Republic of the Philippines

DEPARTMENT OF JUSTICE
MANILA

CHARLENE B. CONCEPCION,
Petitioner
Case No: _____________
For: Makati Mayor Jejomar
Erwin Binay Jr.
Suspension from office
-versusJEJOMAR ERWIN BINAY JR.,
Respondent
x-----------------------------------------x

PETITION FOR SUSPENSION

COMES NOW Petitioner CHARLENE B. CONCEPCION, unto this

Honorable Office, most respectively avers that:

NATURE OF THE PETITION

1. The present petition is a Petition for Suspension from office of the

Mayor Jejomar Erwin Binay Jr.

2. Thus, this petition seeks for suspension of the respondent as the

Mayor of Makati City upon the provision of the Republic Act 3019
stating:
Section 1. Statement of policy. It is the policy of the
Philippine Government, in line with the principle that a
public office is a public trust, to repress certain acts of
public officers and private persons alike which
constitute graft or corrupt practices or which may lead
thereto.

THE PARTIES

3. Petitioner Charlene B. Concepcion of legal age, single and with

residence at 98, Julita St. Sta Quiteria Caloocan City.

4. Respondent is an Incumbent Mayor of Makati City who is involved

in the overpricing of Makati Science High School.

STATEMENT OF MATERIAL FACTS

5. Respondent was elected as Mayor during the 2013 Elections with a

vote of 251,330. Ombudsman Conchita Carpio-Morales has
approved the six-month preventive suspension of Makati Mayor
Junjun Binay and 14 other officials of the Makati City government in
connection with their involvement in the irregularities in the
construction of a ten-storey building in Makati Science High School
worth P1,349,980,757.50 stated in the RA 3019:
Section 3. Corrupt practices of public officers. In addition to
acts or omissions of public officers already penalized by
existing law, the following shall constitute corrupt practices of
any public officer and are hereby declared to be unlawful:
(g) Entering, on behalf of the Government, into any contract or
transaction manifestly and grossly disadvantageous to the
same, whether or not the public officer profited or will profit
thereby.
6. Respondent registered Ms. Ebeng Baloloy still being controlled by
the Binays and that she is one of the thousands ghost employees
of the Makati local government and other alleged dummies. Under
RA 3019 which provides:
Section 3. Corrupt practices of public officers. In addition to
acts or omissions of public officers already penalized by
existing law, the following shall constitute corrupt practices of
any public officer and are hereby declared to be unlawful:
(j) Knowingly approving or granting any license, permit,
privilege or benefit in favor of any person not qualified for or
not legally entitled to such license, permit, privilege or
advantage, or of a mere representative or dummy of one who
is not so qualified or entitled.
Hence, this Petition.

PRAYER
WHEREFORE, it is mostly respectfully prayed of this Honorable
Office, that judgment be rendered to suspend the Incumbent Makati
Mayor Jejomar Erwin Binay Jr.
Other reliefs, just and equitable under the premises, are likewise
prayed for.

REPUBLIC OF THE PHILIPPINES

CITY OF MANILA
S.S
BARNACHEA, CONCEPCION & ASSOCIATES
Unit A, 3rd floor Queen St. Quezon City
Metro Manila
By:
Atty. Charlene B. Concepcion
VERIFICATION AND CERTIFICATION FOR NON FORUM
SHOPPING
I, CHARLENE B. CONCEPCION, Filipino Citizen, of legal age, and
with residence at 98 Julita St. Sta Quiteria Caloocan City
respectively under oath:
1. That I am the Petitioner in the above-entitled case.
2. That I have read and understood all the contents of the same
attest all the allegations therein are true and correct to the best
of my knowledge and based on the authentic records.
3. That I shall report such fact within five (5) days therefore to this
Honorable Court.

IN WITNESS WHEREOF, I have hereunto set my hand this ____ day of

___________ 2015, __________________ City, Philippines.

CHARLENE B. CONCEPCION
Affiliant

SUBSCRIBED AND SWORN to before me this 14th day of November

2015, at Quezon City, Philippines, by Charlene B. Concepcion, has
satisfactory proven her identity through her TIN number. 012-345-678-900.
That she personally signed the documents before me.

Notary Public

Doc. No. ________;

Page No. ________;
Book No. ________;
Series of 2015