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REPUBLIC OF THE PHILIPPINES

NATIONAL WATER RESOURCES BOARD


8TH Floor, NIA Building, Diliman
EDSA, Quezon City

IN THE MATTER OF THE


PETITION FOR THE
INCREASE IN THE VOLUME
OF WATER FLOW ALLOWED
UNDER TRANSFER WATER
PERMIT NUMBER 02-18-163-
024397
Case No. ______________
STA. CLARA POWER
CORPORATION,
Petitioner,

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

PETITION

Petitioner, STA. CLARA POWER CORPORATION, by counsel


and unto this Honorable Board, most respectfully states that:

1. Petitioner, is a corporation duly organized and existing


under the laws of the Republic of the Philippines with office address at
Highway 54 Plaza, 986 EDSA, Wack-Wack, Mandaluyong City, herein
represented by its Armando S. Yanga. A copy of Petitioner’s
Secretary’s Certificate is hereto attached and made integral part hereof
as Annex“A”.

2. Petitioner is engaged in power generation and will build


and construct the Loboc Hydro Electric Power Plant located at Brgy.
Gotozon, Loboc, Bohol.

3. On May 16, 2018, NWRB issued Transfer Water Permit


Number 02-18-163-024397. Transfer Water Permit Number 02-18-
163-024397 is hereto attached and made an integral part hereof as
Annex “B”.

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4. Upon review of the Petitioner on site at Brgy. Gotozon and
in optimizing the design of the Hydroelectric Power Plant, Petitioner
found out that the optimized design requires 24,000 liters per second
of water, however, the Water Permit only allows for 12,000 liters per
second of water. A copy of the Project Description report showing the
requirement of 24,000 liters per second is attached and made and
integral part hereof as Annex “C”.

5. Petitioner now seeks to change the approved volume of


water flow in the Transfer Water Permit No. 02-18-163-024397 to the
necessary and suitable water flow for the Hydroelectric Power Plant.

6. In view of the foregoing, petitioner most respectfully


requests that the Honorable Board allow the increase in of the
allowable flow of water from 12,000 liters per second of water to
24,000 liters per second of water.

PRAYER
WHEREFORE, premises considered, it is most respectfully
prayed from this Honorable Board to GRANT the present Petition and
APPROVE the increase in the volume of water under Transfer Water
Permit No. 02-18-163-024397 from 12,000 liters per second to 24,000
liters per second.

Petitioner prays for such other relief and remedies just and
equitable under the premises.

Mandaluyong City for Quezon City, _______.

ROLAND G. ROSALES
Counsel for the Petitioner
4/F Highway 54 Plaza, 986 EDSA corner Stanford St.,
Wack-Wack, Mandaluyong City
Landline: (02) 7065156; (02) 7065158
Mobile: 09178420546
PTR No. 3865184, 1/9/2017, Quezon City
IBP No. 1061301, 1/9/2017, Quezon City Chapter
MCLE Compliance No. V-0019509, 4/13/2016
Roll No. 48656

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MEILINE M. MAQUILING
Counsel for the Petitioner
4/F Highway 54 Plaza, 986 EDSA corner Stanford St.,
Wack-Wack, Mandaluyong City
Landline: (02) 7065156; (02) 7065158
PTR No. 2575174, 1/18/2017, Mandaluyong City
IBP No. 1064418, 1/17/2017, RSM Chapter
MCLE Compliance No. V-0020482, 4/28/2016
Roll No. 59215

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VERIFICATION AND CERTIFICATION OF NON-
FORUM SHOPPING

I, Armando G. Yanga, of legal age, Filipino and with office


address at unit 2F Highway 54 Plaza, 986 EDSA, Wack-Wack,
Mandaluyong City, after having been sworn to in accordance with
law, hereby state:

1. I am the ________________ of Sta. Clara Power Corporation


and its duly authorized representative.

2. On behalf of the Corporation, I have caused the preparation and


filing of the foregoing Petition entitled “In the matter of the Petition
for the increase in the volume of water flow allowed under
transfer water permit number 02-18-163-024397” filed before the
Honorable National Water Resources Board. A copy of the
Secretary’s Certificate authorizing the affiant to file this Petition
is attached hereto as Annex “A”.

3. I attest that I have read and understood the foregoing Petition


and that the allegations contained therein are true and correct of
my own personal knowledge and/or based on authentic records.

4. I further certify that:

a. The Corporation has not commenced any other action or


claim involving the same issues in any court, the Supreme
Court, the Court of Appeals or any division thereof, or any
other tribunal or agency.

b. To the best of my knowledge, no such action or claim is


pending in any court, the Supreme Court, the Court of
Appeals or any division thereof, or any other tribunal or
agency.

c. If I should hereafter learn that the same or similar action or


claim has been filed or pending in any court, the Supreme
Court, the Court of Appeals or any division t hereof, or any
tribunal or agency, I undertake to report said fact to this
Honorable Board within five (5) days from notice.

IN WITNESS WHEREOF, I have hereunto set my hands


this __________ day of _______, 2018 in _______________.

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Armando G. Yanga
Affiant

SUBSCRIBED AND SWORN to before me this ______ day of


_____, 2018 at __________, Philippines, affiant having exhibited
to me _____________________________________.

Doc. No. _____;


Page No. _____;
Book No. _____;
Series of 2018

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