Kidnapped ICRC Workers: Good News And Bad News

by: attybenji 


The good news is – Filipina hostage Mary Jane Lacaba was rescued and recovered alive from the kidnappers (April 2, 2009). Some reports alleged that she was handed-over formally by the captors to the negotiators, not rescued, upon payment of ransom!

The bad news is – the Swiss Andreas Notter and Italian Eugenio Vagni are still under captivity, sad to say, a day after freeing Lacaba, the kidnappers threatened to execute these two remaining captives. We do not know when? May awa ang diyos, huwag po naman sana!

With this new development, authorities are readying the evacuation of over 21,000 residents in 5 towns of Sulu for a possible worst case scenario or armed confrontation between security forces and the Abu Sayyaf bandits, as reported in various newspapers (April 3, 2009)

In retrospect: Filipina Mary Jean Lacaba, Swiss Andreas Notter and Italian Eugenio Vagni have been kidnapped and remained in the jungles of Sulu since January 15, 2009. They were abducted after a visit to a local prison where the Red Cross is funding a water project.

Recall that barely an hour before the ultimatum would lapse, Philippine Red Cross Chairman Senator Richard Gordon asked the Abu Sayyaf kidnappers for proof that the three Red Cross volunteer workers were alive as government troops and tanks moved closer amidst the threats to behead the captives. (April 1, 2009)

Senator Gordon’s messages to the captives, while uttering the words of comfort and inspiration, suddenly tears fell from his eyes, saying – “The whole family of Red Cross prays for you and I’m proud of the way you’ve comported yourself”. “I’m sorry I should be stronger than you because I’m not in the midst of the ordeal you are in now.”

And to the captors he pleaded, – “There was no glory in what the captors are doing. You are just pinning yourself down. These people are not your enemies. They were here to help the prisoners in the city jail by providing them with water and other needs”.

As the crisis deepens, the Catholic Church is urging Filipinos to pray for the release of the kidnapped ICRC workers.

The CBCP circulated copies of a pastoral letter in all catholic churches exhorting all Filipinos as brothers and sisters to reach out to both kidnappers and their hostages with prayers, saying that let it be a whole nation praying that all may experience true freedom and security. Likewise The CBCP is appealing to both kidnappers and the government to use every peaceful means to address thought peaceful process what ever is the root of this on going problem of kidnapping in Jolo, Sulu and the whole country.

We, as peace loving Filipinos, are sympathizing with the plight that the hostages are facing right now in the hinterlands of Sulu. They are facing the uncertainty of tomorrow, “nangangamba tayo na baka gagawin ng mga bandido ang kanilang banta”, God forbids!

– Just try to sympathize with their families, and imagine the sufferings, anguishes, mental torture, psychological-emotional pains, sleepless nights, mental shocks, fears and insecurities. As, anytime from now, the captives would be caught in the crossfire of the battle between the kidnappers and government forces once the latter commences its rescue operations. Also, anytime from now, they can be executed and beheaded by their captors.

From a distance, we can only offer our prayers for the lasting solution to this horrible situation in Sulu and for the release of the two other captives from the hands of the Abu Sayyaf bandits.

After freeing the Filipina, the fate of the hostages is still uncertain and unknown, and the fear of bloodshed is inevitable once the military begins its rescue operations in Sulu. Madaming inosenteng civilians ang madadamay sa bakbakang militar at mga bandidong grupo!

– Also, try to dramatize the situation, and imagine a scenario, or put yourself in the shoes of the families or relatives of one of the hostages, or of all the hostages, coupled with the shocking news update every now and then that the kidnappers are threatening to behead the hostages one by one. For sure, “hindi ka mapapakali, hindi ka makakain, maiihi ka, matatae ka, iikot ang tumbong mo at hindi ka makakatulog”, why? Because these group of kidnappers are known for their barbaric acts in the past. By all means, they have the capacity to exterminate the captives when their demands for ransom, or otherwise, are not heeded, and not taken seriously by the government negotiators, etc.

In fact, I was monitoring this incident for weeks now, and believe me guys while I was watching the news update on TV, a day before Lacaba was released, “naluha ako at naiyak”, because I could not help but to reminiscence the sad memories of the past, similar to the ordeal and nightmare that the hostages have gone thru for months in the mountains, and the tormented mind of the victims’ families as well, …… I cried, and tears fell from my eyes because some years ago my father, Ceferino was kidnapped by the NPAs, and my brother, Edilberto, was also victim of kidnapping years back in Nigeria.

In local parlance, malungkot ang alaala ng kahapon, kaya hindi ko mapigilan ang maiyak at maluha sa ganitong sitwasyun!


RE; Kidnapping of my father, Ceferino!

Sometime in 1995, my father was kidnapped by the NPAs in San Ramon, Bulan. While my brother, a seaman-engineer, was held captive by the Nigerian rebels in Warri of 2007.

My father, a municipal councilor then, and was active in local politics in Bulan. All of the sudden, one gloomy afternoon, the NPAs had snatched my father in our house and was forcibly brought to the jungle of the unknown, and of place of no return, where most, if not all, of the civilians, who have been held hostage by the rebels were buried thereat after being strangulated, stabbed, or buried alive according the reports; my father used to describe the place as between the boundary of the towns of Juban and Magallanes overlooking the sea from a far. He was held in captivity for almost a week, blindfolded and his hands were tied, and could not sleep well due to the pestering sounds and bites of the mosquitoes, known carriers of malaria virus (hindi pa uso nuon ang sakit na dengue).

Fear of not seeing his husband anymore, my mother has already entertained a thought of committing suicide due to hopelessness, frustration and despair. No news, no update of the incident, or the whereabouts of my father is still unknown, no means of communication, no telephone, no text, no cellular phone to connect thru to the captors at that time. But, worst, the NPAs had advised my mother not to tell anybody about the incident, nor report the kidnapping to the authority, which my mother obligingly did.

Despite said warning, some concerned citizens reported the said incident to the police, and minutes thereafter, the police proceeded to our house in San Ramon to confirm the reported kidnapping of my father, but my mother, for fear of reprisal from the captors opted to remain silent about it and when asked about the incident, she even diverted the interrogation made by the men in uniform saying that my father was in Manila for his regular medical check up, but the men in uniform did not believe her claim, because my mother at that time was uneasy and crying and tears were falling from her eyes uncontrolled by cotton handkerchief.

Luckily, prayers really paid off, because after week long of captivity my father was finally released unharmed somewhere in the mountainous barangay in Irosin.

The reason why he was kidnapped? According to them, my father is a spy for the military, and is having an illicit relationship with another woman. Oh my Gulay, this is a silly accusation? This is a blatant lie and not true. A fabricated and concocted charge purportedly made by his political rivals, who have personal grudge to grind against my father, “mga inggitero” in our barangay. But, this is politics anyway, a dirty politics I should say!

In consideration of his release, a board & lodging had been charged to my father’s account, he was asked to defray of the amount of P45-Thousand pesos, which we obligingly complied with (note: from the first demand of 100thousand pesos, natawaran hanggang umabot ng 45thousand nalang), on the condition that said amount would be treated not as a payment for ransom, but to be referred to as sort of a Donation to the KILUSAN, or as payment for the board & lodging of my father while under captivity. Silly, is it not?


RE; Kidnapping of my brother, Edilberto!

My brother, Edilberto, a seaman-engineer, was kidnapped along with the other 23 Filipino crew while their ship was navigating along the Delta River in Warri, Nigeria.

They were held in captivity for 24 days in the jungle of the Warri by the rebels who called themselves, the Movement for Emancipation of Niger Delta (or, “MEND”), the dreaded and most notorious group of rebels in Nigeria, engaged in piracy, kidnapping and extortion, whose leader opted to remain as a mysterious leader of the group, called “General”.

Within 24 days of captivity, we, the families, have suffered several days of sleepless nights, anxieties and mental shock, and like the ICRC Workers’ hostages, we’re also facing the same fate of uncertainty at that time. Because, the MEND rebels also threatened to execute one by one the Filipino hostages as reported in the CNN and BBC if the government of Nigeria and the ship owner would not heed to their demands. To resolve the problem, the Nigerian government has already called its men in uniform to prepare for the worst case scenario to rescue the captives at all costs, but luckily the purported plan did not push through, because the rebels threatened to use their hostages as human shields once the military pursues its plan.

We were then in constant contact with the representatives of the DFA, OWWA and the Hamonia Shipping Agency, the local manning agency, for more updates, these representatives would always advise us (families of the hostages) not to allow each one of us to be interviewed by media people in order not to jeopardize the on-going negotiations between the Nigerian government and the rebels, as well as the representative of the shipowner.

Amidst the advisory from the DFA and OWWA to shun away interviews by media people, feeling uneasy and worried of the situation, I then defied said warning, and taken the cudgel for all the families of the seamen-hostages by writing a letter of appeal to a local newspaper in Nigeria (the “Guardian”) via email. The contents of my letter was published in Nigeria and in also in various newspapers in Manila. Because of that incident, I was summoned by the DFA and that of Hamonia representatives in their office advising me to please avoid further making an appeal to the MEND rebels because in so doing I might be able to complicate or jeopardize the on-going negotiations. Their reason is “lalaki daw ang ulo ng mga rebelde at mas lalong magdedemand ng malaki dahil umaapela ang pamilya ng biktima for humanitarian considerations”.


The Picture below, (courtesy of CNN) – where kidnappers displayed their high-powered guns to the Filipino crew hostages in the undisclosed place in Warri, Nigeria.


Hereunder is my letter to the Guardian newspaper in Nigeria which was published thereat, viz:

Families’ Plea to Captors: Release Seamen in Nigeria
02/03/2007 | 10:48 AM
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Families of 24 Filipino seamen abducted in Nigeria last month appealed anew to the captors over the weekend to release their hostages.

In a letter published Friday in the Nigerian newspaper “The Guardian” (, Benjamin Gaspi of Manila sought a win-win solution to end the crisis.

“We, the families of the abducted Filipino seamen, are hereby appealing to the Nigerian militants for the immediate release of the seafarers from weeklong captivity … Once again, we appeal to the kidnappers to release the captives,” Gaspi said in his letter.

“We hope and pray that both the government and the militants should find a way to come up with a win-win solution to end the crisis. The families of these hostages in the Philippines are suffering from severe anxiety, stressful days, wounded feelings, moral shock, depression and sleepless nights,” he added.

Although Gaspi did not specify his relation to any of the abducted seamen, he indicated he was writing the letter on behalf of the families of the abducted seamen.

He said the crewmen should not have been abducted because they were “not interfering nor are they intervening in the internal and political affairs of Nigeria.”

“These seamen have nothing to pay because they have no money to pay the ransom (if any). If they really want money they can let go the crew, then take full custody of the vessel and its cargo, then the owner can now pay as well as all those people who have interest in the vessel and cargo,” he said.

Negotiations are still ongoing for the release of the 24 Filipino seafarers and crew of Baco Liner 2, a German owned-vessel held hostage by Nigerian militants last Jan. 19.

At least seven of the crewmembers were brought to a safe house while the others remained inside the ship under the control of the militants.

Gaspi also voiced concern that the hostages may contract malaria and diarrhea.

“We are very much worried and anxious because we do not even know the names of the seamen who were taken ashore and those who were held hostage inside the ship,” he said.


 AT HINDI PA RIN PO AKO MAPAKALI, kaya sumulat ako sa Ambasador ng Pilipinas sa Abuja, Nigeria. Ito ang nilalaman ng follow-up letter ko kay Ambasador Umpa, thru email, viz:

February 1, 2007

Ambassador Plenipotentiary
Philippine Embassy in Abuja
Abuja, Nigeria

Dear Mr. Ambassador,

Warmest Greetings!

Sir, unless the those captives are released from nearly month long of captivity; anxiety, mental anguish, low morale, boredom, sleepless nights, despair and depressions will always be part of the day to day routine of the wives, families and relatives of the 24 abducted Filipino seafarers since they were held hostage last January 19, 2007 by the so called Nigerian Militants-MEND.

Considering Sir, that the DFA has imposed a news black-out on the progress of the negotiation and even told the families to cooperate with them by not entertaining interviews from the local media so as not to derail the negotiations, may we respectfully ask an update or breaking news directly from your good office on the progress or status of the negotiation between the rebels and the delta state government, including the chances of having them released as soon as possible.

We understand also that your good office is doing its best to fast track the release of the hostages. Just to calm down, pacify and appease the feeling anxieties among the families of the kidnapped seamen, please give us an update on this incident.

We hope also that you will not get angry at us for being so “MAKULIT” in asking an update from your office every now and then, after all, the lives of the Filipino people are at stake here.

Thank you so much sir for accommodating always my request.

Very truly yours,



Another picture, (courtesy of CNN) – where kidnappers performed their native dance and rituals carrying with them loaded high-powered guns, firing their guns down the soil and up in the air.










Upon receipt of my letter, the Honorable Ambassador Umpa readily replied to my query, as follows:


01 February 2007

Mr. Benjamin G. Gaspi
MIS- 43 -2007

Dear Mr. Gaspi:

The Philippine Embassy in Nigeria acknowledges receipt of your letter dated
01 February 2007.
We understand your concern for the welfare of your brother and the rest of the
Filipino seamen abducted in Warri. Rest assured that the Embassy is doing all
its best to work out the release of our Filipino brothers.
I have personally led a six-man Embassy team to make sure that negotiations
are fast-tracked and that the Filipinos are treated well and are in good
condition. Daily contacts with the chief government negotiator are maintained
since Embassy personnel and the Delta State Government officials involved
are staying in the same place.
As regards the conflicting reports, the Embassy assures you that we are
closely monitoring every phase of the negotiations and as such, has the
higher authority to verify and confirm what transpires in the course of the talks
to release the hostages, in close coordination with the chief government
negotiator and other Delta State officials.
Thus, more weight should be given to the Embassy reports than to the articles
written in Nigerian local papers. We reiterate that the 24 Filipinos are safe and
are in good condition. The German office of the ship’s owners, as well as the
representatives of the local manning agency here in Warri have denied being
contacted whatsoever by anyone regarding the critical situation of some of the”
Further, the Embassy would also like to inform you that it is coordinating with
the German employers in the event of release of the 24 seamen.
Finally, we are hoping for the best and we are counting on your prayers and
the rest of the Filipino nation’s so that we could see light at the end of the
tunnel soon.

We appreciate your continued support and please feel free to communicate
with the Embassy any time and be up dated with any developments.
Thank you once again and best regards.

Very truly yours,



Also, picture below (courtesy of CNN), as told by my brother, sometimes kidnappers would point the barrels of their guns to the captives to intimidate them, and more significantly to catch the attention of the international community. (you see how worried they are in this picture).

pix-of-hostages_3At Last, after marathon negotiation with the kidnappers, the 24-Filipino crew, who were held hostage by the MEND militant rebels, were finally released upon paying of, allegedly more or less, 50M U.S. dollars as ransom.

Released Finally: as published in Manila Times, and other local newspapers and tabloid, viz:

Emotional Reunion for Released Seamen

Monday, February 19, 2007
REUNITED with her husband Roberto, chief engineer of the ship seized by rebels in Nigeria, Jocelyn Arcangel said she and her family would take a holiday before deciding on their future.
Roberto was among the 24 Filipino seamen recently released after being held captive at gunpoint for 24 days. They flew home Saturday to an emotional reunion with loved ones.
“We will have a very long family vacation after this incident and we’ll decide after whether he [Roberto] should leave again,” Jocelyn said.
“My sons don’t want him to leave anymore. It was very traumatic. We have not heard from them for a long time and there are fears that they were harmed,” she said.
Roberto said he just wanted to be with his family before declining to talk further with reporters.
Glenda Cagas said her husband, Herculano Cagas, the ship’s third engineer, would probably ship out again after resting in Manila, despite his traumatic ordeal.

“It is difficult, but we don’t have any other choice. We need the livelihood for the family,” Cagas said, noting that their two children aged six and four have yet to enter primary school.
“The hardest part for us was when we saw them on cable television being threatened with guns by their captors in masks,” she said.
Looking haggard after their ordeal but smiling and waving, the men were met by government officials and a throng of journalists after disembarking from a commercial flight at the Ninoy Aquino International Airport.
“We are very happy. Thank you very much President [Gloria] Arroyo,” they said in unison to an explosion of camera flashes.
They were quickly taken to Malacañang and tearfully reunited with family and friends.
Gunmen seized the oil workers on January 20 from a Nigerian-flagged, German-owned cargo ship off the coast of Nigeria.

They were held captive under constant threat by masked gunmen in muddy swamps of the oil-rich Delta region, as Philippine and Nigerian negotiators worked for their release.
It is still unclear who was responsible for the seizure, although a high-profile militant group, the Movement for the Emancipation of Niger Delta, has fingered a rival outfit identified as Fndic.
The men declined to comment on negotiations that led to their freedom on February 13 for fear of jeopardizing the safety of two other Filipinos seized separately. Filipino diplomats are in Nigeria working to free them.
A Filipina woman was abducted on February 7 in Port Harcourt in Rivers State. Gunmen abducted the woman from the center of the city, at the heart of Nigeria’s oil industry.
A day earlier a Filipino employee of Netco Dietsmann-the Nigerian arm of a Monaco-based oil services company-was seized from a company car heading for the airport in Owerri, the capital of Imo State.
Nigeria is one of the biggest employers of Filipino workers in Africa, with some 3,900 Filipinos employed there at the end of 2006.
The Philippines is one of Asia’s biggest exporters of manpower, with an estimated eight million of its citizens working as maids, seafarers, oil rig workers and in other labor-intensive jobs.
President Arroyo has banned further deployments to Nigeria in the wake of the kidnappings.
On Sunday she instructed embassy officials assigned in conflict areas to ensure the safety of Filipinos in their areas.
Besides Arcangel and Cagas, the crewmembers of Baco Liner 2 are Ruben Roble, master; Elmer Nacionales, chief officer; Carlos Abellana, 2nd officer; Mauro Agacid, 3rd officer; Cirilo Nebit, 2nd engineer; Engr. Edilberto Gaspi, electro tech officer; Sukarno Landasan, Rogelio Garcia, Jonel Bernales, Manolo Isidro, Marlon Mendez, Ronaldo Corpuz, Joven Hidalgo, Jose Talde, Samson Mayo, Henry Sebastian, Jonie Saguid, Edgardo Ellera, Evelio Nacionales, Marcelino Caladman, Nelson Aquino and Herman Valez.

The President said the government would maintain close watch over the welfare of Filipino workers worldwide.
“We continue to pray with the same fervor for the remaining hostages in Nigeria in the hope that their situation will also come to a happy ending,” she said.
The President also thanked the officials of the Department of Foreign Affairs who were involved in the release of the Filipino seafarers.
“To those who work to ensure the safety of our Filipino men, thank you, particularly Foreign Affairs Undersecretary Estevan Conejos Jr. and Special Ambassador to the Middle East Roy Cimatu,” she said.
-AFP and Sam Mediavilla


The Picture below of jubilant Filipino crew upon their arrival at the NAIA, after being released from the 24 days of captivity. My brother, Edilberto, is at the center raising and waving his left-hand to the media people. He is the tallest among the crew.










PGMA Welcomes 24 Freed Seamen and their Families in Malacañang


Twenty-four Filipino seamen, who were freed recently after almost a month of captivity by their Nigerian captors in the oil-rich Niger Delta in Nigeria, thanked President Gloria Macapagal-Arroyo last night for her immediate action to secure their release.

The seamen, who arrived at 6:40 p.m. at the Ninoy Aquino International Airport (NAIA) from Nigeria via Hong Kong, proceeded to Malacañang to personally extend their gratitude to the President.

The President, together with Foreign Affairs Secretary Alberto Romulo, hosted a sumptuous dinner for the 24 seamen along with their family members, relatives and friends at the Palace Heroes’ Hall.

During the emotional family reunions, the President went from table to table and had brief talk with the newly-arrived seamen and their family members.

“Maraming salamat po, Madame President, sa inyong mabilis na pagtugon sa aming panawagan na kami ay mapalaya agad,” said the seafarers as they echoed their gratefulness to the President.

“Welcome back to the Philippines. Praise God! Salamat sa inyong pag-sakripisyo. Have a nice reunion sa inyong mga pamilya,” the President told them.

The Chief Executive had earlier thanked Nigerian President Olusegun Obasanjo for “taking a direct hand” in the release of the Filipino seamen.

She also lauded all diplomats who were involved in the immediate release of the 24 seamen, particularly Foreign Affairs Undersecretary Esteban Conejos Jr. and special envoy to the Middle East Roy Cimatu.

“Salamat sa mga nagtrabaho nating diplomat para masiguro ang inyong kaligtasan, katulad ni Usec Conejos at Ambassador Cimatu. Araw-araw ay sinasabi ko na siguraduhin ang inyong kaligtasan at 24 oras silang
nagtrabaho. Praise God that everything had ended well,” she said.

The released Filipino crew members of Baco Liner 2 who called on the President at Malacañang were Ruben Roble, master; Elmer Nacionales, chief officer; Carlos Abellana, 2nd officer; Mauro Agacid, 3rd officer; Roberto Arcangerl, chief engineer; Cirilo Nebit, 2nd engineer; Herculano Cagas, 3rd engineer; Engr. Edilberto Gaspi, electro tech officer; Sukarno Landasan, Rogelio Garcia, Jonel Bernales, Manolo Isidro, Marlon Mendez, Ronaldo Corpuz, Joven Hidalgo, Jose Talde, Samson Mayo, Henry Sebastian, Jonie Saguid, Edgardo Ellera, Evelio Nacionales, Marcelino Caladman, Nelson Aquino, and Herman Valez.

They were abducted by Nigerian gunmen on Jan. 20 and freed unharmed last Feb. 13 without any ransom paid.

Meanwhile, Press Secretary and Presidential Spokesperson Ignacio R. Bunye said President Arroyo is hopeful that the two remaining Filipino hostages in Nigeria would also be released soon by their captors.

“The government maintains a close watch over the welfare and well-being of our workers all over the world, and President Arroyo always takes a personal hand in critical events such as the last one,” Bunye said.

“Active diplomacy at a high level and the active presence of our diplomats on the ground will continue to be our strategy to keep our beleaguered workers from harm’s way and to bring them home,” he added.
– – – xxx

Actually, may isa pa akong kapatid na seaman na si Alberto, ay muntik na rin makidnap ng mga Somali pirates in 2007, buti nalang daw nai-locked nila lahat ang doors ng ship, kaya hindi nakapasok sa loob at umalis agad,,, the rest is history na.



Long live Bulan Observer.



3 thoughts on “Kidnapped ICRC Workers: Good News And Bad News

  1. To attybenji

    Thanks for this post! Please send me by e-mail the corresponding photos you mentioned for I didn’t get them and I will try to insert them in the right places, just mark them accordingly.
    I haven’t read your whole post yet as of writing, just scanned it, and it sounds thrilling!

    jun asuncion

  2. To Attybenji

    Thanks for updating your post with photos. You story is very personal and deeply moving. I’m glad you shared this to our fellow Tagabulans and the general readers.
    As long as there is extreme poverty, social injustice, greed and corruption in politics the world will always be dangerous. There is no perfect human society but violence, armed rebels and kidnappings are practically reduced to the minimum or statistically insignificant incidence in societies where there is no poverty and grave political corruption.
    The Philippines has again made a name recently in the international community for being a place with dangerous rebels and terrorists, along with having a very corrupt government and president. How can you fight poverty then in such condtions? How can you talk about establishing social justice?
    In connection with the Spratly Islands conflict with China, I have read a funny comment somewhere that should there be a real armed confrontation with China, the Philippines have the run of the roost because aside from our military and police, we have the NPAs, the Abbu Sayyaf’s MILF, and all other criminal groupings to help combat China.
    I’m not sure how the NPAs and Abbu Sayyaf men reacted to Chip Tsao’s arrogance towards the Filipino. Were their amor propio and nationalistic pride also scratched and wounded by Tsao’s pernicious sermon to our nation and poor OFW?
    And how about President Arroyo’s amor propio and patriotism? Was she also indignated and insulted personally by Tsao’s ridicule of the Philippine Republic?
    I have mentioned this Tsao’s issue to my German colleague and he said that’s probably what the Filipinos need to be “verletzt”-wounded- by an outsider so that they’ll unite together and start working seriously for the progress of the Philippines. Well, there is a sense to his comment. But knowing our long history of foreign insults and humiliations, I really doubt if Tsao’s arrogance would translate in us something positive and substantial in our political attitudes and behaviour at least in next year’s election.

    I have found this old article by Albert T. Muyot and Vincent Pepito F. Yambao. It is very interesting and related to the issues that confront us.

    jun asuncion

    30-06-1999 International Review of the Red Cross

    No. 834, p. 303-316 by Alberto T. Muyot, Vincent Pepito F. Yambao
    Steps taken to ensure implementation of international humanitarian law in the Philippines

    Alberto T. Muyot is Director of the Institute of Human Rights, University of the Philippines Law Center, Quezon City (Manila), and Vincent Pepito F. Yambao is a junior researcher at the Institute.

    Respect for the life and the dignity of every individual is deeply imbedded in the Filipino culture, so much so that while the country’s history has been marked by several armed struggles to liberate its people from colonial masters, armed confrontation is regarded only as a last resort. Since the Philippines attained independence in 1946, political dissent has escalated from time to time into bloody encounters between government forces and insurgent groups, and many Filipinos have experienced the horrors of war. Innocent civilians, whose lives are supposed to be protected, have been helpless victims of atrocities. [1]

    This characteristic of the internal conflict in the Philippines, where there is no official state of war and where ordinary penal laws are applied to the insurgents and their supporters, is precisely the reason why considerations of human rights and those of international humanitarian law are closely related in Philippine practice. Directives from the Philippine government and the Armed Forces of the Philippines (AFP) to the troops in the field refer to both human rights and principles of international humanitarian law without distinction. In peace negotiations between the government and the insurgents the two sides have combined human rights and international humanitarian law as a single issue in the negotiations. This runs counter to the traditional distinction by which international humanitarian law is applicable in times of war while human rights principles are applicable during times of peace.

    The Philippines is party to the four Geneva Conventions for the protection of war victims (of 12 August 1949), to Additional Protocol II applicable in non-international armed conflicts (of 8 June 1977), to various human rights instruments – including the International Covenant on civil and political rights and the International Covenant on economic, social and cultural rights (both of 16 December 1966) – and to other major conventions.

    The Philippine government’s formal commitment to the principles of human rights and international humanitarian law has been translated into municipal law, the foremost example of which is the 1987 Philippine Constitution, which has often been referred to as a human rights constitution. A number of proclamations, memoranda, orders, circulars, and other executive statements reflecting this commitment were likewise promulgated under the presidency of President Corazon C. Aquino, at the height of the insurgency in the late 1980s. These were aimed at regulating the conduct of military operations by providing specific guidelines to the military and civilian officials for the government’s counter-insurgency campaigns, during which civilians were most exposed to abuses by both the soldiers and the insurgents. [2]

    In response to accusations of military abuse, President Aquino issued Memorandum Order No. 393 directing the AFP and the Philippine National Police (PNP) “to reaffirm their adherence to the principles of humanitarian law and human rights in the conduct of security/police operations”. [3]

    On the other hand, the National Democratic Front (NDF), besieged by similar accusations of abuse, unilaterally declared its adherence to the principles of human rights and international humanitarian law. [4]

    Early in 1998, the negotiating panel representing the Philippine government and the NDF signed the Comprehensive Agreement on the Respect for Human Rights and International Humanitarian Law CARHRIHL). [5] The agreement seeks among other things to protect innocent civilians who are caught in the crossfire and combatants who have ceased to take part in hostilities.

    Implementation of international humanitarian law:
    general consideration
    The 1987 Constitution encapsulates the common concern of the Filipino people for the dignity of the individual and his basic rights. Article II, section 11 stipulates that “the State values the dignity of every human person and guarantees full respect for human rights”. Article II, section 2 states that, as a matter of principle, the Philippines “renounces war as an instrument of national policy… and adheres to the policy of peace, equality, justice and freedom …”. Article III provides for a comprehensive Bill of Rights which echoes the rights laid down in international instruments.

    Worded in general terms, the rights guaranteed under the above-mentioned Bill are thus afforded to each citizen without “distinction as to race, sex, color, religion, or political persuasion”. Hence, every person, regardless of whether he is an insurgent or an innocent civilian, is guaranteed these rights. [6]

    Distinction between civilians and combatants
    In armed conflict, distinguishing between civilians and combatants is the principle that guides the conduct of military operations. The general rule is that the civilian population must be protected during military operations. There may even be instances where the safety of civilians is considered paramount even at the cost of allowing the insurgent forces to escape. The objective is to ensure that the civilian population is spared the dangers arising from such operations. [7]

    During the operation itself, members of the AFP and the PNP are required to exercise utmost restraint and caution. While the use of armed force may be necessary to accomplish the mission, it must nevertheless be directed only against hostile elements and not against civilians or non-combatants. [8] These same basic rules are set out in the Code of Ethics of the Armed Forces of the Philippines. [9] While it is true that once the safety of the troops is jeopardized self-preservation becomes their primary concern, this should be done through the judicious use of force so as to avoid or lessen material damage and civilian casualties.

    For their part, the insurgents have their own set of rules to follow in the conduct of hostilities against government forces. The NPA’s Basic Rules state that “all officers and men are prohibited from committing the slightest damage against the interest of the masses”. [10]

    Both the government and the insurgents have thus promulgated rules to protect civilians. But implementing those rules is complicated by the nature of the conflict, which is a battle for the hearts and minds of the people. The policy of involving civilians or drawing support from them for the struggle has made it inevitable that civilians are then suspected of supporting one side or the other. This has made the principle of distinguishing between civilians and combatants difficult to apply and very easy to breach.

    Special protection for children
    Children, who usually know nothing about what is happening around them, are the most vulnerable of all to the ill-effects of armed conflict. Thus, Republic Act No. 7610 was enacted by the Philippine Congress to protect children against abuse, exploitation and discrimination. The law contains provisions for the protection of children who are victims of armed conflict or who might be involved in the fighting. As an added measure of protection, the law declares children to be “peace zones”, [11] stipulating that they may not be the object of attack and are entitled to respect and special protection from any form of threat, assault, torture or other cruel, inhumane or degrading treatment. Further, the law prohibits the recruitment of children into the AFP, or its civilian units, or other armed groups including insurgents. Children may not take part in fighting or be used as guides, couriers, or spies. Finally, the law states that children must be given priority during evacuations that result from hostilities. [12]

    If and when children have been involved in armed conflict, whether as spies, couriers, guides or combatants, they have the following rights: the right to separate detention facilities, free legal assistance, notification of their parents if they are arrested, and release into the protective custody of the Department of Social Welfare and Development. [13]

    Guidelines for the conduct of warfare and use of weapons
    Precautions in attacks
    A joint circular from the Department of Interior and Local Government and the Department of National Defense outlines some important rules and precautions that their personnel should take during military operations. When the use of armed force is inevitable, utmost restraint must be exercised and only reasonable force necessary for mission accomplishment must be used. This must be directed only against hostile elements and not against civilians or non-combatants. [14]

    If engaged in actual combat where the safety of the unit is endangered, the commander may selectively apply the available means to defend his unit or position. However, he must exercise utmost care in preventing civilian casualties or material damage. [15] In addition, commanders must coordinate with local government officials and the government agencies concerned beforehand to prepare for urgent delivery of services to the areas to which civilians are to be temporarily evacuated for their safety. [16]

    “Stay-put policy”
    A directive from the military to area commanders emphasizes that, during an operation, the inhabitants of an affected area should as a general rule be allowed to remain in their residences (“stay-put policy”). This is primarily due to the difficulty of controlling large-scale movements of civilians. [17] But during combat operations, movements of civilians can occur. Plans must therefore be drawn up to anticipate this problem and to prepare the armed forces by assigning tasks to particular units. Such tasks must be coordinated with the civil authorities. In some instances, the military may be allowed to take direct control of the movements and place the civilians in holding areas until they can be returned safely home. [18]

    This directive also stipulates that before conducting an operation, a plan must be drawn up containing measures to enforce the “stay-put policy”. [19] A survey must be conducted to determine which areas are most suitable for evacuation. [20] Moreover, military personnel that are to be deployed must be briefed prior to their assignment. The briefing must stress the importance of proper conduct towards the civilian population. [21] Finally, medical teams must be made available to provide emergency medical attention or evacuation to injured civilians caught in crossfire. [22]

    Prohibited weapons
    The use of armed force is restricted to military objectives. As such, artillery fire, which may cause unnecessary damage and casualties, is subject to the approval of the tactical commander concerned or his deputy. The deputy commander must not be lower in rank than brigade commander or its equivalent. Mortar fire may be resorted to only with the approval of or on orders from the battalion commander concerned, his executive officer or an officer of equivalent command level. [23] Preparation fire may be delivered only against confirmed hostile positions prior to attack or other offensive action, and then only subject to the approval of or orders from the brigade commander or an officer of equivalent command level. Airstrikes may be used only under extreme circumstances. Targets must be carefully evaluated by the close air-support commander for approval by the area commander. [24]

    The use of weapons that cause unnecessary suffering or superfluous injury is generally prohibited. Members of the AFP are prohibited from using aerial, naval or artillery fire for interdiction and harassment, especially when the fire missions are unobserved and near populated areas, and when civilian casualties or material damage are likely to be incurred. [25] The use of weapons that are by nature indiscriminate is likewise prohibited. Hence specific restrictions are provided for the use of certain weapons which cause unnecessary damage and casualties. [26]

    Negotiation with the other side
    Government troops are directed to negotiate with the other side in cases of threatened armed confrontation and to respect the white flag of truce at all times. An intermediary panel composed mainly of local political and religious leaders usually facilitates local negotiations between government troops and insurgent groups. [27] Government representatives also negotiate cease-fire agreements in order to prevent undue damage to the government’s economic programmes and to allow everyone to celebrate holidays such as Christmas in relative peace.

    Prohibition on pillage
    Pillage is prohibited and is punishable under the Articles of War. [28] It is considered an act unbecoming of an AFP officer. [29] Hence, to protect troops from charges of looting, abuse and other forms of misbehaviour, civil relations units in the military are directed to immediately conduct a survey of the residents after the operation and properly document their findings. [30]

    Members of the AFP and the PNP are directed to respect all persons and objects displaying the red cross emblem, the white flag of truce or emblems designating cultural property. [31]

    Private physicians and other health-care personnel visiting or treating detainees are required to submit two photocopies of an identification card containing the holder’s photograph which is issued by the Professional Regulation Commission 24 hours before the visit except in medical emergencies. [32] Civil defence personnel and members of the media are also issued with identity cards.

    Specific protection
    Protecting the civilian population against starvation
    In a directive to all its commanders in the field, the AFP has recognized the need to reduce the social costs of armed conflict in the conduct of its counter-insurgency campaigns. Guidelines therefore prohibit preventing government agencies in charge of delivering goods and services from entering the areas concerned and thus unduly delaying the transport of agricultural, industrial and commercial products intended for use by the residents as part of the normal flow of commerce. The directive also stipulates that medical supplies and personnel, foodstuffs and other basic necessities should be allowed to enter freely for the use of the people. However, in actual tactical operations, such movements may be controlled as the situation requires. [33] Nevertheless, Memorandum Circular No. 139 provides for exceptions to be made to this control of basic necessities in order to avoid the starvation of civilians. [34]

    Another directive states that, when operations have ended, coordination and liaison with national and local government agencies should be pursued to ensure rapid assessment of damage, restoration of utilities, rescue, evacuation and hospitalization, provision of food and other essential supplies, including emergency facilities for food preparation, and recovery and disposal of the dead. [35] It also states that objects indispensable for survival should not be the object of attack. [36]

    Protection from attack on medical and religious personnel and medical facilities
    Medical and religious personnel and facilities are accorded protection from attack. The Articles of War prohibit attacks against churches, hospitals and other places granted the special privilege of protection. [37] Medical personnel are protected when they are providing health services. They may not be made the object of harassment. [38]

    A directive to all major area commands stipulates that medical teams must be made available to provide emergency care or evacuation to injured civilians caught in crossfire. [39] In addition, a joint circular requires members of the AFP and PNP to respect all persons and objects bearing the red cross emblem. [40] Another directive states that people must have unimpeded access to medical supplies and personnel, foodstuffs and other basic necessities. [41]

    Republic Act 7610 stipulates unhampered delivery of basic services and ensures the safety of those who provide those services. This includes fact-finding missions carried out by the government and non-governmental organizations NGOs). [42] The Philippine Human Rights Committee has also directed that non-government health workers must be permitted to go to evacuation centres to render medical and relief assistance. Medical and relief goods must be distributed to evacuees without delay, whether they come from the government or from non-governmental organizations. [43]

    Hostilities may be suspended and special measures such as “corridors of peace” adopted to allow relief supplies to reach children. “Days of tranquillity” (a cessation of hostilities for the purpose of providing health services to civilians in the combat area) are also provided for. [44]

    Military action to aid civilians must also be undertaken promptly after an operation. This includes providing medical care for sick and wounded children and other evacuees, procuring and distributing food and shelter for displaced persons and restoring vital facilities. [45]

    Protecting cultural objects
    A joint circular requires of the AFP and PNP that they respect all persons and objects bearing emblems designating cultural property. [46] It is worth mentioning that the Philippines is a signatory to both the Convention for the protection of cultural property in the event of armed conflict and to the Protocol on the protection of cultural property in the event of armed conflict. However, it has yet to ratify either instrument.

    Treatment of the individual in connection with armed conflict
    Obligation to give quarter
    Members of the AFP and the PNP have the duty to give quarter during security or police operations. They are also prohibited from mistreating innocent civilians and hostile or lawless elements who are considered hors de combat. Individuals to whom the AFP and the PNP must give quarter include those who are wounded, captured or who have surrendered. [47] The AFP and the PNP are directed to respect the white flag of truce at all times [48] and to attack only hostile elements – not civilians or non-combatants. [49]

    Instructions to military commanders require the necessary precautions to be taken for the protection of innocent civilians, treatment of the wounded and the recovery of bodies. [50] The directive requires the armed forces to coordinate their actions with the various government agencies providing aid to those affected by the operations. A joint circular lays down rules of conduct for soldiers and police during security or police operations, the objective being to prevent abuses and reduce the toll in lives and property. [51]

    Persons in detention or otherwise in the hands of a hostile party
    The 1987 Philippine Constitution states in Article III, section 12 that torture, force, violence, threats and other similar means may not be used against an accused person or a detainee. This provision also prohibits secret places of detention, solitary confinement, incommunicado or other similar detention. Confessions obtained in violation thereof are inadmissible as evidence in any court, whatever the proceedings. [52] Moreover, all units of the AFP and PNP are given specific instructions on procedures for arrest and detention. [53]

    The law allows relatives, friends and legal counsel of detainees or arrested persons access to the detention centre or jail where they are being held. Physicians and health-care personnel also have access under a joint circular of the Department of National Defense and the Department of the Interior and Local Government. [54] Regional commanders are held responsible for assisting families and lawyers in locating the detainees. There is also Republic Act 7438, on the rights of an individual under custodial investigation, section 2(f) of which states that detainees have the right to be visited by members of their family, representatives of NGOs and officials of the Commission on Human Rights. [55]

    Release and return
    A resolution was adopted by the Philippine House of Representatives on 21 December 1995 urging the President to release the “remaining 218 political prisoners still languishing in 52 different penal colonies, regional and provincial jails and other detention centers throughout the country”. [56]

    The President has issued guidelines for the granting of bail, release and/or pardon of persons detained and/or convicted of crimes against national security and public order and for cases in which the Articles of War have been violated. The first paragraph of the guidelines states the categories of persons covered by the guidelines: all persons charged, detained or convicted for violations of the Revised Penal Code, Special Laws (e.g. the Anti-Subversion Law) and the Articles of War. [57] The Presidential Committee classifies the persons covered by the programme as those charged/detained/convicted for committing (1) crimes against National Security and Public Order (e.g. rebellion and illegal possession of firearms for the purpose of rebellion) or (2) common crimes committed in pursuit of political objectives. However, inclusion in this process depends on whether an application has been properly filed and whether the alleged crime was committed on or before 27 July 1992.58 A formal procedure – from the filing of application, meeting of the committees and review until the approval of the President – is also provided. [59]

    A report on the peace process released by the Office of the Presidential Adviser reveals that 215 alleged political prisoners had been released as of 10 March 1997: 55 by conditional pardon, 42 by temporary release on recognizance, three on bail, 11 on parole, 43 by court action and 47 as a result of amnesty. [60]

    Displacement and treatment of displaced persons
    The executive branch of the government has made efforts to enable health-care services to be provided to war-torn areas by coordinating its activities with different NGOs. [61] The tasks involved were further subdivided among the various government agencies. For instance, the Department of Social Welfare and Development provides protective custody, treatment and rehabilitative services to child victims and their families while the Department of Justice facilitates the prosecution of cases involving children as victims. [62]

    The Congress, on the other hand, has enacted Republic Act 7610, which provides guidelines regarding the protection of children in armed conflict. It requires action to facilitate the reunification of families temporarily separated by armed conflict. [63] Children must also be given priority during evacuations that result from armed conflict. Measures must be taken to ensure that children in evacuation centres are accompanied by persons responsible for their safety and well-being. [64] Finally, the Act also states that, whenever possible, members of the same family must be housed in the same premises, be given accommodation separate from other evacuees and be provided with the facilities needed to live a normal family life. Children, expectant mothers and nursing mothers must be given additional food in proportion to their physiological needs. The children must have opportunities for physical
    exercise, sports and outdoor games. [65]

    The AFP has issued its own directives to field commanders regarding evacuations and displaced persons. Displaced persons are allowed or persuaded to return to their homes. This lessens the time they spend under the commander’s responsibility and reduces the danger of contracting diseases. [66] In addition, “hamleting” is forbidden in order to prevent the spread of disease. [67]

    As the aforegoing makes clear, the Philippines is not lacking in rules to implement the norms of international humanitarian law in relation to the violence besetting the country. It can safely be said that with the sheer number of these rules, our legal system is replete with proof that the government and the Filipino people in general are deeply concerned about the ill-effects of violence and conflict. It should be noted that most of these rules were promulgated as a result of intense lobbying by NGOs and other cause-oriented groups that had developed quite a sophisticated system of documenting abuses.

    These groups have also urged the creation of “peace zones”: communities declared to be safe havens for civilians and thus free of any form of armed confrontation. The concept of peace zones is an area-based, community-initiated, non-violent approach to the insurgency problem in the country. It includes cease-fires that come about when all combatants are called upon to withdraw from the peace zone. Thus, peace zones are generally regarded as an emphatic assertion of the people’s basic rights and authority. [68]

    Another positive development is the recent signing by the government and the insurgents of the Comprehensive Agreement on the Respect for Human Rights and International Humanitarian Law as a first step towards ending armed hostilities. Although divided by divergent political ideologies, it is a reassuring sign that both camps are at least united in acknowledging that in between them are civilians who ought to be protected and spared the inhumanity of war.


    1. Z. Lee and M.C. Gastardo-Conaco, Peace Zones in the Philippines, 1994.

    2. A. T. Muyot and A. T. B. del Rosario, The humanitarian law on non-international armed conflicts: Common Article 3 and Protocol II Additional to the 1949 Geneva Conventions, 1994, p. 67.

    3. Presidential Memorandum Order No. 393 directing Armed Forces of the Philippines (AFP) and the Philippine National Police (PNP) to reaffirm their adherence to the principles of humanitarian law and human rights in the conduct of security/police operations, of 9 September 1991.

    4. Letter to the Government of the Republic of the Philippines, 23 December 1986.

    5. Signed on 16 March 1998 in The Hague (Netherlands). On file with the authors and the Review.

    6. Memorandum on the reaffirmation to the adherence to the principles of humanitarian law and human rights, Order No. 393, 4 November 1991.

    7. Letter directive to commanders of major services and area commands, re: Protection of children in armed conflict, 27 September 1991, Office of the Chief of Staff, 1991, pp. 31-32.

    8. DND-DILG Joint Circular No. 2-91 (1991). This circular provides for implementing guidelines regarding Order No. 393 which directs all units of AFP and PNP to reaffirm their adherence to the principles of international humanitarian law, op. cit. (note 6).

    9. Armed Forces of the Philippines, Code of Ethics, Art. 3, sec. 2.16.

    10. Basic Rules of the New People’s Army, Principle IV, point 3, at 6.

    11. Republic Act No. 7610 (1992), Art. 10, sec. 22.

    12. Ibid.

    13. Ibid.

    14. Op. cit. (note 8), sec. 1 a(2).

    15. Ibid., sec. C, par. 5.

    16. Ibid., sec. 3, par. c.

    17. Military Directive to commanders of major services and area commands, regarding the protection and rehabilitation of innocent civilians affected by AFP counter-insurgency operations, of 15 July 1988, sec. 3.

    18. Ibid., sec. 3, par. d.

    19. Ibid., sec. 4, par. a.

    20. Ibid., sec. 4, par. b.

    21. Ibid., sec. 4, par. c.

    22. Ibid., sec. 4, par. d.

    23. Op. cit. (note 8), par. 2, sec. c (3).

    24. Ibid., sec. c (4).

    25. Ibid., par. 2 , sec. c (1).

    26. Ibid.

    27. In a recent case of bombing which caused the death of 11 civilians in Buldon Maguindanao, both the military and the Moro Islamic Liberation Front agreed to let an independent group led by Eliseo Mercado conduct its own investigation. This occurred after the military rejected the Commission on Human Rights’ report, which assigns responsibility to the members of the AFP. Father Mercado is a well-known religious peace negotiator in Cotabato City.

    28. Articles of War, Art. 76.

    29. AFP Code of Ethics, Art. 5, sec. 4 (4.2.3).

    30. Op. cit. (note 17), sec. 4, par. i.

    31. Op. cit. (note 8), No. 2-91, sec. a (5).

    32. Guidelines on visitation of detainees by private physicians and other health personnel, para. 3 and 4.

    33. AFP GHQ Letter/Directive to commanders of major services and area commands, re: Facilitating delivery of goods and services to the countryside (1990). See also Executive Order No. 309 (1987): Reorganizing the Peace and Order Council; and Office of the President, Memorandum Circular No. 139 (1991) prescribing the guidelines for the implementation of Memorandum Order No. 398.

    34. Ibid.

    35. Op. cit. (note 17).

    36. Op.. cit. (note 8).

    37. Articles of War, Art. 79. This article punishes the forcing of safeguard or the unlawful attack on buildings, monuments and other structures being given special protection.

    38. DFA, DOJ, DLG, DND, DOH Memorandum of Agreement with PAHRA, FLAG and MAG, of 10 December 1990.

    39. Op. cit. (note 17), sec. 4, par. d.

    40. Op. cit. (note 8), sec. a (5).

    41. AFP-GHQ Letter/Directive to commanders of major services and area commands, re: Facilitating delivery of goods and services to the countryside, of 22 September 1990.

    42. Republic Act No. 7610 (1992), Art. 10, sec. 22, subsections (c) and (d). See also Art. 1, sec. 3, subsection (c), par. 1.

    43. PHRC Resolution No. 91-001, of 13 December 1988.

    44. Op. cit. (note 7).

    45. Ibid. See also “AFP Task Force holds med mission”, Manila Bulletin, 27 November 1996; and Proc. No. 523 (1995): Proclamation declaring the existence of a state of calamity (man-made) in the Province of Basilan.

    46. Op. cit. (note 8)

    47. Ibid.

    48. AFP Code of Ethics, Art. 5, sec. 2 (4.5).

    49. Ibid., Art. 3, sec. 2 (2.16).

    50. Military instructions to all major service and area commanders, re: Safety of innocent civilians and treatment of the wounded and the dead, of 6 September 1989.

    51. Op. cit. (note 8), sec. a(3).

    52. Philippines Constitution, Art. III, sec.. 12 and 19.

    53. Directive of 1 November 1991, sec. 3 (b). Directive re: Memo Order No. 393, of 9 September 1991. See also Memorandum on the strict observance of human rights, MND Memorandum of 20 March 1982, par. 2. — In response to complaints about torture or maltreatment allegedly inflicted on persons arrested or investigated, especially those suspected of committing crimes against national security, this memorandum directs all units of the AFP to turn arrested persons over to higher authorities after an arrest. It also provides that no detainee shall be with the arresting officer for more than eight hours during any given day. Medical check-ups are mandatory.

    54. Op. cit. (note 8), sec. b (2).

    55. Republic Act No. 7438 (1992), sec. 2(f). An Act defining certain rights of persons arrested, detained or under custodial investigation as well as the duties of the arresting, detaining, and investigating officers and providing penalties for violations thereof.

    56. H. Res. No. 27. Tenth Congress (1995).

    57. Office of the President, Guidelines for the grant of bail, release or pardon of persons detained or convicted of crimes against
    national security and public order, and violation of the Articles of War, of 11 August 1992. The same guidelines provide for the application period and the committees to which applications should be submitted.

    58. Primer by the Presidential Committee for the grant of bail, release or pardon. Document from the files of the Office of the Presidential Adviser on the Peace Process.

    59. Ibid.

    60. Audit list of alleged political offenders who are no longer in detention centres as of 10 March 1997. Document from the Office of the Presidential Adviser on the Peace Process.

    61. Op. cit. (note 38). See also Office of the President, Memorandum Order No. 257 (1995), par. 1, sec. 2, subsection a and c: Memorandum on continuing the Child Rights Center in the Commission on Human Rights and appropriate funds thereof.

    62. Ibid.

    63. Republic Act. No. 7610, Art . 10, sec. 22 (f).

    64. Ibid., sec. 23.

    65. Ibid., sec. 24.

    66. Op. cit. (note 17).

    67. PHRC Resolution No. 91-001, of 13 December 1988.

    68. Op. cit. (note 1), pp. 6-7.

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  3. problema talaga kapag dumaan ka sa bansa na walang organisadong gobyerno maraming magyayari masama diyan tingnan mo maraming na hostage.

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