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REPUBLIC OF THE PHILIPPINES

PROFESSIONAL REGULATORY COMMISSION


Ground Floor, and Second Floor, Delegation Building of the Philippine International Commission
Center (PICC ) Pasay City

LORNIE I. NAVASQUEZ, et. al.


Complainant,
Administrative,Medical
Negligence, Criminal Case.
No: ________________________

-versus -

EVELYN VICTORIA ELIDO RESIDE, et. al.

Quirino Memorial Medical Center - Medical Chief II .


Respondent.

X----------------------------------------------------------X

COMPLAINT AFFIDAVIT ( advance modify copy )

1.Comes Now, Lornie I. Navasquez, “ as well as all the


surviving family members “ assisted by counsel acting as
consultant “ , can be serve with summons at # 6 Freedom Park
Batasan Hills Quezon City, Metro Manila, herein referred to as
complainant, after having duly sworn in accordance with the law,
do hereby depose and state:

2. Unto, PRC-Chairman Honorable TEOFILO S. PILANCO JR.,


herein complainants is accusing respondent Dr. Evelyn Victoria
Elido Reside QMMC Medical Center Chief II, “ cancer patient
Nartates, attending Physician” and co–respondent, Dr. Homar
Anthony Chua Organo, with License No. 125807, both employee
of Quirino Memorial Medical Center, a Department of Health, ISO
No. 9001:2015, Certified , mandated, Health care provider, and can
be serve with summons and other processes at P.Tuason St. cor.
J.P. Rizal St. Project 4 Quezon City .
Patient Statement of Account ANNEX “A “

(3) That, others, also will be impeaded at the necessary and


appropriate time time as warranted by circumstances similarity of
situations would allow and accordingly and correspondingly
impleaded as provided by rule of law rights versus wrong ; The
public officer/Respondent;

PREAMBLE OF THE CASE

4) That, QMMC ENT OPD WARD, patient Mrs.Nartates, Ma.Lanie


Fe y Navasquez, Hospital No. 1195360 , died early at the age of
41, on July 17, 2019, at East Avenue Medical Center.
Death Certificate ANNEX “B ”

issue to be clarify

Page 1 of page 10
A. Pneumonia high risk,
(a) Is, actually only one of the many complications , as a
result of the erroneous, QMMC Ward ENT-OPD, co- respondent
Organo, performed, Incision Biopsy via Caldwell Luc.
Medical Certificate No. 07-576 ANNEX “ C “

(b) Because, victim Nartates,QMMC laboratory, chest ex ray,


results, before the surgical biopsy testing, shows that both
lungs, are clear, Actually the cause of pneumonia, is due to the
Untreated major surgical biopsy testing. That worsen patient
Nartates health condition, became bedridden for long period of
time, made her suffer Pneumonia.
please see QMMC Lab.- CHEST X RAY results ANNEX “ D- “

(c) In addition, both respondents Reside and Organo, Neglect


to submit the” essential“ Official copy/ies of the “ erroneous “
Incision Biopsy result/s, stating among others, as to what stage of
cancer the victim is afflicted with, to properly guide the QMMC IM
ONCO, to decide the proper cancer medications required.
,
B. Diffuse large b cell lymphoma (one 1 year)

(a) Granting, but not admitting that, it is the actual


cause of victim Nartates, premature death,

b) The truth on the matter , is that the actual cause of


death, is not the declared Diffuse large b cell lymphoma (one 1
year) Because , evidently, the victim painful , new growth , visible
outer skin cancer, less than 1-inch “ Is actually positioned on the
right jaw, but precisely, not on the inner part of the nose, throat.

c) Besides, patient nartates, never complaint of any


pain, on the nose , throat ever since. That needs to launch a
major surgical biopsy testing for malignancy.

d) That, In this example co –respondent Organo, and all


other medical practioners, involve in this mistake, violates R.A.
6770 , apparently took advantage, of a free medical surgical
training “ on the inner nose part, of victim nartates , disguise
as a major surgical biopsy testing for malignancy, at the expense of
patient Nartates. Life..

e) That, the truth on the matter, is that, the cause of


victim Nartates, premature death, is actually because of the
mistaken, co- respondent Organo, surgical “ illegal medical practice” biopsy
testing, on wrong body parts of victim Nartates, soft tissues, of
the innermost part of the nose , throat, gums. (Highlight for
emphasis)
victim own photo “OPPO mobile album , ANNEX “ E - 1, E-2,E-3 “

f) Further, precisely , not the new growth painful tumor


on the lower right jaw, is the cause of victim Nartates
premature death,

g)Instead it is the UNTREATED, erroneous surgical “


illegal medical practice “ ( underline for emphasis ) biopsy testing , is the
definite reason, of the lingering illness, 24 / 7 in pain and in
shame , complication, after complications, and finally cause,
victim Nartates, Ma. Lanie Fe y Navasquez , premature death, .
against the rule of l aw, and against the will of Almighty God..
OPERATIVE RECORD ( SURGICAL MEMO O. R. TECHNIQUE ANNEX “D-1 ”

Page 2 of page 10
h) After all, co- respondent Organo, baseless, illegal,
surgical “ illegal medical practice” biopsy testing, is precisely,
not intended for medication, of patient Nartates. Because. Co –
respondent Organo, and other medical practioner, involve in this
surgical malpractice, hastily discharge patient on July 12 ,2018 (4
days confinement) without prescribing any take home long term
antibiotics medication, precisely to prevent the future ill effects of
the said surgical biopsy testing,
i) That, in this example , co- respondent Organo.
Intended to fool around, while enjoying, with his cohorts, a free
surgical fatal, legal , “medical practice” biopsy testing, on the
patient nose, despite clearly evident , without swelling , because
the swelling is , visible on the outer skin lower jaw , as testified
by Dr. Anthony Albert N. Abad M.D. FPCR, Radiologist
Oncologist, who earlier refuse to treat patient Nartates on July
23, 2018 ANNEX “ D-1” for reason he did not disclose to herein
patient family members.

Further on August 7, 2018 , Dr. Abad, send us back to QMMC


co- respondet Organo, with a letter address to co- respondent
Organo. ANNEX “D-2” advicing co- respondent Organo , to treat
patient wounds , and ask for forgiveness, but since then co-
respondent Organo , never treat the surgical wounds , at the
expense of the future 24/7 sufferings, eventually ending patient
Nartates abundant life .
As a proof, victim own mobile “OPPO photo album , ANNEX “ D -3 ,
D-4,D-4, D-6”

4.) That, complainants, and all the surviving family members,


is confirming to this Honorable Commission your honor please,
that the actual cause of premature death of victim Nartates, is
precisely NOT because of the diffuse large B cell Lymphoma one
year .
Death Certificate ANNEX “E ”.

a) Because, QMMC ENT- OPD, records of patient Nartates,


evidently, will show that victim Nartates, nor any member of her
family , complaint for any pain, whatsoever, in the allege, inner /
outer parts, of the nose,throat .

b) Instead, patient Nartates, principal complain is the


swelling on the outer skin, right cheek, where the painful cancer is
located.

c) Therefore, it is definitely and medically incorrect to


execute a major surgical biopsy testing for malignancy, on victim
Nartates , wrong body parts, where there is no pain at all, and
definitely no surgical biopsy testing for malignancy is necessary .

d.) Besides the painful visible new growth ( stage 1 )


swelling , located on the lower jaw is very silent and not as
destructive, that will cause, a “ one 1 year “ premature death to
cancer patient Nartates.
Victim actual photo “OPPO mobile“ album ANNEX “ F-1” “,F-2 “

e.) Further“ Medical News Outlook tip, stating among others,


that a cancer patient who is diagnose with stage 1 cancer, has an
83 % of surviving for longer than five (5) years . ” Please see
Medical News Outlook tip website

Page 3 of page 10
f) Furthermore, co- respondent Organo, already admitted,
earlier his errors, to common law husband Arthur, at the cancer
patient Nartates bedside, during the initial induction chemo
therapy session at QMMC- Internal Medicine ONCO .Ward.

g) “ Quote “ co- respondent Organo said , Tao lang kame hindi


kame DIOS , NAGKAKAMALI DIN KAMI In this example, co-
respondent Organo, admission of responsibility, is a valid ground
for this Honorable PRC - Chairman HON. TEOFILO S. PILANCO JR,
your honor please, in your capacity as such, to recommend for the
immediate confiscation, of PRC License, (to kill legally) and
Likewsie , to remove all the names , ( including all the other
QMMC- medical practioners involved in this said, erroneous surgical “
illegal medical practice” ( underline for emphasis) biopsy testing for
malignancy , namely (Admitting ) Dr. Cherlaine F. Ventinillia, Dr,
Coloma Dr. Emmanuel Banzon Austin Jr. from the PRC Master
List of Physician.
REQUEST for Surgical Pathology Consultation ANNEX “ H”

5) Moreover, That, co- respondent Organo, and all the other


medical practitioners, involve, In this case, questionably ,
disregard to practice clinically , the lesser risk kind of biopsy on
victim Nartates. such as,

(a) Brush biopsy. Medical Practice, Testing for tumor


malignancy .
(b) MRI biopsy medical practice testing for tumor
malignancy . .
(c) Needle type of biopsy medical ,Practice Testing , for
malignancy/
d) And many modern type of biopsy medical Practice
testing.

6) That the cause of action a violation of R.A. 6770 ,


Republic Act 6770 ; Public office is a public trust, must at all
times be accountable to the people, serve them with utmost
responsibility, integrity, loyalty, efficiency, act with patriotism and
justice and lead modest lives.

a) That, respondent Dr. Reside, being the QMMC Medical


Chief II, in her capacity as such , and being the attending
physician of patient Nartates, (ever since on the record )
neglected, to function as such, and QMMC ENT OPD WARD,
records will show that she failed to visit personally patient
Nartates, even once , to properly diagnose the definite biopsy
testing needs, respondent reside, crystal clear , in this case,
failed, in her supervisory functions, much worst, failed to advice
appropriately co- respondent Organo . and other practicing
doctors involved in the subject major surgical biopsy testing for
malignancy , to decline, the deadly surgical biopsy medical
practice, on victim Nartates, instead , to save patient life ,
respondent reside should advice , co – respondent Organo, to
execute the safer kind of biopsy medical practice testing for
malignancy stated above.. Statement of Account patient Nartates MEDICAL
CERTIFICATE ANNEX “I ”
.
7.) That, Patient mobile OPPO, photo album, clearly point to
the actual cause of victim Nartates, premature death is no other
than the following difficulties,

Page 4 of page 10
a) Victim photo of the new growth visible tumor on the
lower right jaw is not violent at all
Victim actual photo “OPPO ‘ mobile album ANNEX “J “ .J-2,J-3,J-4,J-
5,J-“

8) Furthermore, That, QMMC OPTHA / ENT / ENT Female - Bed


Dr. Cherlaine F. Ventinllia , admitted patient Nartates, ON July
08,2018, patient undergo and pass, several laboratory test , on
July 10, 2018 perform the deadly , legal , major surgical biopsy
testing for malignancy ,on wrong body parts , damaging the soft
tissues of gums, VISIBLE NOSE, , throat , AFTER THE SUBJECT
ILLEGAL MEDICAL PRACTICE , ( capital letter for emphasis ) hurriedly
discharge vitim Nartates , on July 12 , 2018, Your Honor please,
Take note, WITHOUT PRESCRIBING long term antibiotic take home
MEDICATION, except for Orahex (oral rinse ) ADMISSION AND
DISCHARGE RECORD ANNEX “ K -”

9) Moreover ,That, on July 10, 2018, Despite, respondent


Reside and co- respondent Organo, being a PRC License
professional doctor, are very much aware of the future, lingering
effects , of the complication of the said, S/P BIOPSY INCISION VIA
CALDWEL LUC. to victim Nartates, crystal clear , Neglect to
properly diagnose , much worst Neglect to refer subject patient
needs, before discharge , of a QMMC Infectious Disease
Specialist, who will prescribe a take home long term antibiotics
program.
Admission and Discharge Record ANNEX “ k -1 “

a) Definitely, for patient future protection, and to prevent,


infection, and inflammation, of the nose , mouth and lips ,
further , to prevent the future , nose and mouth, huge bleeding,
due to the “UNTREATED “ wounded, ( razor blade “15” ) inner soft
tissues, of the nose, gums and mouth, that will surely afflict the
said patient. , and finally will lead to several difficulties, after
difficulties, until finally , premature death, against the rule of law ,
and against the WILL OF GOD, will come to pass.
Discharge summary / medical abstract ( no Home Medications ) ANNEX “ K-2”

b.) Furthermore, That, In this example, respondent Reside,


adding more insult to the injured victim Nartates,
irresponsibly, without preservation to God given precious human
life, apparently hastily approve, co - respondent Organo,
including all the PRC License medical practioners of QMMC - ENT
OPD practicing doctors, such as Dr. Banzon Emmanuel AUSTIN Jr,
Dr. Coloma, Dr. Ventinillia, and other QMMC - participating
medical PRactioners, jointly, similarly misdiagnose, and unlawfully
discharge patient Nartates, on July 12, 2018.
Request for Surgical Pathology consultation. by Dr. Emmanuel
Banzon jr. ANNEX “ K-3 “ .

c.) That, in this example, respondent Reside, as QMMC Medical


Chief II, crystal clear, neglect to exercise her supervisory
functions, to address the said medical blunders, about to be
committed by co-respondent Organo, and similarly , all the other
practicing doctors involved in this incident.

d) Further, considering that, QMMC - ENT OPD WARD then


Head, co- respondent Dr. Organo, “ who is the principal practicing
doctor , in the said mistaken major biopsy “ illegal medical practice “
operation , apparently, still under going, his QMMC, Residency

Page 5 of page 10
Training Program. And records shows, graduated only sometime in
December 2018.

e.) Furthermore , in this instance, co- respondent Organo,


apparently , is not yet officially, mandated by the Department of
Health to diagnose, a visible tumor,on the right lower jaw,
of patient Nartates ” much more , to complete a major surgical
biopsy testing, precisely, because it is outside, co-respondent
Organo, DOH, permissible medical practice of jurisdiction.

f.) That, For Truth and Justice sake, Respectfully requesting


your honor please, complainants, and all the surviving family
members, is hereby requesting, this honorable PRC Chairman
office, if possible your honor please, to endorse this complaint, to
DOH Secretary , - Honorable FRANCISCO T. DOQUE IIi to intervene
on this dangerous health care providers,” medical practice “
irregularities.

10. That, undeniably, both respondents Reside, and Organo.


And all the PRC License practicing doctors involve, in this surgical
biopsy” illegal medical practice” testing, in this case, crystal clear, as a
public servant and a public trust NEGLECT to,

a) Identify first and foremost, to focus, on the immediate


needs, for antibiotics treatments, more than the subject patient,
discharge orders on July 12, 2018, and much more , on the patient
needs for induction chemo therapy treatments, Since the said
tumor is not as aggressive, in comparison to the ill effects of the
said mistaken surgical “ illegal medical practice” biopsy testing. Besides.
Since the subject painful , new growth lump, outer skin less than
one (1)inch is precisely , not as aggressive as the seriously injured,
soft tissues,of the innermost part of the nose, throat gum, lips.
Heavily damage by a deadly weapon razor blade “15” of QMMC
ENT OPD . Surgery “ illegal medical practice” biopsy testing.,
Mobile “OPPO “Photo album of victim Nartates ANNEX “ E-4 “
victim mobile (OPPO) photo album Annex “ E-5 “

b) To treat Victim Nartates, the immediate required multi


antibiotics long term medications program.

c) To refer said patient, to the proper QMMC Infectious


Disease Specialist, for appropriate medications. of the upcoming,
nose gums, mouth lips inflammations and other severe
complications.

11) That, in case, both respondents Reside, and Organo,


likewise, the QMMC ENT-OPD WARD , professional doctors, involve
in this incident, hasty in patient evaluations, Orders the
immediate illegal release of victim Nartates, on July 12 , 2018,
crystal clear a violation of 1987 Constitution, Article II, Section 15.
And other existing laws related on the matter.
ANNEX “ E- 6”

a) That, unexpectedly, all the said respondents in this case,


neglect to protect and promote the right to health of victim
Nartates, “
Apparently, Neglect to prescribe the necessary, take home,
long term medication treatment program, precisely to prevent
the distressing, imminent infectious disease, to subject patient
Nartates.
QMMC OPERATIVE RECORD ) MEMO/ O.R. TECHNIQUE ANNEX “ D “

Page 6 of page 10
12) That, Complainants is accusing respondent Reside, and
co- respondent Organo, co – respondent Dr, Cherlaine F.
Ventinillia, Dr. Banzon Emmanuel Austin Jr. Dr. Coloma, undeniably,
part of the surgical team, in this instance, crystal clear, liable to
answer for committing, medical negligence on patient Nartates..

13) That, QMMC OPTHA ENT /ENT patient records will show
that all said respondents involve, in this case, neglected to
diagnose appropriately, during the four ( 4 ) days victim Nartates
confinement at the said Ward, as health care provider, with full
blanket authority, and as a public servant and a public trust ,
right there and then, should locate the best available
medications, to treat, victim Nartates, soft tissues, innermost ,
throat , gum, lips mouth, earlier , heavily injured, by deadly
weapon. “ 15 razor blade “ due to the said, surgical biopsy medical
practice for malignancy testing.
QMMC OPERATIVE RECORD MEMO / O.R. TECHNIQUE ANNEX “ E 1 “

CAUSE OF ACTION

R.A. 6770 Public office is a public trust, must at


all times be accountable to the people, serve them
with utmost responsibility, integrity, loyalty,
efficiency, act with patriotism and justice and lead
modest lives.

14) That all the respondents, involve herein , ever since


being aware of the ill effects to subject patient , caused by the
said unauthorized QMMC ENT OPD, surgical biopsy medical
practice testing, victim Nartates, records clearly shows, the
medical negligence of all the respondents in this case, who
indirectly / directly , participated in July 10, 2018 , said illegal
surgical biopsy medical practice testing for malignancy.

a) In this example, all the herein accuse respondents,


disobey R.A. 6770 and other existing Laws, related on the matter,
Undeniably, Neglect to serve / diagnose, worst of it failed to refer
victim Nartates, urgent medical requirements to QMMC Infectious
Disease Specialist, to treat appropriately the forthcoming
,worsening patient disorder, due to the untreated. “ Ever since”
innermost part, soft tissues, of the nose, throat , gums, mouth,
badly damage cause by the said unlawful major surgical “ razor
blade 15 “ biopsy medical practice for malignancy testing..
R.A. 6770 ANNEX “ F “

15) That resulted, victim Nartates , numerous complications


such as ,
a) Lingering illness, 24 /7
b) Foul odor, nose mouth, fluid discharge,
Medical Abstract ANNEX “ F-1”
c) Worst of it the rapid inner part, soft tissues of nose, gums, and
mouth swellings,
d) And on October 20, 2018, patient Nartates , was rush to QMMC
Emergency Room Ward, due to huge bleeding of the nose and
mouth, and requires three (3) units of blood to survive.

e) Discharge on October 24 2018, again, in this case Neglect to


treat properly by the Attending Physician respondent reside,

Page 7 of page 10
Statement of Account of patient Nartates ANNEX “ G
f) Many teeth falling one by one.
g) Lately swelling mouth lips , except the new growth visible tumor
is not aggressive.
Mobile “OPPO “victim photo album ANNEX “ G-1,G-2,G-
3,G-4
h) Problem in food intake.
i) Malnutrition . “
j ) Shaky feeling.
k ) Very depress feeling. “
l) Cannot stand alone No more toileting
m) Needs diaper for urine purpose
n) Loss of blood blood transfusion
DISHARGE SUMMARY /MEDICAL ABSTRACT ANNEX “G-5 ”
o) Sudden Loss of weight.
p) Bedridden.
q) Premature death. Death certificate ANNEX “ I “
16.) .That, if only, and purely herein respondents,
likewise all the involved, participating , practicing doctors, “
stated above, “ did not neglect their duty as a public servant, and
a public trust, and properly diagnose, victim Nartates, worsening
condition, which immediate needs , is to refer said patient to
QMMC - Infectious Disease Specialist, to prevent the permanent
health difficulties, caused by the earlier co- respondent Organo,
and team, committed medical mal practice operation on the (wrong
body parts of patient nartates ) innermost part, soft body tissues,
of victim Nartates, she, should have been still alive and still
earning today and so on, even Granting, with the new visible
growth on the outer skin, lower right chin, “ Medical Outlook
News Reports . Stating among others,” that tumor, below 1 inch
size, survival rate 83% of five (5) years .
.
17) In this example, all the herein respondents in this case ,
adding more insult to the injured patient Nartates, NEGLECT, to
refer said patient , to a QMMC Infectious Disease Specialist, for
appropriate treatment, to avoid all, further complications, TO be
suffered by Patient Nartates , such as ,

a) Right side, nose open wounds,.


Victim mobile “ OPPO “ photo album patient image ANNEX “J
b) Permanent, Separation from six (6) all minors children’s,
four (4) in school
c) Loss of daily wages, being a Philippine Normal College,
BS ED batch 2001 Graduate,
CERTIFICATION of Employment NAVASQUEZ MA. LANIE FE
ANNEX “ K “ . K-1, K-2, K-3,K-4,K-5,K-6,K-7 K-8.K-9.K-10 “
d) A License professional teacher,
PRC verification for teaching ANNEX “O ”
e) Loss of a generous sister to total of four (4) brothers and
three (3) sisters,
f) Premature death, physically fit, at the of age 41, except
for the small lump on the right chin.)

18). That all the respondents QMMC – ENT OPD WARD ,


illegal surgical biopsy testing, causing 24 / 7 agonies suffered by
patient Nartates , as well as all the surviving family members,

19) In this case all respondents, Dr. Reside, Dr. Organo, Dr.
Coloma, Dr. Banzon Emmanuel Austin Jr. Dr. Cherlain F. Ventinilia,

Page 8 of page 10
being a public servant and a public trust , crystal clear, acted
very much contrary to the Dept. Of Health, Civil Service
Commission mandate, and likewise , to the Rule of law .

CAUSE OF ACTION

Art III 1987 Constitution BILL OF RIGHTS


(Section 1 Section ,2, )
“Section 1, No person shall be deprived of life,
liberty, or property without due process of law, nor
shall any person be denied the equal protection of
the law.

20) That in this case, herein, all respondents affirmed


above, clearly , abandoned, and continues negligence, And failed
to comply appropriately ,
(a) Depriving patient abundant life pleasure,
(b) Depriving patient liberty to love and support family
needs, further the same respondents, neglect to extend the equal
protection of law, to the said patient,

c) Besides, 1987 Constitution Article II, Section 14 declares


that “The State shall protect the rights to health of the people and
instill health consciousness among them . Also, Article XIII. On
social Justice ,and Human Rights on health , declares that it is the
responsibility of the State, to adopt and integrated and
comprehensive approach to health development which shall
endeavor to make essential good health , and other social services
available to all the people at affordable cost. There shall be
priority for the needs of the under privilege, sick, elderly disable
women and children . The state shall endeavor to provide free
medical care to the paupers. And this is the legal mandate of the
QMMC accredited by Department Of Health. The same
respondents stated above, deprived of life, liberty and likewise
the equal protection of the law, and neglect to diagnose nor treat
appropriately patient Nartates,

PRAYER

WHEREFORE , PRMISSES ALL WELL CONSIDERED,

In conformity with MAYOR PRRDuterte Administration,


crusade to stop corruption in ALL , government service.
complainants most respectfully prayed of, for its pronouncement,
your honor please, to issue a corresponding Resolution declaring
a probable cause for Administrative, Criminal, Medical
Negligence, Gross Misconduct, dishonesty, omission,
unreasonable ,unfair, oppressive, irregular, inconsistent under RA
6770, RA 3019 Sec.5 par. (a and e) and other existing laws related
on the matter, which is beyond reasonable doubt committed by
respondent Dr. Reside, co –respondent Dr. Organo, and all the
other PRC License , practicing doctors involve , after which, your
honor please, Order all the respondents in this case , especially
respondent Reside, co- respondent Organo, , to jointly, similarly ,
ask for a public apology , with a promise not to do the same
negligence again to future other QMMC patients, and most
important to make a written promise to support victim Nartates,
all six ( 6 ) minor children’s until complete college education.

Page 9 of page 10
Five (5) are now in public school the eldest is grade 9 youngest is
kinder .

Further, for truth and justice, deprive , ever since to patient


Nartates, your honor please , Order all respondents of this case
to equally , compensate the existing all surviving family members,
of the late, Mrs. Nartates Ma. Lanie Fe Navasquez, in the amount
of not less than Nine Million (P9,000, 000 ) Pesos, as damages,
of mental anguish , pain and sufferings , and most specially ,
Due to

a) Victim Nartates, deprive of liberty, to earn a daily


income, locally and abroad, until retirement age of seventy (70)
years old,
as early as 2014 Approve visa as Teacher in KUAWIT ANNEX “ P “
b) The victim being BS ED, Philippine Normal
University , Graduate, batch 2001. DIPLOMA PHILIPPINE NORMAL
UNIVERSITY Annex “ Q ”
c) Loss of care, protection, guidance advice training and
nurturing tutoring / mentoring. Educational support , Victim all
minors, six (6) children’s.
d) Medical and other miscellaneous expenses ever since 2018
e) Retired cab driver, senior citizen common law husband ,loss
of a supportive wife.

If, respondents in this case, insist to delay justice further,


for and in behalf of victim Nartates, likewise to all the surviving
family members, your honor please, Kindly Order. all the
respondents of this case, to file their counter affidavit, to
contradict herein accusations against them, And if respondents
failed, to respond accordingly, You honor Please, issue an order
to the PRC officer in charge, to immediately, confiscate the
physicians, PRC license, “to kill legally, so as to avoid further
disaster to happen to other innocent patients.

Furthermore, your honor please, issue an order to remove,


all the respondents, names, from the master list of Physician, in
this honorable Philippine Regulatory Commission office.

Otherwise to the prejudice of herein complainants, and all the


distress surviving family members, of the late Mrs. Nartates, Ma
Lanie fe y Navasquez. Who died prematurely at the age of 41,
because of all the respondents jointly, similarly, committed, illegal
medical practice, performing a major surgical biopsy testing for
malignancey, in victim Nartates, “ wrong body parts “ inner nose,
throat , where ther is no pain and precisely no cancer that needs to
conduct a major surgical biopsy testing for malignancy, and worst
of it, all the respondents in this case, undeniably, abandoned, and
neglect to treat , victim Nartates, deadly surgical wounds
appropriately .

Afterwards, your honor please, kindly endorse this complaint


to the Court of competent jurisdiction, for proper Prosecution,
Conviction, Separation from the service.

Other relief as may be deemed just and equitable under the


premises is likewise prayed for .

Quezon City for, Metro Manila October 05, 2019 .

Page 10 of page 10
LORNIE I. NAVASQUEZ . DANIE I. NAVASQUEZ

Complainants

Common Address

6 Freedom Park 5 Batasan Hills , Quezon City

VERIFICATION & CERTIFICATION

We. the undersigned affiants, under oath, depose and state :


that we have caused the preparations, of the foregoing Complaint,
“ through the aid of a counsel acting as consultant , that as the
surviving afflicted party , we, have read the same and do
affirm all the allegations therein are true and correct of our
personal knowledge and base on authentic records of the case on
hand.

We, FURTHER CERTIFY , That , we request the DOH, via emails


for investigations , Likewsie ,we request via emails, the 8888 Civil
Service Commission for investigations, as of the moment pending
resolutions,

Complainants firmly belief, with all due respect to PRC-


Chairman HON. TEOFILO S. PILANCO JR, your honor
please, consider, first and foremost, the merit of the case and set
aside for the meantime the pending , DOH, CSC earlier afflicted
party investigation request,

IN WITNESS HEREOF, we have affixed our signature this


05 day of October 2019 at Quezon City Metro Manila , Philippines.

LORNIE I. NAVASQUEZ DANIE I. NAVASQUEZ

AFFIANT

I.D. No ________ __ _____ I.D No.


___________.

SUBSCRIBE AND SWORN to before me this 05th day of


October , 2019 in Quezon CITY Metro Manila, after exhibiting to
me their valid I.D.

Doc. No. :________ .


Page No. ;______
Book No. ; _______
Series of 2019_________

Copy forwarded to all parties concern Reg. Mail _______ & via emails

MAYOR PRRDuterte via emails prrdappointments@gmail.com


HON. EVELYN VICTORIA E. RESIDE qmmc_doh@yahoom.com
Common address P. Tuason St. cor. J.P. Rizal St. Project 4 Quezon City REG.
MAIL No._______________
Hon. Homar Anthony Organo P. Tuason St. cor. J.P. Rizal St. Project 4
Hon Banzon Emmanuel Austin Jr. P. Tuason St. cor. J.P. Rizal St. Project 4
Hon. Coloma P. Tuason St. cor. J.P. Rizal St. Project 4

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HON. FRANCISO T. DOQUE III ftduque@doh.gov.ph
HON. ALICIA de la ROSA BALA arbala@csc.gov.ph
HON.JEREMIAH B. BELGICA - ARTA Director General complaints@arta.gov.ph
Broadcaster BEN TULFO “BITAG
“ BITAG OFFICIAL multimedia network , in due time

AUTHORIZATION LETTER

HON. TEOFILO S. PILANCO JR,


PRC - CHAIRMAN
14 October 2019

Chairman PILANCO JR,

WE , hereby authorize the bearer of this letter , to


pay for the Professional Regulatory Commission docket
fees.

Likewise to file this COMPLAINT to the PRC Legal


Service for immediate review .

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You are all aware that we, the afflicted party Is
seeking for truth and justice .

Thank y ou and anticipating for your immediate


action on this request.

Very Truly Yours

Lornie I. Navasquez Danie I.


Navasquez 09224551455
Brother of the late Lanie fe Navasquez Nartates

Complainants

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