REPUBLIC OF THE PHILIPPINES
ENERGY REGULATORY COMMISSION
San Miguel Avenue, Pasig City
IN THE MATTER OF THE APPLICATION FOR APPROVAL OF THE 17th GENERATION RATE ADJUSTMENT MECHANISM (17TH GRAM WITH PRAYER FOR PROVISIONAL AUTHORITY
NATIONAL POWER
CORPORATION (NPC),
Applicant, No. 2018-014 RC ERC Case
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LABAN KONSYUMER INC.,
Intervenor.
VERIFIED PETITION TO INTERVENE
intervenor Laban Konsyumer Inc., thru Atty. Victorio Mario A. Dimagiba (hereinafter, ?LKI?), most respectfully moves for the Denial of the instant application as contained in the Notice of Public Hearing of this Honorable Commission dated 02 August 2018 and docketed on August 3 2018 (the ?Applicatiån?), and in connection therewith, most respectfully states as follows:
1. The instant application .must be immediately denied moto propio by the Honorable Commission for lack of cause of action and legal basis under Sections 70 and 74 of Republic Act
No. 9136
2. Under section 70, the NPC shall be responsible for providing power generation in areas that are not connected to the transmission system, the missionary electrification function shall be funded from the revenues from sales in missionary areas and from the universal charge to be collected from all electricity end users as determined by the ERC.
3. Under section 74 all forms of cross subsidies from all classes of consumers sha!l be phased out from the establishment by the ERC of the universal charge. The EPIRA law was approved on June 8, 2001 or seventeen (17) years ago.
4. Intervenor reserves the right to submit additional arguments when necessary.
Quezon City for Pasig City, Septernber 14, 2018.
OLO
ATTY. VICTORIO MARIO A. DIMAGIBA
AB, LLB, LLM
Intervenor and Counsel
No. 5 Elgin Street, Brgy. Fairview, Quezon City Roll of Attorney No. 24285
PTIR No. 5645010 / 1.15.2018/ Q.c.
IBP No. AR 001653/ 1.15.2018 / Q.c. MCLE Exemption V-000692, 419.19
dimagibavic@gmail.com
VERIFICATION
I, Victorio Mario A. I)imagiba, of legal age and Filipino hereby depose as follows:
l . I am the Presidenc and counsel of Laban Konsyumer Inc.
I prepared personally the instant Petition for Intervention.
3. I swear that the facts alleged therein are true and correct to the best of my knowiedge.
Quezon City for Pasig City, September 14, 2018
Subscribed and sworn to before me this | 4 Stday2bWSeptember, 2018 and the herein party presented his OSCA [D No.5529 1
ATTYO VICTORIO MARIO A. DIMAGIBA
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