Republic of the Philippines Quezon City
) ) S.S. COMPLAINT
We, the undersigned complainants, all of legal age, Filipinos, and with office address at the National Headquarters of ACT Teachers Party-List (Block 26 Lot 5, J.P. Rizal Street, New Capitol Estates 1, Batasan Hills, Quezon City), hereby accuse the Respondents named below, and any official and employee under their orders who are responsible for the acts complained herein or similar thereto, of (1) partisan political activity or intervention of public officers and employees and (2) use of public funds and equipment and facilities for an election campaign in violation of Article 261 (i) and (o) of the Omnibus Election Code, both of which are election offenses, committed as follows: 1. Respondents are national, provincial, city, and municipal officials of the Philippine National Police in the following capacities: Oscar D. Albayalde PNP Chief PCSUPT Dionardo B. Carlos Director, Police Regional Office 8 PSSUPT Rolando V. Bade Provincial Director, Leyte Police Provincial Office PSSUPT Nelson DC. Eucogco Provincial Director, Southern Leyte Police Provincial Office PSSUPT Dante P. Novicio Provincial Director, Samar Police Provincial Office PSSUPT Reynaldo B. Dela Cruz Provincial Director, Northern Samar Police Provincial Office PSSUPT Jose Ceasar B. Biso City Director, Ormoc City Police Office PCI Miguelito N. Bocade Officer in Charge, Isabel Municipal Police Station PCI Allan T. Novales Officer in Charge, Bato Municipal Police Station PCINSP Joemen P. Collado Acting Chief, Palo Municipal Police Station 1