its liabilities to
          be settled. Realizable value after considering appraisal increment of P1.574 million on
          ROPOA would still be less than the liabilities by P9.644 million.”
                             xxx                xxx                xxx
                   “In our (BSP) letter dated May 23, 2000, the bank was given a final deadline of June
          15, 2000 to correct the serious findings noted in the April 30, 2000 special examination,
          particularly the infusion of fresh capital to correct the deficiency. Bank management failed to
          infuse the required capital within the June 15, 2000 deadline.”

                   “In a letter dated July 6, 2000, the (rural bank’s) Board of Directors was reminded of
          management’s inaction on the directives as contained in the May 23, 2000 letter; and that said
          inaction would be taken to mean as disinterest on its part to rehabilitate the bank; and that
          BSP would have to take action as mandated by law.”

3.        Rural Bank of Bocaue (Bulacan), Inc.
          SES Report dated August 16, 2000

                    “Findings in the general examination as of January 31, 2000 disclosed that the bank
          has insufficient realizable assets to meet its liabilities …”
                              xxx                xxx                 xxx
                    “The bank has insufficient realizable assets, as determined by the Bangko Sentral to
          meet its liabilities. The bank’s net realizable assets is computed as … (P39.269).”
                              xxx                xxx                 xxx
                    “The bank was granted a liquidity loan of P100 million on June 5, 2000 (MB
          Resolution No. 927). A total of P17.023 million has been released …”
                              xxx               xxx                  xxx
                    “In a meeting held at the BSP last April 7, 2000 and attended by one bank officer
          and the legal counsel, the bank was enjoined to infuse fresh funds of at least P53.146 million
          within 30 days from April 7, 2000.”

                   “The bank was advised to consider inviting new investors to rehabilitate the bank
          within 30 days if present stockholders are not in a position to infuse fresh funds.”

4.        Rural Bank of San Teodoro, Inc.
          SES Report dated September 2, 1999

                   “The book value of the bank’s assets is less than its liabilities by P17.185 million (as
          of February 28, 1999).”
                             xxx               xxx                xxx
                   “Despite a P32.938 million drawdown from its approved emergency loan of P50.000
          million (approved by the M.B. in its Res. No. 091 [P20 million] dated January 21, 1998, and
          No. 980 [P30 million] dated July 8, 1998), the bank has not been able to contain the
          continuing demands for withdrawal.”
                             xxx               xxx                xxx
                   “In our letters of February 9 and 15, 1999, the bank was given up to February 28,
          1999 to have the rehabilitation in place, otherwise Section 30 of R.A. 7653 shall be applied.
          Again, in our letter of March 30, 1999, management was informed that it has been given
          sufficient time within which to rehabilitate the bank.”

                  “In our (BSP) letter of May 12, 1999 informing the bank of the results of the special
          examination as of February 28, 1999, we reiterated to management that it has been given
          enough time within which to rehabilitate the bank but none has ever materialized. The bank
          was warned that the persisting and untenable condition leaves BSP with no recourse but to
          implement Section 30 of R.A. 7653.”

         From the contents of the SES reports, it is obvious that all these four (4) banks were INSOLVENT
(meaning, the liabilities of the bank exceed its assets). Insolvency is a clear unequivocal basis under Section
30(b) of RA 7653 New Central Bank Act to close a bank and place it under receivership, to wit: “(b) has
insufficient realizable assets, as determined by the Bangko Sentral, to meet its liabilities”. Yet, UBI and UDB
were not found to be insolvent at the time of their closure, as is evident in their respective SES reports.

         In the fifty two (52) years of the old and new Central Bank Acts (R.A. 265 and 7653), it appears that
this is the FIRST TIME that a bank (or, for that matter, two banks) was ever closed for reason of only
illiquidity, a fact that respondents attempted to conceal by their PERJURY.

       The truth is, the recommendation to close UBI and UDB because of illiquidity was irregular,
unprecedented, and without valid basis. Respondents clearly made such recommendation out of gross
inexcusable negligence, manifest partiality or utter bad faith.

        In the light of false and misleading testimonies, respondents Reyes and Aure should therefore be
additionally charged with perjury.

        Furthermore, respondents Reyes and Aure insult our intelligence by citing three (3) banks that were
ordered closed AFTER UBI’s and UDB’s closure.

        It is also apparent from the SES Reports that it took several months before the SES finally recommended
the closure of these four banks. In the case of UBI and UDB, it only took the respondents less than 24 hours to
recommend immediate closure.

       Furthermore, it is apparent that there were discussions and conferences between these four banks and
BSP regarding the latter’s findings, as they were accorded due process. In the case of UBI and UDB, there was
no conference or discussion about the SES findings in their reports, when respondents made their
recommendations to the Monetary Board.

        Furthermore, it is apparent that these four banks were given the opportunity to correct their deficiencies
based on the SES findings. In the case of UBI and UDB, no opportunity was given to them to correct any
deficiencies, as respondents made their immediate recommendations of radical closure to the Monetary Board.


       The Supervision and Examination Sector (SES) and its personnel are bound by the examination standards
and procedures established by the BSP. These standards and procedures are properly documented in the Central
Bank Manual of Examination Procedures (Annex “F”), excerpts of which are quoted hereunder:



        x x x
        17. Prepare yourself with details of findings before conferring with officials of the institution at the
        termination of the examination. Conduct the conference with an open mind and in the most dignified
        manner. Avoid arguments and take note of their explanations or reasons to exceptions noted.

        18. Complete and submit your report within a reasonable period.


        The Examiner-in-Charge undertakes the overall supervision of the examination. He directs the
        examination so as to attain its objectives most efficiently. His primary duties and responsibilities are
        as follows:

        x x x
        6. Summarizes examination findings noted.
        7. Leads the conference with officers/directors of the institution on exceptions/deficiencies noted.
        8. Prepares the examination report. (page 7)

        4. Concluding the examination. (page 14)

        All working papers together with a list of exceptions/deficiencies noted should be turned-over by
        assisting examiners to the examiner-in-charge for review and compilation. Follow-up of previous
        examination findings should be undertaken by the examiner-in-charge.

        Assisting examiners should refrain from conferring about their findings with any of the institution’s
        officers or employees. They should leave this to the examiner-in-charge to avoid confusion and
        embarrassments. A pre-closing conference led by the examiner-in-charge should be held with the
        officers/representatives of the institution on findings/exceptions. The minutes of the conference may be
        made part of the report to the Monetary Board. A copy of the summary of findings/violations should
        be furnished the institution examined so that corrective action may be taken by them as soon as

        Respondents flagrantly violated their own Central Bank Manual of Examination Procedures when they
prepared the SES Reports on UBI, UDB and UII in at least four (4) major points:

1.      As admitted in his Counter-Affidavit (Paragraphs to, respondent Aure himself prepared
        the SES Report on UBI. Under the Manual of Examination Procedures, the report should have been
        prepared by the examiner-in-charge of UBI, and not by the department head who would have to review
        said report. (In the case of UII and UDB, the SES Reports were prepared by the examiners-in-charge
        Aurora Inumerable and Dominador Migue, respectively. See Paragraphs 5, 7 & 11 of Guerrero’s

2.      No conference with UBI, UDB nor UII was conducted by BSP. Under the Manual of Examination
        Procedures, the required due process would have enabled UBI, UDB and UII to reply to SES findings.
        (In the case of the four banks cited by Reyes and Aure, BSP held such conferences as indicated in their
        SES reports.)

3.      BSP did not provide UBI, UDB nor UII with a summary of the SES findings/violations. The SES
        Reports were given five (5) months after, and only upon demand by complainant’s counsel. Under the
        Manual of Examination Procedures, such summary or report should have been provided to the
        institutions. (In the case of the four banks cited by Reyes and Aure, these banks were informed of the
        findings as indicated in their SES reports.)

4.      BSP did not give any time or opportunity to UBI, UDB and UII to take action to correct any
        deficiencies. Under the Manual of Examination Procedures, a summary of findings/violations is provided
        precisely “so that corrective action may be taken by them as soon as possible”. By recommending
        immediate closure, respondents shut-out any possibility for the institutions’ shareholders and
        management to work-out any remedies. (In the case of the four banks cited by Reyes and Aure, the banks
        were given several months to take corrective action as indicated in their SES reports.)

        It is impossible for respondents to ignore the Central Bank Manual. As experienced officers of BSP with
long years of bank examination to boot, it devolved upon each of the respondents to ensure that the rules therein
are observed.


       In the related case no. OMB-0-01-0089 Defensor vs Buenaventura, the counter-affidavit of Antonio M.
Brotonel (Annex “G”) was submitted. Brotonel, who was Manager of Division 2 under Aure’s Department of
Commercial Banks II Counter-Affidavit, stated:

                 "I had no difficulty of preparing the financial data and gathering other information about UBI
                 on April 25, 2000 considering that Division 2 had already the available financial data as of
                 April 18, 2000 which was submitted by Mr. Aure Jr. to the Deputy Governor, Supervision and
                 Examination Sector, so that it only requires updating the financial position of the UBI from
                 April 18 to April 25, 2000. Besides, the Report of Examination of Urban Bank as of March
                 31, 1999 was already finished.
                                    xxx                         xxx                        xxx

                 "As a matter of fact the source of financial data and reports were picked up or taken from

                  various reports submitted by UBI to BSP as shown in the matrix of the source documents
                  supporting the memorandum to the MB on April 26, 2000 and copy of which is hereto
                  attached as Annex “2”…

          The Annex “2” that Brotonel attached to his affidavit is a document entitled:

                                         URBAN BANK, INCORPORATED
                                     MEMORANDUM TO THE MONETARY BOARD
                                                April 26, 2000

       Said document contained a list or “matrix of source documents supporting the memorandum to the MB
on April 26, 2000”. It listed the source documents supposedly annexed to the SES memorandum (report) on

        However, the annexes enumerated in Brotonel’s matrix are inconsistent or not the same as the annexes
actually attached to the SES report on UBI, as summarized in a comparative table below:

  Annex letter                      Annex document                                Document actually annexed to
   assigned                       per Brotonel’s matrix                               SES Report on UBI

Annex A             Letter of Urban Bank-List of Urban branches          Adjusted Capital Position- Jan, Feb, Mar 2000

Annex B             Manual of regulations Sec X106 bank capital;         Compliance with Reserve Requirements on
                    Urban’s consolidated statement of condition Jan,     Deposit Liabilities, Feb 3 to Apr 19 2000
                    Feb, Mar 2000; Urban’s report on compliance
                    with loan loss provision Jan, Feb, Mar 2000;
                    BSP’s report of examination Mar 31 1999; MB
                    resolution 256, Feb 16 2000 allowing URDI
                    earnings as part of capital

Annex C                                                                  Large Loan Accounts as of Latest Regular
                                                                         Examination, Mar 31 1999

Annex C & D         BSP’s report on interbank loan transactions Jan,
                    Feb, Mar 2000; Urban’s onsolidated daily report of
                    condition Jan-Apr 2000; BSP’s printout statement
                    of account showing overdraft, runtime Apr 26
                    2000 08:40:48.

Annex D             BSP’s statement of overdrawings                      Liquid Assets- Feb, Mar 2000

Annex E             BSP’s status of loan portfolio Dec, Jan, Feb2000     Top 20 Stockholders, Dec 31 1999

Annex E-1                                                                Senior Officers & Members of the Board of
                                                                         Directors, Dec 31 1999

Annex F             Details of classified accounts per BSP’s exam
                    report Mar 31 1999; Urban’s report on credit and
                    equities exposure P1-million-up Dec 31 1999;
                    Urban’s consolidated statement of condition Dec
                    31 1999

Annex G             Urban’s deposits insured by PDIC Feb 29 2000;
                    Urban’s CDRC Jan-Mar 2000

Annex H             Urban’s CSOC Feb, Mar 2000

Annex I             Urban’s CSOC Feb 2000

Annex J             New Central Bank Act Sec 30 proceedings in
                    receivership and liquidation

Unmarked                                                                 Urban’s letter to BSP on bank holiday; BSP’s
                                                                         letter to PDIC placing UDB under receivership;
                                                                         Zuniga’s legal opinion

        Given the inconsistencies, it appears that the SES Report was altered or substituted. In addition,
Brotonel’s affidavit establishes the fact that certain documents, hereunder identified, were accessed by and made
part of the diligence effort by respondents in preparing the SES Report on UBI. Inspite of respondents’
possession of vital information contained in these documents AT THE TIME that the Report was being
prepared, reviewed, signed and accepted, respondents omitted such information that would counter their
findings in the SES Report on UBI:

1.      BSP’s Manual of Regulations Sec X106 on bank capital would show that UBI, as a publicly-listed bank,
        would have six (6) more months to meet the increased minimum capital of P2.4 billion.

2.      UBI’s Report on Compliance with Loan Loss Provision as of March 2000 would show that UBI provided
        enormous loan-loss reserves to meet the possible losses from a higher past-due ratio.

3.      BSP’s Report on Interbank Loan Transactions for January 2000 would show UBI had substantial liquidity
        evident from its large consistent interbank lending activities during the month. BSP’s Report for March
        2000 would show that UBI still managed to lend on certain days during the month.

                OF  ACCOUNT    WILL     PROVE   YUVIENCO’S     DECEPTION

        In her Counter-Affidavit (Paragraphs 16-17), respondent Yuvienco claimed that three (3) of UBI’s
Statements of Account (Annexes F-4, F-5 and F-6) provided in the Complaint were “altered and falsified”
because they did not “bear the three asterisks (***) which follows the transaction in every ledger abstract sent
out indicating the end of the document”. These three statements were dated 4/26/00 1:59PM, 4/26/00 6:37PM,
and 4/25/00 4:56PM, respectively.

        The attention of the Honorable Ombudman is called that there were twenty (20) Statements of Account,
received from 17 to 27 April 2000, that were annexed to the Complaint. It should be questionable that, of the
several statements without the (***) asterisks, respondent Yuvienco selected only three to have been falsified.
Additionally, this Honorable Office is invited to subpoena the ENTIRE similar Statements of Account on file with
UBI for the whole year 1999 and 2000. They should number over 400 statements including the 20 statements in
the Complaint, and will show the numerous statements without the (***) asterisks.

        It may be noted that all these statements, including the 20 statements in the Complaint, are print-outs of
electronic mail, as ACTUALLY received by UBI’s PC-terminal.. Statements are received, over dial-up
telephone lines, from BSP’s PC-server that employs “Lotus cc:Mail” software application. What were actually
sent and received would therefore be contained as mail-formats in the electronic storage of these two PC’s.

                IT MET ON APRIL 26 2000.

        The first page of the SES Report on UDB made reference to UDB’s letter dated 26 April 2000 and
attached as “Annex A” to said Report. However, BSP received said letter at its Roxas Boulevard offices at
exactly 10:18am, as evidenced by BSP’s own receiving time-stamp on the letter (Annex “H” hereof).
Respondents therefore could have prepared the Report after 10:18AM, signed and delivered it to Manila Golf
Club in Forbes Park, Makati, by which time the Monetary Board meeting would have already been adjourned.

         In his Counter-Affidavit (Paragraphs 9-13), respondent Guerrero stated that he had received the letter
earlier by fax “at exactly 8:46AM” of 26 April 2000, and it was therefore the fax that Guerrero annexed to the

                “On the same morning, at exactly 8:46AM, I received a faxed letter dated April 26, 2000 from
                Ms. Phebe F. Cabildo, President of UDB, informing BSP that UDB had also decided to
                declare a bank holiday on the same day… I forwarded the faxed letter to Ms. Mandapat, who
                called the Deputy Governor over the telephone to advise him of the same… Thereafter, Ms.
                Mandapat instructed Mr. Migue to prepare a Memorandum on UDB… At about 9:30AM of
                April 26, 2000, the original and a duplicate copy of the Memorandum on UDB were also
                 placed in a sealed envelope and personally delivered by Mr. Migue to Ms. Haboc of the office
                 of the Deputy Governor, who turned over said envelope to Mr. Ahorro for delivery to Deputy
                 Governor Reyes at the Manila Golf Club at Makati City.”

        The truth is that no such fax was sent by UDB nor UBI. SIX (6) VITAL PIECES OF EVIDENCE,
herewith attached, prove the non-existence of the alleged fax and the PERJURY of respondent Guerrero:

1.      The sworn affidavit of Atty. Justina Callangan, UDB’s corporate secretary, who stated that she signed the
        letter at almost 10:00AM. Therefore it is impossible for respondents to have received a 8:46AM fax of
        UDB’s letter bearing her signature (Annex “I” hereof)

2.      The sworn affidavit of Atty. Corazon Bejasa, UBI’s Legal Head, who stated that she prepared and
        initialed said letter at about 9:30am before forwarding it to Callangan for her signature. Likewise, it is
        impossible for respondents to have received a 8:46AM fax of UDB’s letter bearing her initial (Annex
        “J” hereof).

3.      The sworn affidavit of Mr. Prudeno Natividad, UBI’s Systems Head, who described several technical
        details and facts such as, among others, that all fax machines of UBI and “URBANBANKFAXCENTER”
        imprint their fax headers (consisting of sender’s information) only on top of the transmitted document,
        and not at the bottom (Annex “K” hereof).

4.      The physical evidence of the 8:46AM fax itself, submitted by respondents in Case no. OMB-0-01-0089
        (Defensor vs Buenaventura). Six (6) unique markings on the fax’s face prove that said markings were not
        made under an authentic fax transmission (Annex “L” with markings for visual aid):

        a. There are two fax headers, one on top and one at the bottom.

        b. There are two different times: The time in the top header was “09:00”; the bottom header was
           “08:46”. (Worse for respondents, it was the bottom time that Guerrero stated in his counter-affidavit
           that he allegedly received the fax.)

        c. The sender’s name “URBANBANKFAXCENTER” was imprinted in the top header; however the
           sender’s number “8879900” was imprinted in the bottom header.

        d. The top and bottom headers are not parallel to each other.

        e. The vertical fax markings appear to be perpendicular to the bottom header but not to the top header.

        f.   There is a distinct 90-degree corner created by the “fax markings” in the upper left-hand of the fax..

5.      The physical evidence of an authentic fax from URBANBANKFAXCENTER, unwittingly submitted by
        respondents for comparison in the aforementioned case. Said authentic fax contained physical features
        absent in the 8:46AM fax, further proving that said 8:46AM fax was indeed fabricated. Moreover, the
        authentic fax was consistent with the technical information in Natividad’s affidavit (Annex “M” hereof
        with markings for visual aid):

        a. There was only one fax header, and it was the top header.

        b. The sender’s number “8879900” was imprinted in the top header and therefore would not have been
           printed twice or elsewhere in the fax, much less in the bottom header.

6.      The physical evidence of the “Annex A” document which was marked as such by respondents and
        actually annexed to the SES Report on UDB (Annex J of Complaint). Said SES Annex was not the
        8:46AM fax, but rather the original-received copy of UDB’s letter, which respondents received at 10:18
        A.M (Annex “N”, with markings for visual aid)

       The above evidence have been submitted before the Honorable Ombudsman in Case no. OMB-0-01-
0614, Tabios vs. Buenaventura et al, for falsification and perjury.

        The above evidence establish more than probable cause that Guerrero perjured himself regarding the
existence of the fax. Indeed, if the fax never existed, then the SES Report could not have been made before
10:18AM and delivered in time for the Monetary Board meeting that convened at the Manila Golf Club at
10:45AM. Respondents clearly falsified the Report to make it appear that it existed, when in fact it did not, at the
time that the Monetary Board met.


        In its Order of 2 July 2002, the Honorable Office stated:

                  “It may well be added that the actions taken by the Monetary Board in receivership and
        liquidation proceedings as in the instant case is final and executory and may not be restrained or set
        aside by the court much more by this Office, except on petition for certiorari on the ground that the
        action taken was in excess of jurisdiction or with grave abuse of discretion amounting to lack or excess
        of jurisdiction xxx

                  “Consequently, the Monetary Board including herein respondent Buenaventura cannot be
        faulted to come up with a decision for the closure of UBI as embodied in the questioned Resolution
        No. 634. This is because all heads of offices have to rely to a reasonable extent on their subordinates,
        and on the good faith of those who prepare the reports for the formers’ consideration as in this case
        (citations omitted)

                 “As in the case of respondent Zuniga Jr., BSP’s General Counsel, we find his legal opinion in
        order as it is merely an opinion which may be reversed or be the subject of an attack. Absent therefore
        any proven bad faith on his part in rendering the same, we cannot hold him administratively liable

        With all due respect, the Complaint against Buenaventura and Zuñiga should not have been dismissed.


         The Honorable Ombudsman dismissed the Complaint against respondent Buenaventura, ruling “the
Monetary Board including the herein respondent Buenaventura cannot be faulted to come up with a decision for
the closure of UBI as embodied in the questioned Resolution No. 634. This is because all heads of offices have to
rely to a reasonable extent on their subordinates, and on the good faith of those who prepare the reports for the
formers’ consideration as in this case.”

        Complainant takes exception to the foregoing findings of this Office.

         Firstly, Buenaventura stated in his Counter-Affidavit (Paragraph 2.3.2): “The truth of the matter is that
Urban Bank, prior to its closure, has been subject of the Bangko Sentral’s attention in several instances”. In
Paragraph 2.3.3, Buenaventura went on to enumerate several events before UBI’s closure that involved himself
personally or had his personal knowledge. Buenaventura also admitted in Paragraph 2.3.3.i that UBI’s letter
declaring a bank holiday “was prepared right then and there and was signed by Borlongan” in Buenaventura’s
office in the afternoon of 25 April 2000.

        The fact is, as stated in the Complaint (Paragraph 6):

                  “UBI Chairman Arsenio M. Bartolome III and I went to see respondent Buenaventura in his office
        at the BSP to pre-clear the probability of UBI declaring a bank holiday…Respondent Buenaventura
        directed me to submit to him a letter formalizing UBI’s intention of declaring a bank holiday. Respondent
        Reyes was in Buenaventura’s office and he prepared a draft. I edited his draft by adding the last paragraph
        stating that UBI’s declaration of a bank holiday would be subject to the approval of its board. Respondent
        Reyes instructed Buenaventura’s secretary (Val Parungo) to call my secretary to send him a copy of my
        UBI stationary by fax. When the fax came in, it was machine copied on plain paper and Reyes’ draft was
        typed therein. I then signed the letter.

        After that meeting in Buenaventura’s office, it could only have been Buenaventura who immediately
called for a special meeting of the Monetary Board to convene the next morning. It could only have been
Buenaventura who instructed the SES to rush the preparation of the Reports on UBI, UDB and UII, in time for
said meeting.

        The attention of the Honorable Ombudsman is called to the same Section 16 of R.A.7653 that does not
exempt the BSP governor from the requirement of extraordinary diligence. Be it noted that all officers of the BSP
are enjoined to observe this measure of diligence. As the officer who holds the supreme authority in BSP,
Buenaventura was likewise under a duty to observe extraordinary diligence in the discharge of his functions.
Buenaventura himself would know, for example, BSP Circular No. 156 and the Central Bank Manual of
Examination Procedures. Yet, he purposely neglected and disregarded BSP’s own rules, caused the reckless and
rush preparation of the Reports that likely would have been prepared without the required diligence.

        Consequently, it was error for this Office to exculpate Buenaventura from any liability, either directly or
through his subordinates.

                 B.   THE HONORABLE COMBUDSMAN GROSSLY ERRED                                            IN

       In dismissing the Complaint against respondent Zuñiga, the Honorable Ombudsman grossly erred, ruling
absence of bad faith on his part. Said ruling conflicts with the provisions of the New Central Bank Act.

        Section 4(b) thereof requires public officials to “perform and discharge their duties with the highest
degree of excellence, professionalism, intelligence and skill”. Furthermore, Section 16 requires BSP officials to
“exercise extraordinary diligence in the performance of their duties”.

       Though evidence of bad faith may be in question, competence and diligence were certainly lacking in
Zuniga’s official act of issuing his Legal Opinion.

        In his Counter-Affidavit, Zuñiga stated (Paragraph 28.3):

                 “In the present case, I prepared the requested Legal Opinion with utmost care and diligence,
        basing it on my knowledge and research of the relevant law and jurisprudence, as well as on my longtime
        experience of working in the banking industry.

                  “I was presented with the question of whether or not the declaration by a bank of a ‘bank holiday’
        is sufficient to order the closure of said bank and place it under receivership.” (Underscoring supplied)

        In his Counter-Affidavit in the related case (OMB-0-01-0089, Defensor vs. Buenaventura), Zuñiga further
stated, “said Legal Opinion was neither ‘unprecedented’ nor ‘reckless’. Yet Zuniga conveniently fails to
specify any precedence, jurisprudence, or historical event from his long-time banking experience, to
support his Legal Opinion. The fact is, there is no precedent, jurisprudence or historical event because
UBI, with UDB, were the first banks in the 52 years of Philippine banking that was ever ordered closed for
reason of only illiquidity.

        Zuñiga’s claim of using utmost care and diligence based on his knowledge and research of law and
jurisprudence is repudiated by his own statements.

        In a congressional hearing investigating into UBI’s closure and conducted by the House Committee on
Good Government on 6 December 2000, Zuniga was asked, “In the Bangko Filipino case, and I’m sure you are
familiar with it, the Bangko Filipino. Have you gone through the Supreme Court decision?” Zuñiga replied, “I
have not gone through with that. I read it but I cannot recall all the specific, the specific rulings there, your

       Banco Filipino is perhaps the most celebrated case in banking jurisprudence. Yet, the General Counsel of
the BSP presented himself ignorant about this landmark decision by the Supreme Court, because his Legal
Opinion would verily contradict this well-known ruling.

         As mentioned and supported in the Complaint, Banco Filipino declared a bank holiday on 23 July 1984
because of continuing withdrawals and even after availing a P119.2 million emergency loan from the Central
Bank. However, it was not ordered closed but was allowed to re-open under conservatorship one month after,
with an additional P3-billion credit line. It was ordered closed only on 25 January 1985, on the basis of an SES
report finding the bank to be insolvent. In 1991, the Supreme Court ruled that the Monetary Board order was
illegal, because the SES report, which took many pages and six (6) months diligence to finish, was still

        Clearly, this was not in keeping with the mandate of extraordinary diligence or even competence. If the
dismissal of the Complaint against Zuñiga were sustained, prejudice would inure to the general public and
complainant, who are in effect, left without any administrative remedy.

        It was therefore error for the Honorable Ombudsman to dismiss the Complaint against Zuñiga.

                      REYES, YUVIENCO, GUERRERO AND AURE.

        In the Order dated July 2, 2002, this Honorable Office found:

                  “…we find that the Supervision and Examination Sector Report rendered by respondents Reyes,
        Yuvienco, Aure and Guerrero and which became the bases for the closure of UBI and UDB were
        haphazardly and negligently done. xxx For these reasons, we hold herein respondents Reyes, Yuvienco,
        Aure, Jr., and Guerrero administratively liable for Simple Neglect of Duty.” (Order, Page 7)

        First, they must exercise extraordinary diligence in the performance of their duties, as officers of the
Bangko Sentral ng Pilipinas. Respondents cannot therefore be held liable for mere “simple neglect of duty”.
Section 16 of Republic Act No. 7653 (New Central Bank Act) is clear on the responsibility of BSP officials.

                 “Sec. 16. Responsibility. - Members of the Monetary Board, officials, examiners, and employees
        of the Bangko Sentral who willfully violate this Act or who are guilty of negligence, abuses, or acts of
        malfeasance or misfeasance or fail to exercise extraordinary diligence in the performance of his duties shall
        be held liable for any loss or injury suffered by the Bangko Sentral or other banking institutions as a result
        of such violation, negligence, abuse, malfeasance, misfeasance or failure to exercise extraordinary

         Secondly, the BSP is the ONLY government entity that is REQUIRED BY LAW to exercise
extraordinary diligence. Such extraordinary diligence is demanded because of the immenseness of its powers,
such as recommending and ordering the closure of a bank. How else could much mandate be ever realized without
making a finding of failure to exercise extraordinary diligence in the performance of duty? That would be
backtracking and corrupting said mandate at the risk of a repetition of similar incidents.

         Third, respondents’ “neglect of duty” pertained to the preparation of official reports recommending the
closure of three (3) separate institutions. Recommending the closure of a bank is a far graver and more serious
act, than perhaps recommending the approval or disapproval of a bank branch. This office should consider the
grave consequences of respondents’ acts. Nowhere in the Order had the Honorable Ombudsman sufficiently
addressed this.

        Fourth, neglect of duty cannot be simple, if they were manifested in not one, but three different SES
reports. The three different reports, which can be considered three counts of neglect of duty, were all done by
respondents and led to the closure of three different institutions.

        More importantly, the reports did not merely contain incorrect and inaccurate statements. They were
grossly erroneous because all of the financial bases in recommending the closure were false. They were
obviously done with malice, evident bad faith and irregularity.

        At this juncture, it bears emphasis that the Complaint does not particularly assail the decision of the
Monetary Board; rather, it specifically assails the falsification of the SES Reports that they contained false
statements to justify their recommendation of closure, and on the falsification of the same SES Reports that they
were falsely made to appear that they existed at the time that the Monetary Board ordered the closure, to comply
with Section 30 of RA 7653.

III.    THERE         WERE        PROCEDURAL

       In his Order dated 13 July 2001, the Honorable Ombudsman Aniano A. Desierto disapproved the
proposed order dated 23 March 2001 of the Administrative Adjudication Bureau (AAB) and directed it “to
proceed with the administrative investigation of the subject case”. Although directed to file their respective
counter-affidavits within ten (10) days from receipt of the Notice, respondents did not do so.

        In an Order dated 10 September 2001, this Honorable Office ordered the parties to appear for a
Preliminary Conference on 25 September 2001, “pursuant to Section 5, Rule III of the Rules of Procedure of the
Office of the Ombudsman”. Said Order found “sufficient cause to warrant further proceedings.”

         In said conference, respondents’ counsels claimed that their clients did not receive copies of the
Complaint-Affidavit although records show otherwise. Counsels’ requests for time to file supplemental
complaint and counter-affidavits were nonetheless granted by the hearing officer with the understanding that a
conference or hearing would then be conducted after all of the pleadings shall have been filed by the

        Section 5, Rule III of the Rules of Procedure of the Office of the Ombudsman (Administrative Order No.
7) provides:

                 “Section 5. Administrative adjudication; How conducted.
                                                xxx                xxx               xxx
                 “b)       If, on the basis of the affidavits and other evidences submitted by the parties, the
                 investigating officer finds no sufficient cause to warrant further proceedings, the complaint may be
                 dismissed. Otherwise he shall summon the parties to a preliminary conference to consider the
                 following matters xxx

                 “c)      After the preliminary conference, the investigating officer shall issue an order reciting the
                 matters taken up during the conference including the facts stipulated, the evidences marked and
                 the issues involved. The contents of this order may not be deviated from unless amended to
                 prevent manifest injustice xxx.”

         Obviously, the purpose for which the Preliminary Conference was called on 25 September 2001 was not
met, since the conference was merely adjourned to give the parties the opportunity to prepare and submit their
pleadings and evidence. In fact, complainant has not even filed a reply-affidavit to the respondents’ Counter-
Affidavits since he was waiting for an order for the resumption of the conference or hearing, or for an order to
file the reply-affidavit. Complainant was not given an opportunity to reply to the respondents’ counter-affidavits,
whether in a conference or hearing or in a reply-affidavit. Be it noted that by no stretch of interpretation can the
inability of complainant to file a reply-affidavit be indicative of an intention to waive the right to file it. In fact,
complainant has and had every intention to file such reply-affidavit.

         There were serious errors of law committed by this Office, which if not corrected, would be prejudicial to
the complainant and the public. A summary determination of a waiver of the right to file a reply-affidavit hardly
does justice to complainant and the general public, given the impact, importance and magnitude of the case. What
is dealt here after all is the integrity of public officers, mandated by law to observe extraordinary diligence in the
conduct of their responsibilities, fairness, justice and honesty.


        WHEREFORE, it is respectfully prayed of this Honorable Office that the Order dated 2 July 2002 be
reconsidered in that:

        TOMAS S. AURE, be found guilty of GROSS NEGLECT OF DUTY, for violation of Section 4,
        Republic Act No. 6713 and in furtherance of Section 16 of Republic Act No. 7653 (New Central Bank
        Act), for which they should be liable for the maximum penalty provided under Section 25, Republic Act
        No. 6770; and

2.      Respondents RAFAEL B. BUENAVENTURA and JUAN DE ZUÑIGA, JR. be found guilty for
        violation of Section 4, Republic Act No. 6713 and in furtherance of Section 16 of Republic Act No. 7653,
        for which they should be liable for the maximum penalty provided under Section 25, Republic Act No.

        Such other relief and remedy are likewise prayed for.

        Pasig City for Manila. 16 July 2002.

                                                    CHATO & ELEAZAR
                                                    Counsel for Complainant
                                          8th Floor Strata 2000 Bldg., Emerald Avenue
                                                    Ortigas Center, Pasig City

                                                     WILFREDO M. CHATO
                                                 PTR No. 0831620/1-09-02/Pasig City
                                                 IBP No. 549461/1-09-02/Makati City

                                                      GERARDO J. DE LEON
                                                 PTR No. 0831625/1-09-02/Pasig City
                                                  IBP No. 549466/1-09-02/Pasig City

Copy furnished:

Counsel for Respondents Alberto V. Reyes and
Tomas S. Aure, Jr.
7/F Strata 2000 Bldg.
Emerald Avenue, Ortigas Centre
Pasig City

Counsel for Respondents Juan de Zuniga, Jr. and
Candon B. Guerrero
4/F Cacho-Gonzales Bldg.
101 Aguirre Street, Legaspi Village
Makati City

Counsel for Respondent Ma. Dolores B. Yuvienco
Rm. 518-A Five Storey Executive Bldg.
Bangko Sentral ng Pilipinas

Counsel for Respondent Rafael B. Buenaventura
Romulo Mabanta Law Offices
30th Flr., Citibank Tower
Citibank Plaza, 8741 Paseo de Roxas
Makati City


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