1. That we are filing this Joint Affidavit-Complaint against MR. CHARLES WARTENBERG, MS. SUZANNE “BABES” LLANERA, MR. LUIS BUENAFLOR and MR. WINSTON SAMANIEGO (no known address); the first (Wartenberg) being the International Director of International Wildlife Coalition (IWC) and the later (Llanera and Buenaflor) as staff members of IWC with contact address at Unit 202 Crystal Mansion Condominium, South AA Street, Roxas District, Quezon City, c/o Atty. Joel Descalar, for violation of RA 8485 otherwise known as The Animal Welfare Act of 1998 a photocopy of RA 8485 hereto attached;
2. That on April 24, 2002 Mr. Wartenberg entered into a Memorandum of Agreement (MOA) with Mr. Freddie J. Farres (for The Junction Newspaper) to conduct research and documentation works on the Illegal Dog Trade in the City of Baguio and Benguet, a photocopy of the MOA is hereto attached and marked as Annex “A”;
3. That soon after Mr. Wartenberg entered into a MOA with the herein complainants, we learned that he left for the United Kingdom (UK) and therefore all coordination, reports, etc…. regarding the contract between IWC and The Junction would be coursed and/or forwarded to Ms. Llanera and/or Mr. Buenaflor;
4. That on May 28, 2002 Mr. Farres had a lunch meeting with Ms. Llanera at Dulcinea Restaurant (located at the 2nd floor of SM Megamall, Mandaluyong City) to discuss the developments regarding the MOA, and right after the meeting with Ms. Llanera other The Junction/Linis Gobyerno staff namely Ms. Bing Dawang, Ms. Grace Bandoy, Ms. Mirasol Doss and Ms. Sarah Almenar went to Dulcinea to meet with Mr. Farres and Ms. Llanera;
5. That on June 4, 2002 Mr. Luis Buenaflor went to the Junction Office in Baguio City and was given a briefing and was updated by the herein complainants on the development of the ongoing research on the Illegal Dog Trade; also on that meeting Mr. Buenaflor received from Mr. Farres two (2) affidavits pertaining to the Illegal Dog Trade in Baguio City and Mr. Buenaflor was also brought by Mr. Aquino to the vicinity of the two (2) illegally operating dog slaughterhouses;
6. That on June 17, 2002 at 10:00 AM Mr. Farres and Ms. Dawang went to the hotel room of Mr. Wartenberg located Durban Street (Oxford Suites) Makati for a meeting with him, and present during the meeting were Ms. Llanera and Mr. Buenaflor, the purpose of the meeting was to discuss the forthcoming raid and apprehension to be conducted on the morning of June 21, 2002 (Friday) on the illegal slaughterhouses located at Baguio City and La Trinidad Benguet, and that during that meeting, Mr. Wartenberg together with Ms. Llanera and Mr. Buenaflor informed us that all live dogs recovered on the forthcoming raid will be loaded into a truck for transport to a dog pound outside of Baguio;
7. That on June 20, 2002 at around 2:00 PM Mr. Wartenberg together with Ms. Llanera and Mr. Buenaflor and some members of the Special Operations Group Task Force Jericho of the DILG and an unidentified person (whom we later on identified as Mr. Winston Samaniego, a veterinarian) conducted a meeting and briefing on our group; that during the pre-operational meeting on the raids to be conducted on the illegally operating slaughterhouses, Mr. Wartenberg together with Ms. Llanera and Mr. Buenaflor again informed and assured us that all live dogs that may be recovered from the forthcoming raids to be conducted will be loaded into a truck and will be brought to a dog pound outside of Baguio for safekeeping until such time that the legal, ethical and moral aspects of the raid and apprehensions have been fully discussed and evaluated by the lawyers and/or prosecutors concerned;
8. That on June 21, 2002 at around 4:00 AM a successful raid and apprehension was conducted at an illegally operating dog slaughterhouse located at San Carlos Heights, Baguio City, herewith attached is a photocopy of the police blotter report/booking sheet, hereto marked as Annex “B” to “B-“ as proof of the raid and apprehension conducted by the Task Force Jericho;
9. That soon after, at around 5:00 AM of June 21, 2002, the raiding team together with the herein complainants proceeded to the second illegally operating slaughterhouse located at Balili, La Trinidad, Benguet for a second raid and apprehension operations, herewith attached is photocopy of “Turnover of evidence and arrested persons for violation of RA 8485”, marked as Annex “C”;
10. That soon thereafter, during our coordination between the raiding teams and our reporters we were informed that members of the IWC namely Wartenberg, Llanera, Buenaflor, and Samaniego were conducting euthanasia (mercy killing) on the recovered live dogs at San Carlos Heights;
11. That because of this alarming report of euthanasia being conducted on all the recovered live dogs, Mr. Odell Aquino immediately proceeded to the slaughterhouse and right then and there together with some members of the Task Force Jericho raiding team they witnessed the on-going euthanasia activities being conducted by Mr. Wartenberg and company, hereto attached are photocopies of photos taken by Mr. Aquino regarding the euthanasia, and The Junction Newspaper issue of June 2, 2002 hereto marked as Annexes “D” and “E”;
12. That immediately thereafter, having confirmed the on-going euthanasia activities, Ms. Bing Dawang proceeded to the slaughterhouse in order to clarify as to why euthanasia was being conducted to the recovered dogs; that upon her reaching the slaughterhouse, she learned that the dead dogs (subjected to euthanasia) have been loaded into a truck, herewith attached is a photocopy of the truck Plate No. TDC-673 used for loading the dead dogs subjected to euthanasia, together with the live dogs recovered at La Trinidad, hereto marked as Annex “F”;
13. That immediately thereafter, the IWC personnel (Wartenberg, Llanera, Buenaflor) together with some members of the Task Force Jericho raiding teams and the herein complainants (Aquino and Dawang) proceeded en route to the earlier on raided slaughterhouse located at Balili, La Trinidad, Benguet;
14. That while en-route to the slaughterhouse at La Trinidad, Ms. Dawang and Ms. Llanera were seated together at the last row back portion of the van, where Ms. Dawang inquired from Ms. Llanera why euthanasia was conducted and who authorized the conduct of such;
15. That Ms. Llanera answered that the euthanasia killings was ‘spur of the moment' decision because they cannot bring the dogs out of the slaughterhouse for fear that they might escape, and for reason that the dog cages were big and had to be cut into pieces;
16. That Ms. Llanera also told Dawang that the euthanasia is without the knowledge of the City Veterinarian, and that Mr. Samaniego was the one who injected the lethal drug to the dogs;
17. That Ms. Llanera informed Dawang that there was no certification from any person in authority as to the need for euthanasia for the recovered dogs, and even suggested that the a certification may be anti-dated to cover for the illegal act;
18. That Ms. Dawang asked Ms. Llanera where the recovered dogs will be brought, and Mr. Samaniego responded that they will be brought to La Union where they will be buried;
19. That when the group was nearing the slaughterhouse at La Trinidad, Ms. Llanera asked Ms. Dawang if the dogs should be taken from the second slaughterhouse alive, and to this, Dawang answered in the affirmative, photos of the live dogs being taken out of the slaughterhouse hereto attached as Annex “G”;
20. That at about 2:00 P.M. of the same day, we saw the truck and a passenger jeep loaded with dogs, in front of Princess Apartelle, located at Ferguson Road, Guisad, Baguio City, where the IWC staff and members of Task Force Jericho were checked in;
21. That in a meeting with Task Force Jericho and IWC, at Princess Apartelle, Mr. Wartenberg admitted that the euthanasia was a premeditated act;
22. That at about 3:00 P.M., we saw the truck bearing the dogs at the corner of Ferguson and Naguilian Rd;
23. That at about 4:00 P.M., we returned to where we saw the truck (at item 22 of this affidavit), but the truck was no longer there, however, gasoline boys at a nearby gasoline station informed us that the truck left about 15 minutes earlier towards the La Union side of Naguilian Rd.;
24. That the herein Complainants/Affiants attest to the truth of the foregoing for purposes of filing at the Honorable Baguio City Prosecutors office against the IWC members (Wartenberg, Llanera, Buenaflor and Samaniego) herein above mentioned for preliminary investigation in violation of RA 8485 otherwise known as The Animal Welfare Act of 1998.
Meanwhile affiants sayeth none.
Done this 26th day of June 2002 in the City of Baguio, Philippines
(sgd) BENIGNA “BING” DAWANG (sgd) FREDDIE J. FARRES
(sgd) ODELL P. AQUINO
Subscribed and sworn to before me this 26th day of June 2002 in the City of Baguio. I hereby certify that I have personally examined the herein affiants/complainants and that I am satisfied that they fully understood the contents of this Joint Affidavit Complaint and that they caused the preparation of the same freely and voluntarily.
Republic of the Philippines)
City of Baguio..) S.S
WE, BENIGNA “Bing” DAWANG, FREDDIE J. FARRES, ODELL P. AQUINO, all of legal ages, Filipinos, all staff members of the Junction Regional Newspaper, with office and postal address at Ground Floor, PCEC Bldg., Happy Homes, Campo Sioco, Baguio City, after having been sworn to in accordance to law hereby depose and state:
1. That we are filing this Joint Affidavit-Complaint against MR. WINSTON SAMANIEGO a known Practicing Doctor of Veterinary Medicine (DVM) with known contact address at c/o Atty. Joel Descallar, Unit 202 Crystal Mansion Condominium, South AA Street, Roxas District, Quezon City for violation of the Veterinarians Code of Ethics particularly Article II (Duty To The Community), Section 18 (Animal Welfare);
2. That hereto attached is a copy of the Joint Affidavit Complaint together with its Annexes (Annexes A to G) filed by the herein complainants at the Baguio City Prosecutors Office against Mr. Winston Samaniego on June 27, 2002 for possible violation of RA 8485 otherwise known as The Animal Welfare Act of 1998;
3. That the attendant facts and circumstances relative to the herein administrative complaint files against Mr. Samaniego before the Honorable Commission are one and the same and can be cleaned in the hereto attached Joint Affidavit Complaint filed at the Baguio City Prosecutors Office;
That the herein Complainants/Affiants attest to the truth of the foregoing for purposes of filing at the PROFESSIONAL REGULATION COMMISSION (PRC) Baguio City Regional Office against MR. WINSTON SAMANIEGO for violation of Veterinarians Code of Ethics;
Meanwhile affiants sayeth none.
Done this 28th day of June 2002 in the City of Baguio, Philippines
(sgd) BENIGNA “BING” DAWANG (sgd) FREDDIE J. FARRES
(sgd) ODELL P. AQUINO
Subscribed and sworn to before me this 28th day of June 2002 in the City of Baguio. I hereby certify that I have personally examined the herein affiants/complainants and that I am satisfied that they fully understood the contents of this Joint Affidavit Complaint and that they caused the preparation of the same freely and voluntarily.