Your honor, before any argument should be put on the table, allow me to remind you and

everyone here present the purpose of the thousands of people who surged into the streets of
EDSA, ousting the over 2 decades of atrocity of then former Pres Marcos. Filipinos, who were all
fed up took each others strength to expel, banish and relegate plunder, murders and
unconceivable human rights violations, pardon me if I choose not to call him a leader as all he
was, was a dictator! This is beyond the penumbra of the letters of the constitution, as it requires
all of us to look into the intent of the framers. Its plain and patent contempt of our democracy
as the dictators burial in the Libingan ng mga Bayani would tantamount to us burying the very
reason why we created the 1987 Constitution.

In the current plight of this judicial controversy, the constitution has provided our courts the
expanded jurisdiction to check whether there is a grave abuse of discretion. In this case, we seek
that the court see the gravest abuse that an incumbent President would do in burying a dictator
as a bayani.

In the matter of the validity of the declaration of the President, it is very clear that it is in
contravention not only to the constitution but the international laws to provide holistic
reparations to the victims of human rights violation. The defense themselves recognized that the
violations of the dictator and so burying him in the Libingan ng mga Bayani would provide more
moral anguish and agony to his victims negating our responsibility under the constitutional
principle of pacta sunt servanda.

In the matter of qualification of the late dictator, the very regulation that they are holding on
provides that those officials who have been dishonorably discharged should not be buried at the
LNMB. Thus, this court in Marcos v. Manlapus declared that Marcos was been forcibly discharged
of his office, no other worse way for a President to be deprived of his position than to be ousted
by his own constituents. We would submit that if we are not going to subject the dictator to that
regulation, it would be a violation of the equal protection clause of the rest of the soldiers who
had to comply to such a requirement as by doing so, there would no longer be a valid distinction
between the two.

We would like to end with a question. Are we going to allow the respondents to use the same
reasoning that Marcos used to circumvent the previous constitutions? We hope not your honor.
With that, we rest our case.