REPUBLIC OF THE PHILIPPINES)

CITY OF GENERAL SANTOS )S.S.

x-------------------------x

JOINT AFFIDAVIT-COMPLAINT
(With Verification and Certificationof Non-Forum Shopping)

We, BIMBO LAVADOR andRENELYN J. LAVADOR, both Filipino, of

legal age, husband and wife, respectively and residents of
__________________________________, General Santos City, after being duly
sworn in accordance to in accordance with law, do hereby depose and say that:

1. We are the parents of FRANCES AIZELLE LAVADOR (AIZELLE for

short), 9 years old and a Grade 4 student of the Holy Trinity College (HTC),
General Santos City;

2. Our daughter AIZELLE is a Taekwondo player where she participates

in various competitions under a Poomsea (Forms) Event (Poomseafor short), an
event in taekwondo which requires different skill level;

3. Sometime on February 17-22, 2018, Socksargen Regional Athletic

Association Meet (SRAA) was slated and held at the Gaisano Mall of Marbel,
Koronadal City;

4. Thus, on February 20, 2018, AIZELLE participated in such Poomsea

Competition at Gaisano Mall of Marbel, Koronadal City whereshe wontwo (2)
Gold Medals in Mixed Pair Poomsea and Team Poomsea, respectively;

5. During the awarding ceremony on that same date (February 20, 2018),
AIZELLE wondered why her name was not included in the announcement
among the participants who qualified and represent for theupcoming 2018
Palarong Pambansa;

6. As AIZELLE could not believe what she has heard in the

announcement, she immediately approached Ms. Theresa Rosaot (Ms. Rosaot), a
teacher and Secretariat of the Poomsea event and inquired from her (Ms. Rosaot)
saying” Ma’am, nadala po ba ako sa Palarong Pambansa? (Ma’am, will I be
included in the Palarong Pambansa?) Ms. Rosaot replied “Oo nadala ka.” (Yes, you
are included.)

7. To confirm the matter if she (AIZELLE) was really included in the 2018
Palarong Pambansa, she approached Mr. Porferio M. Tripoli (Mr. Tripoli for
short), the Tournament Manager of the Poomsea event and inquired saying: “Sir,
nadala po ba ako sa Palaro?” (“Sir, am I included in the Palaro?”) Mr. Tripoli
replied: “Wala ka nakuha, hindi ka kasali.”(“You are not chosen, you are not
included.”)

8. Mr. Tripoli explained several things to AIZELLE but our daughter

hardly understood the matter;

9. I (Renelyn J. Lavador) was surprised as AIZELLEran towards my

directionand cried hysterically;

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 10. Confused of what has happened to my daughter AIZELLE, I (Renelyn
J. Labrador) told her to keep calm and I started asking her what happened;

11. While crying, AIZELLE slowly narratedto me (Renelyn J. Labrador)

what had happened and she told me(Renelyn J. Labrador) that she felt bad about
the announcement that she was not included in the upcoming 2018 Palarong
Pambansa;

12. Being AIZELLE’s mother (Renelyn J. Lavador), I immediately

confronted one of the male organizers (whom I do not know the name) but I was
not able to understand his explanation;

13. Mr. Tripoli then approached me (Renelyn J. Lavador) and explained

the matter;

14. However, I (Renelyn J. Lavador) asked Mr. Tripoli if he has a copy of

the Guidelines of the Event and the Guidelines for their selection;

15. Mr. Tripoli replied to me saying: “Mag draft pa ako Ma’am” (“I have
yet to draft the guidelines Ma’am”);

16. I (Renelyn J. Lavador) could not believe what Mr. Tripoli said and I
was not satisfied of his (Mr. Tripoli) explanation;

17. I then turn to my daughter AIZELLE to comfort her as she was still
crying; she was so emotionally and psychologically affected by the decision of
Mr. Tripoli because she was not included in the 2018 Palarong Pambansa despite
the two (2) Gold Medalsshe won in Mixed Pair Poomsea and Team Poomsea in
the recently concluded Poomsea (or SRAA) Competition at Gaisano Mall of
Marbel, Koronadal CityFebruary 17-22, 2018;

18. It bears stressing to note that Mr. Tripoli did then and there
singlehandedlyexercised partialityin a despotic manner decided to select
participants for the 2018 Palarong Pambansa without using any guidelines (of
the event and for the selection) as during that particular time (February 20, 2018)
he (Mr. Tripoli) was not able to show to me (Renelyn J. Lavador) the
guidelineswhen I asked him (Mr. Tripoli) about the guidelines of such event and
themeans and method (or criteria) of his selection of the players;

19. Obviously, Mr. Tripoli has gravely abused his authority being the
Tournament Manager in selecting participants to the Palarong Pambansa to the
damage and prejudice of our daughter, AIZELLE;

20. Being the Tournament Manager, Mr. Tripoli gravely abuse hispower
and authorityby doing such an unfair and unjustact in the selection ofPoomsea
participants for the 2018 Palarong Pambansawhich caused our daughter
AIZELLE to suffer sleepless nights, besmirch reputation and wounded feelings,
without due regard to the state’s policy onthe paramount interest of the
child/youthparticularly on the aspect of physical, emotional and psychological
growth, development and well-being in relation to sports;

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 21. It is important to note that Mr. Tripoli made a report/endorsementvia
a letter addressed to the Regional Director of DepEd-Region 12 regarding the
selection of athletes only on February 21, 2018,the day afterthe announcement of
those who qualified to participate in the upcoming 2018 Palarong Pambansa; and
worse, it was publicly announced; a copy of the Letter Report/Endorsement of
Mr. Tripoli to the Regional Director is hereto attached as Annex “A” to form part
hereof;

22. In his report, and of emphasis to note,Mr. Tripoli did not take into
consideration the event of Poomsae held in the recently concluded SRAA
Competition in Koronadal City last February 20, 2018 where AIZELLE won two
(2) Gold Medals for Team Poomsae and Mix Pair Poomsae, respectivelywhile
Margaret Jill Saulon has only won one (1) Gold and one (1) Silver in the SRAA
Competition;

23. Mr. Tripoli (being the Tournament Manager)made as basis in his

selection of athletes for the upcoming 2018 Palarong Pambansa was the
participation of AIZELLE vis-à-vis the participation of a certain Margaret Jill
Saulon only in the year 2017 (as indicated in 2nd Page, Annex “A” hereof), to wit:

“Here’s the brief track record of the two contesting players (vying to fill-in
the final slot) in poomsea event (Elementary-Girls):

“*SAULON, MARGARET JILL – National Poomsae

Champion-2017
National Poomsae
Championship, Manila
Unbeaten Regional
Poomsae Champion-
R12A PTA
Gold Medalist-GSCAA
Dual Meet 2017 Group B

“*LAVADOR, Aizelle - Silver Medalist-GSCAA Dual

Meet – Group A
Regional Poomsae Medalist
Alternate Poomsae Player
(Mixed/TeamPoomsae-
GenSan team)

“We, the TKD-SRAA selection committee would STRONGLY

recommend without personal biases that the one we have identified
is someone who has the highest probability of earning medals in
the forthcoming 2018 Palarong Pambansa and we are seeking for
your affirmation.”(Emphasis supplied)

24. This is a clear badge of unfairness and injusticeon the part of Mr.
Tripoli in the selection of athlete for the upcoming 2018 Palarong Pambansa;

25. Further, Mr. Tripoli inhis letter dated February 24, 2018 addressed to
Dr. Magdaleno C. Dujilag, Jr., Regional Sports Officer/RPESS, Region 12,
submitted an Official list of Recommended/Selected Athletes of Taekwondo
Event for 2018 Palarong Pambansa in Vigan City, Ilocos Sur and it appears in the
2nd/last page denominated as “Note:” states that: [B]asis of the selection

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committee in selecting/recommending the THIRD Member (Poomsae Event) to
complete the team poomsae is not necessarily the gold medal earned during the
regional meet, but at least 2nd best performer in the regular Group A or Group B
regular poomsae slot…”; a copy of such letter is hereto attached as Annex “B” to
form part hereof;

26. Mr. Tripoli’s letter (Annex “B” hereof) is in conflict with the Ground
Rules (Approved Taekwondo Competition Ground Rules attached as Annex “C”
hereof) which he prepared particularly in E (3) and the “Note” which state:

“E. AWARDS FOR THE POOMSEA EVENT

“xxx

“3. Mixed Pair Poomsea:

“Winning contestants in the individual Poomsae categories

shall be awarded the following medals.

“First Place – Gold Medal (2 Gold)

“Second Place - Silver Medal (2 Silver)
“Third Place - Bronze Medal(2 Bronze)

“Note: Medal tally for mixed pair will be recorded in the girls
division. WINNERS IN CATEGORY A AND CATEGORY B.
WILL ADVANCE IN THE HIGHER MEET, WINNING TEAM
(THE MOST NUMBER OF GOLD MEDALS) WILL DETERMINE
THE THIRD MEMBER OF THE TEAM IN THE NEXT HIGHER
MEET” (Emphasis supplied)

27. Noteworthy also is the fact that the said ground rules has not been
taken into consideration by Mr. Tripoli in the selection of best athletes for the
2018 Palarong Pambansa;

28. Mr. Tripoli instead submitted his own absurd and unreasonable
Official list of Recommended/Selected Athletes of Taekwondo Event for 2018
Palarong Pambansa in Vigan City, Ilocos Sur to Dr. Magdaleno C. Dujilag, Jr.,
Regional Sports Officer/RPESS, Region 12 as indicated in Annex “B” hereof.

29. We also referred this matter to Dr. Arturo B. Bayocot via our letters
dated February 21, 2018 and March 09, 2018, hereto attached as Annexes “D”
and “E”, respectively.

30. As such, Mr. Tripolihas violated Section 4 (c) of Republic Act No.
67131, Section 10 of Republic Act 7610, Article 3 (3) (2nd paragraph)2 and
Presidential Decree No. 603.

31. In view of the foregoing statements, we execute this joint affidavit-

complaint to institutecriminal charges against Mr. Porferio Tripoli for violations
of Section 4 (c) of Republic Act No. 67133, Section 10 of Republic Act 7610, Article

1
Code of Conduct and Ethical Standards for Public Officials and Employees.
2
The gifted child shall be given opportunity and encouragement to develop his special talents.
3
Code of Conduct and Ethical Standards for Public Officials and Employees.

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3 (3) (2nd paragraph)4and Presidential Decree No. 603; and for administrative
charges of Grave Misconduct, Conduct Prejudicial To The Best Interest of The
Service, Serious Dishonesty, Falsification of Records and other appropriate and
relevant charges against him (Mr. Tripoli).

32. We are the complainants in this case; we have caused the preparation
of this joint affidavit complaint; we have read the contents thereof; and the
allegations stated herein are true and correct of our knowledge and/or on the
basis of copies of documents and records in our possesson; and we hereby certify
that we have not commenced any other action or proceeding in the different
divisions or any agency of the government involving the same issues raised in
this affidavit complaint; that should we thereafter learn that a similar action or
proceedings is pending in the said tribunal or agency, we undertake to report
such fact within five (5) days to the aforesaid tribunal or agency.

IN WITNESS WHEREOF, I have hereunto affixed my signature this

___day of March 2018 at General Santos City, Philippines.

BIMBO LAVADOR RENELYN J. LAVADOR

Affiant Affiant

SUBSCRIBED AND SWORN to before me this _____day of March 2018

at General Santos City, Philippines. I hereby certify that I have examined the
affiants and I am satisfied that they have voluntarily executed, read and
understood their joint affidavit-complaint.

4
The gifted child shall be given opportunity and encouragement to develop his special talents.

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