SINCE March 4, 2016
IN RE :
A.C. NUMBER 10084
ATTY. RAUL QUIROZ
DISBARMENT CASE
DECEITFUL ACT NUMBER 10
TRANSLATION
4.1.10 TENTH DECEITFUL ACT
(Contrary to 3.1.1 & 3.1.2.1 & 3.1.2.2)
The intention to cheat is the motivation
behind when Atty. Raul Quiroz referred
to the BITUMEN IMPORT FACILITY as
a " commercial business unit" and
not a "refinery business unit" in order
to justify hiring other people to operate
the BITUMEN IMPORT FACILITY.
May I call your attention, Your Honor,
"17. The bitumen project that the
complainant was referring to was
Bitumen Import Facility that involved
direct importation of bitumen products
from other countries. This is consistent
with the Company's position that current
economic conditions make it more
profitable for the Company to import
directly than refine raw materials.
The Bitumen Import Facility does not
involve refining operations In fact, it is
not the Complainant's refinery
business unit that handles the facility
but it is commercial business unit
because it involves finished products."
PACKET 10 : LABEL 5.10.1 SHELL Rejoinder
The truth, Your Honor, is, the " commercial
business unit " which Atty. Raul Quiroz is using as
reference to the BITUMEN IMPORT FACILITY
and the "refinery business unit" as reference to
PROCESS-2 or the refinery are not different from
each other. Both of them entail plant operations.
Both of them were watched and maintained by
plant operators. Both of them had control rooms,
storage tanks for raw materials and products,
motors, pumps to started and stopped, valves
to be opened and closed. Both had raw materials
finished products. It does not follow that when you
call the BITUMEN IMPORT FACILITY as
"commercial business unit" , this plant would be
operated by employees wearing coat and tie,
a TUXEDO, not at all.
This plant is just similar to the LPG TERMINAL
SGEI (Shell Gas Eastern Inc.) that we operate
ourselves. On SGEI, we received LPG (liquified
petroleum gas) finished product in bulk quantities
loaded by huge ship tankers from abroad or from
the adjacent refinery destined for distribution to
various destinations in the Philippines and Asia.
The only difference is instead of LPG we would be
dealing with bitumen (asphalt product). In short,
all of them involve plant operations. All of them
are operating plants.
It is very clear that the intention to cheat is the
motivation behind using the phrase " commercial
business unit " as reference to the BITUMEN
IMPORT FACILITY being different from "refinery
business unit". If we would borrow the word from
Congressman Farinas during Corona's
Impeachment : This is a "PALUSOT" ( a funny,
sham alibi). This is a sham alibi to justify removal
of personnel from PROCESS-2 then hire new
operators for the BITUMEN IMPORT FACILITY.
This was a vicious deceitful act that warrant
Atty. Raul Quiroz's disbarment.
He should be disbarred.
EXCERPTED FROM THE ORIGINAL
A.C. 10084
ATTY. RAUL QUIROZ
DISBARMENT COMPLAINT
WRITTEN IN PILIPINO
Ang intensyon na manglinlang na
tawagin ni Atty. Raul Quiroz, na ang
BITUMEN IMPORT FACILITY na isang
"commercial business unit " at hindi
isang "refinery business unit" upang
bigyang katwiran ang pagkuha ng ibang
tao para mag-operate nito.
Kaya po, Your Honor, makikita po natin
"17. The bitumen project that the
complainant was referring to was
Bitumen Import Facility that involved
direct importation of bitumen products
from other countries. This is consistent
with the Company's position that current
economic conditions make it more
profitable for the Company to import
directly than refine raw materials.
The Bitumen Import Facility does not
involve refining operations In fact, it is
not the Complainant's refinery
business unit that handles the facility
but it is commercial business unit
because it involves finished products."
PACKET 10 : LABEL 5.10.1 SHELL Rejoinder
Ang katotohanan po, Your Honor, ang "commercial
business unit" na ikinakabit ni Atty. Raul Quiroz sa
BITUMEN IMPORT FACILITY at ang "refinery
business unit" na ikinakabit ni Atty. Raul Quiroz sa
PROCESS-2 o refinery ay wala pong pagkakaiba,
pareho po silang planta na pinatatakbo at
binabantayan ng operator. Pareho pong may
control room, mga tanke na imbakan ng
produkto, mga motor, mga pumps na, paandarin o
pahihintuin, mga balbula na isasara o bubuksan.
Pareho pong may raw materials at may finished
products.Hindi po komo "commercial business unit"
ay patatakbuhin ito ng mga empleyadong naka
tuxedo at nakakurbata. Ito po, ay tulad rin ng
planta na LPG Terminal (SGEI) na pinatatakbo
na rin namin. Dito, tumatanggap kami ng LPG
( Liquified Petroleum Gas, finished product po ito)
in bulk quantities karga ng malalaking barko from
abroad o galing dine sa refinery at dini-distribute
naman namin sa ibat ibang destinations sa buong
Pilipinas o saan man sa ibang parte ng Asia. Ang
pagkakaiba lang po ay imbes na LPG (LIquified
Petroleum Gas) ay bitumen (produktong pang
asphalto) naman ang iimbakin at idi-distribute sa
pagkakataong ito. Sa madaling salita ay lahat po
sila ay pare-parehong mga planta. Iisa lang po
ang nakikita nating layunin ni Atty.Raul Quiroz na
sabihin ang "refinery business unit" at "commercial
business unit" ay magkaiba kundi ang layuning
manlinlang. Kung atin pong hihiramin ang salitang
ginamit ni Congressman Farinas noong
Impeachment Trial : ito po ay PALUSOT.
Palusot po ito ni Atty. Raul Quiroz upang bigyang
katwiran na alisin ang mga tao o operator mula
sa PROCESS-2 at tumanggap ng bagong tao para
sa BITUMEN IMPORT FACILITY. Napakalaki pong
pandaraya o palusot ang pagtataguyod rito ni
. Raul Quiroz.Dapat lang po siyang ma-disbar.
Kaya po Your Honor please, dahilan po sa
panglilinlang o pagpa palusot ay alisan po natin
ng karapatan bilang abogado si Atty. Raul Quiroz.
N O T I C E
The following Justices of
the Supreme Court of the
Philippines are DEEMED
provided with copy of this
"BITUMEN PLANT_ATTY. RAUL QUIROZ'S
DECEITFUL INTENT TO CHEAT"
DECEITFUL INTENT TO CHEAT"
through Atty. Theodore
Te's PIO e-mail
address on MARCH 4, 2016
to the present and prayers
for corrective and/or
and/or investigative
and/or administrative
and/or judicial and/or
disciplinary actions
be instituted in due time.
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RETIRED FEBRUARY 2016
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Justice Alfredo Benjamin S. Caguioa
E-MAIL DEEMED SENT THROUGH
PIO CHIEF E-MAIL ADDRESS
STARTING MARCH 4, 2016
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