Antonio Trillanes IV

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Antonio Trillanes IV
Antonio F. Trillanes IV.jpg
Senator of the Philippines
Assumed office
June 30, 2007
Personal details
Born Antonio Fuentes Trillanes IV
(1971-08-06) August 6, 1971 (age 43)
Caloocan, Metro Manila, Philippines
Nationality Filipino
Political party Nacionalista Party (2012–present)
Team PNoy (2012-2013)
Independent (2007–2012)
United Opposition (2007)
Spouse(s) Arlene G. Orejana
Children Francis Seth Trillanes (b. 1997)
Thea Estelle Trillanes (b. 1999)
Alan Andrew O. Trillanes (b. 2001, now deceased)[1]
Residence Caloocan City
Alma mater Philippine Military Academy
University of the Philippines - National College of Public Administration and Governance
Profession Senator/Legislator of the Philippines; Public Servant; Former Navy Lieutenant[2]
Religion Roman Catholic
Website Official Website
Military service
Allegiance Republic of the Philippines
Service/branch Philippine Navy

Antonio "Sonny" Fuentes Trillanes IV (born August 6, 1971) is a former[3] Navy Lieutenant Senior Grade and currently serving as a senator of the Philippines since 2007.

He was born in Caloocan City.[4]

He was known for leading the 2003 Oakwood Mutiny when he and some 300 junior officers and enlisted men[5] of the Armed Forces of the Philippines took over the Oakwood towers in Makati City as protest for alleged rampant corruption in the Philippine government - in the Armed Forces of the Philippines in particular - and the prevalence of social injustice all over the country.[6] He was detained for almost seven and a half years after protesting against corruption.[7]

In the Senate election held in May 2007, Trillanes successfully launched a nationwide campaign from his prison cell as he ran and won a seat in the Philippine Senate on a shoestring budget.[8] He was elected to the Senate as guest candidate for the anti-administration[9] Genuine Opposition ticket, and assumed office on June 30, 2007. He made history[7] for being the first Philippine senator to be elected while in jail when more than 11 million people voted him into office on a strong anti-corruption advocacy.[10]

On November 29, 2007, Trillanes, together with the soldiers facing coup d'état charges in connection with the 2003 Oakwood Mutiny, marched out of the courtroom while attending a hearing[11] towards the Peninsula Manila hotel in Makati City, to reiterate their call[12] for the ouster of then President Gloria Macapagal-Arroyo.[13]

On December 20, 2010, he was given provisional freedom pending the recognition of the court's amnesty declaration of President Benigno Aquino III.[14]

In October 2013, Trillanes formalized his re-election bid, filing his certificate of candidacy at the main office of the Commission on Elections in Manila. He ran under the banner of the Nacionalista Party, which is allied with the ruling Liberal Party in the 2013 midterm elections.[15] He formed part of the umbrella coalition of the administration-backed senatorial line-up for the 2013 Philippine Senate election known as the Team PNoy.[16]

Formally proclaimed as a Senator in May 2013,[17] Trillanes was re-elected by 14,127,722 Filipinos as per Comelec's official tally of votes.[18]

Personal life[edit]

Known as "Sonny" to his family and friends, Trillanes was born and raised in Caloocan, to Philippine Navy Capt. Antonio Floranza Trillanes, Sr. (PMA Class '59) of Ligao City, Albay, and Estelita (née Fuentes) from Ivisan,[19] Capiz. Trillanes' other siblings are: Antonia; Antonio, Jr.; Juan Antonio ("Jay"); Antonio III ("Tiny"); and Dominic.

Trillanes is married to Arlene G. Orejana, a former member of the Philippine Military Academy corps of professors — a PMA Class 1997 graduate herself — and together they have had three children: Francis Seth, Thea Estelle, and Alan Andrew (who died at 21 days old).


His elementary years were spent at Siena College, Quezon City from 1975–1983, and from 1983–1987, his secondary education was at Angelicum College in Quezon City. In 1990, while a third year BS in Electronics and Communication Engineering (ECE) student from De La Salle University on Taft Avenue, Manila, he took and passed the [PMA] entrance examination. He formally entered into public service the following year as a cadet in the Philippine Military Academy where he graduated cum laude in 1995, while earning a degree in BS Naval System Engineering. Other awards he received while in PMA are the Mathematics Plaque, Physical Science Plaque, and the Tambuli Award for electrical/electronics engineering.

In 2002, Trillanes took up his graduate studies at the University of the Philippines National College of Public Administration and Governance, and got his masters degree in Public Administration, Major in Public Policy and Program Management.

For the duration of the masters program, he received two University Scholar Awards for obtaining two semestral GPAs of 1.0 to 1.25 and a College Scholar Award for obtaining a semestral GPA of 1.25 to 1.50.[20]

Highlights of Military Profession[edit]

After graduating from PMA, Sonny went through all shipboard assignments starting from Mess & Supply Officer; Deck & Gunnery Officer; Engineering & Damage Control Officer; Executive Officer; and, ultimately as Acting Commanding Officer of a patrol gunboat.

During his five-year sea duty experience, his unit apprehended dozens of smugglers, illegal loggers, poachers, human smugglers and illegal fishermen in numerous maritime law enforcement operations conducted in the waters off Batanes, Ilocos, Cagayan, Isabela, Zambales, Scarborough, Quezon, Bicol, Palawan, Mindoro, Romblon, Iloilo, Cebu, Zamboanga Peninsula, Basilan, Sulu, Tawi-Tawi, Davao and Maguindanao.[citation needed]

Other shore positions he held were: Administrative/Personnel Officer of Philippine Fleet Patrol Force; and Procurement Officer/Instructor, Naval Education & Training Command.

Among the highlights of his military profession, was the daring search and rescue operation for the survivors of the ill-fated M/V Princess of the Orient at the height of a super typhoon in 1998. For this act of risking their own lives in the fulfillment of their duty, Sonny and his unit managed to rescue thirty-two (32) survivors.

He was also involved in numerous naval operations in support of ground operations directed against the Abu Sayyaf and other lawless elements. As procurement officer of the Naval Training and Education Command, Philippine Navy, Sonny reformed the procurement system, which resulted to the accumulated savings of more than four million pesos in favor of the government.

He has participated in 22 naval exercises conducted with local and foreign navies. For his meritorious service to his country, Sonny has been awarded a total of 23 assorted merit medals, campaign ribbons and badges.

Political career[edit]

Trillanes filed his certificate of candidacy on February 7, 2007, to run as an independent Senator even though he was detained for coup d'état. Later, he accepted an invitation from the Genuine Opposition party (GO) as one of its guest candidates to field against the Arroyo administration. He campaigned, though in jail, through the social networking site, Friendster. He was eventually proclaimed Senator-elect on June 15, 2007 by the Commission on Elections. He is the 2nd youngest senator after Benigno Aquino, Jr. elected at the age of 35 (his partymate Bam Aquino join him as youngest senator elected in 2013)

On July 23, 2007, Trillanes' motion for an "arrangement" with the Makati RTC that would allow him to fulfill his duties as a Senator while under detention, and to allow him to attend the SONA, remained unacted upon. A week after, Judge Oscar Pimentel denied Trillanes's plea to be granted leave from detention to attend Senate sessions, and to set up an office inside Fort Bonifacio in Taguig City where he had been detained.[21] In response to Trillanes' continued imprisonment despite his election as Senator, former University of the Philippines president Francisco Nemenzo, Jr. and former vice president Teofisto Guingona, Jr. of civil society launched the "Paglingkurin si Trillanes [Let Trillanes Serve] Movement" in Pasay City on August 23, 2007. Akbayan Representative Risa Hontiveros, Ana Maria Nemenzo of the Freedom from Debt Coalition, opposition leader Jose Alcuaz, and Trillanes' spokesperson Sonny Rivera, were present.[22]

Notwithstanding calls from civil society groups to allow Trillanes to serve as Senator pursuant to his election, Judge Oscar Pimentel denied Trillanes's petition to attend Senate sessions on September 20, 2007, for lack of merit, ruling that his incarceration would not be a bar to fulfilling his duties as a Senator.[23] His petition, having been denied by the lower court, Senator Trillanes filed a petition with the Supreme Court of the Philippines, asking that his petition to be allowed to attend Senate sessions be granted. Representing him was his lawyer Reynaldo Robles. Included in said petition was a request that he be allowed to receive visitors in his jail at Fort Bonifacio.[24]

On October 17, 2007, the Supreme Court of the Philippines, in an en banc resolution, directed the Armed Forces of the Philippines (AFP), and Makati Regional Trial Court Judge Oscar Pimentel to comment within 10 days on Senator Antonio Trillanes IV's petition.[25] These requests were however later overshadowed by Trillanes' decision to stage another action against Gloria Arroyo's administration. On November 29, 2007, the senator led another uprising, this time at the Manila Peninsula Hotel in Makati. After walking out of his court hearing, he and Brigadier General Danilo Lim led their supporters to the hotel where they staged their protest against the government, calling on the public to join them. Six hours later, after military teams surrounded the hotel and armored personnel carriers broke through the hotel's front doors, Senator Trillanes and his companions surrendered.

In 2010, under Proclamation 75, President Benigno Aquino III granted amnesty to Trillanes and other military personnel accused of trying to oust the Arroyo administration. He was able for the first time to enter the Senate and perform his duties as a senator.

Trillanes stood up against Gloria Macapagal Arroyo's corrupt and oppressive regime, and was incarcerated for almost 7 ½ years. As a senator, he is the 4th most productive senator in terms of the number of bills and resolutions filed, totalling to 734 bills and resolutions, 30 of which have been passed into law. He ranks 2nd both in most number of national bills sponsored and committee hearings conducted.[1]

After formalizing his re-election bid in October 2012, Trillanes filed his certificate of candidacy for 2013 elections at the Commission on Elections main office in Manila. He is running under the banner of the Nacionalista Party, which is allied with the ruling Liberal Party in the 2013 midterm elections.[26] Trillanes was ranked ninth out of the out of the 12 winning senators. Trillanes was proclaimed senator-elect on May 20, 2013 by the Commission on Elections[27] with an official tally of 14,127,722 votes.[18]

Manila Peninsula Incident[edit]

On the morning of November 29, 2007, Trillanes, Brig. Gen. Danilo Lim, Capt. Nicanor Faeldon and other Magdalo (mutineers) officials marched out of their trial and then through the streets of Makati City, to call for the ouster of President Gloria Macapagal-Arroyo. They then had a meeting on the second floor of The Peninsula Manila Hotel along Ayala Avenue. Former vice-president Teofisto Guingona joined the march to the Manila Peninsula Hotel, as well as some soldiers from the AFP.

3 P.M. Deadline[edit]

Thirty soldiers who stood on trial for the 2003 Oakwood Mutiny walked out of court and set up a meeting at The Peninsula Manila Hotel, where they called for the ouster of Gloria Macapagal-Arroyo. They had been joined by former vice-president Teofisto Guingona, who called the gathering a "New Edsa".

Arroyo called for an emergency Cabinet meeting as she took a chopper back to the Palace amid tight security. Novaliches Catholic Bishop Antonio Tobias, Infanta Bishop Emeritus Julio Labayen, and Fr. Robert Reyes joined the Antonio Trillanes IV group, while Exec. Sec. Eduardo Ermita and Ignacio Bunye rushed back to Malacañang. PSG sealed off the Palace, while troops secured the north and south Luzon expressways.

A website forthwith appeared, proclaiming General Lim and Senator Antonio Trillanes IV as the leaders of the incident.[28] The website entry read: "Senator Antonio Trillanes, Brig. Gen. Danilo Lim, Magdalo soldiers, their guards and the people have started marching towards Makati triangle. We presently find in existence a dangerous concept where the armed forces now owe their primary allegiance and loyalty to those who temporarily exercise the authority of the executive branch of the government rather than to the country and the Constitution they have sworn to protect. That is a concept we defy and struggle to eradicate. If you believe you are a man of will and courage with unselfish motives and brave enough to fight against such tyranny, rise up and be counted!"[29]

The Philippine National Police (PNP) gave Sen. Antonio Trillanes IV and Brig. Gen. Danilo Lim until 3 pm to surrender, as it evacuated guests and personnel inside the Manila Peninsula Hotel.[30]

The PNP general also ordered later the evacuation of the press in the hotel. Brig. Gen. Danilo Lim, stated, "We make this fateful step of removing Mrs. Macapagal-Arroyo from the presidency and undertake the formation of a new government."[31]

Security forces were scheduled to arrest members of the group at exactly 3 pm. Judge Oscar Pimentel, Makati Regional Trial Court, issued the arrest order, and Director Geary Barias, National Capital Region Police Office director, stated: "Arrests will be made at 3 pm"[32]

After 3 pm, police director Geary Barias of the National Capital Region Police Office left The Peninsula Manila Hotel, since he was asked to leave by troops supportive of Trillanes. Sen. Antonio Trillanes IV dismissed the PNP 3 pm deadline, saying, "Believe me, nothing will happen after three o'clock."[33]

At least 50 Special Weapons and Tactics commandos lined up outside to assault the Manila Peninsula Hotel in Makati City to enforce the arrest of rebel soldiers. Sporadic warning shots were heard from the police outside the hotel, as smoke was seen coming from the hotel seconds after the shots. (4:01 pm) The Palace asked reporters to move out of the hotel, as armored personnel carriers arrived. Hundreds of guests scrambled to vacate, and Trillanes said they will 'wait and see'[?] Bishop Julio Labayen appealed: "Please do not storm the place, so nobody gets hurt." (4:37 pm)

Firing stopped at 4:30 pm[34][35] GMA crew, and other media personnel were trapped in the hotel, while the Palace appealed to the media and the public to stay away from Makati. Tear gas was fired into the hotel lobby as government troops advanced. Soldiers surrounded the hotel at 5 pm).[36]

The armored tank then destroyed the main facade of the Manila Peninsula Hotel to allow the troops to enter.

Chief Justice Reynato Puno, who had just arrived from Guam, stated that he would not head a caretaker government if President Arroyo was removed from power, for he wants to insulate the judiciary from politics. Prominent businessmen denounced Trillanes and Lim.


Senator Antonio Trillanes IV and Brigadier General Danilo Lim decided to compromise to arresting authorities to avoid loss of civilian lives inside the hotel.[37] Police Director Geary Barias declared that the standoff at the Manila Peninsula Hotel was over as Sen. Antonio Trillanes IV, Brig. Gen. Danilo Lim, along with other junior officers, agreed to leave the hotel and surrender to Barias after the six-hour siege.[38]


Trillanes and Lim were placed under maximum security in Camp Crame.[39][40] Anti-Arroyo rallyists marched towards Liwasang Bonifacio. Julio Labayen, bishop-prelate emeritus of Infanta, was transferred from detention in Camp Crame to the custody of the current Infanta bishop-prelate, Rolando Tria Tirona, and/or the Catholic Bishops Conference of the Philippines (CBCP). Manila Pen '50' or the personalities arrested were transferred from the Camp Bagong Diwa in Bicutan to the maximum detention cell in Camp Crame, while 11 ABS-CBN personnel were released after processing. 450 people were arrested in Metro Manila due to the curfew enforced in the metropolis and in Regions III and IV.

Novaliches Bishop Antonio Tobias, Caloocan Bishop Deogracias Iniguez, Jr. and Infanta, Quezon Bishop Emeritus Julio Labayen, all of Kilusang Makabansang Ekonomiya (KME) – lead a prayer rally at Plaza Miranda in Quiapo, Bonifacio Day, and asked Mrs. Arroyo to step down for "lack of moral ascendancy to lead the nation." Bagong Alyansang Makabayan (Bayan) held its rally at nearby Bonifacio Shrine in Lawton led by former Vice President Teofisto Guingona, Jr.. As of 1:30 pm, some 5,000 members of militant groups gathered at España Avenue to march towards Liwasang Bonifacio. At 11 am, "reserve force" / troops with 10 6 × 6 military trucks came from Fort Magsaysay in Palayan City, Nueva Ecija and passed along EDSA towards Camp Aguinaldo in Quezon City. Some personalities / detainees arrested, accused the police of "maltreating" them during their detention in Camp Bagong Diwa. Lawyer Argee Guevarra stated that retired bishop Julio Labayen was "treated like a common criminal", handcuffed and fingerprinted during detention: "Bishop Labayen was never imprisoned during Martial Law. But under the rule of Arroyo and Pidal, no less than a bishop was arrested and detained." Australia and the UK cautioned nationals in Manila. The Manila Peninsula Hotel re-opened on December 3, after assessment of damages.

On December 1, 2007, the Philippine National Police (PNP) formed a team to re-arrest Nicanor Faeldon, while former University of the Philippines president Francisco Nemenzo was freed to the custody of Akbayan Rep. Ana Theresia "Risa" Hontiveros as inquest proceedings continued against Senator Antonio Trillanes IV and 49 others at the Camp Crame Multipurpose Hall who were accused of Rebellion. DOJ Undersecretary Fidel Esconde, state prosecutors Aristotle Reyes, Philip dela Cruz and Alvin Navarro were part of the inquest panel. Inquest proceedings ended at 1:00 am, and Senior State Prosecutor Emmanuel Velasco said the resolution will be released on December 3: "Until we issue a resolution, those arrested will stay in detention or under the police custody; We will make a resolution as soon as possible. We also do not want to prolong the agony of the complaint respondents."[41] Velasco, also stated on Peninsula 50: "We are working fast to avoid prolonging the agony of the respondents. We want to see to it that if they are innocent, they can be released immediately. If they are liable, we want to assure them this is just work and there is nothing personal. There was no media personality charged. And from what I have observed so far, media did not do anything wrong during the standoff."[42] The Central Command (CENTCOM) of the Armed Forces of the Philippines remained under red alert as CENTCOM chief Maj. Gen. Victor Ibrado conducted a loyalty check among his personnel. Francisco Nemenzo, Jr. confirmed that a police general hit Senator Antonio Trillanes IV: "My civilian companions and I were not hurt. I didn’t hear any report that the civilians were hurt. But the soldiers were roughed up, especially Senator Trillanes]. I saw that a police general punched Trillanes, and then his handcuff was tightened. It appeared that they wanted to humiliate him, they dragged him by holding his belt."[43] Meanwhile, opposition senators blocked a resolution of Sen. Miriam Defensor Santiago to expel Sen. Antonio Trillanes IV from the Senate of the Philippines. Also, Philippine National Police chief Director General Avelino Razon, Jr. affirmed that it will counter media networks (ABS-CBN) suits against the PNP who also denied an allegation of a lawyer of junior officers that Senator Antonio Trillanes IV, Brig. Gen. Danilo Lim and their companions were manhandled at a police camp. Teofisto Guingona, Jr. returned to Crame to visit detained daughter, and actress-writer Bibeth Orteza was released from Camp Crame. The Bishops’ rally fizzled out, while elsewhere, loyal troops choked off support for Trillanes. 602 curfew violators were held in Central Luzon, while 479 were arrested in Calabarzon during curfew. Further, Gloria Macapagal-Arroyo's luncheon with Pampanga journalists was cancelled but she kept her Europe itinerary despite ouster attempt.[44]

Avelino Razon, Jr., chief of the PNP and the Armed Forces stated that Makati police, 32 personalities and government employee were probed for siege involvement, and also announced set talks with media / the Kapisanan ng mga Brodkaster ng Pilipinas (KBP) on December 5:"We're going to have a talk with the AFP and KBP to discuss the problem so what happened will not be repeated."[45]

On December 3, 2007, Antonio Trillanes IV asked Miriam Defensor Santiago to reconsider her expulsion Senate Resolution 228 (citing Rule 34, Sec. 97 of the Senate Rules / Art. II, Sec. 3 of the 1987 Constitution). But Senate President Manuel Villar, Jr. stated: "Kailangan 2/3 or 16 votes papunta sa explusion (You need 2/3 or 16 votes for expulsion)."[46] The Department of Justice (DOJ), 10-page resolution, filed Rebellion charges against Teofisto Guingona, Jr., Bishop Emeritus Julio Labayen, Sen. Antonio Trillanes IV, Army Brig. Gen. Danilo Lim, "running" priest Robert Reyes and 31 other individuals. It also issued a hold departure order against the 36 individuals, while 15 others released underwent preliminary investigation. Thus, the Senate of the Philippines held caucus on the arrests of media men, curfew and expulsion resolution, as Manuel Roxas II filed resolution for inquiry on the treatment of journalists.[47] The Peninsula Manila declared itself "fully operational" at noon. Sanlakas militants stormed the PNP headquarters, Quezon City (10:30 am in front of the Camp Crame main gate along EDSA) to call for the release from detention of their leaders. The Armed Forces National Capital Region Command (NCRCom), fact finding board, uncovered lapses by 100 soldiers but no Mutiny by Magdalo guards.[48] Natividad Reyes / the family of activist priest Robert Reyes appealed to Gaudencio Rosales. With situation ‘normalized,’ Hermogenes Esperon left for Malaysia. 14 arrested civilians were released by the Philippine National Police from the PNP Custodial Center in Camp Crame past 7 pm: businessman Herman Tiu Laurel, Stella Guingona, daughter of former vice-president Teofisto Guingona, El Cid Fajardo, Leonido Toledo, Evangeline Mendoza, Jose Albert, Eduardo Castro, Ferdinand Sandoval, Julie Ancheta, Maamor Lanto, Romeo Dacles, Ryan Custodio, Edgardo Viania and Ray Linaac.

On December 6, 2007, the Rebellion and inciting to rebellion case were raffled to high-profile Judge Elmo Alameda of Makati Regional Trial Court Branch 150. He handled the rebellion case against the "Batasan 6", lawmakers, and the murder case against former Batangas governor Jose Antonio Leviste. DILG Secretary Ronaldo Puno stated that defiant media can be arrested again, while Sen. Aquilino Pimentel, Jr. and Sen. Panfilo Lacson visited Antonio Trillanes IV to check on his living conditions. Pimentel told Trillanes to ‘Stay out of trouble.’ The NBI asked The Peninsula Manila for Nov 29 CCTV footages. ABS-CBN news executives assailed government officials for the arrest and cuffing of members of the media, in the Hotel dialogue. DOJ deferred motion to transfer Trillanes, Lim to New Bilibid Prisons, as Muntinlupa Representative Rozzano Rufino Biazon, an administration ally, and Deputy Minority Leader Roilo Golez opposed: "The Bilibid is an institution of convicts and Trillanes et al. are not convicts. Their detention in NBP will be irregular. It seems to be punishment while still undergoing trial."[49][50] Bishop Emeritus Julio Labayen of Infanta, Quezon, returned to Quezon province (Infanta with Bishop Rolando Tirona).

In a 48-page comment filed November 28, Solicitor General Agnes Devanadera blocked Trillanes's plea for Senate attendance. President Gloria Macapagal-Arroyo stated that the government would show no mercy to Sen. Antonio Trillanes IV and the rebel soldiers and civilians. "You saw it on television. It's clear that the actions of these few desperate men reveal just how out of touch they are with the hopes and dreams of the average Filipino."[51]

On December 13, 2007, the Makati court dismissed rebellion cases against Teofisto Guingona, Jr., Fr. Robert Reyes, Bishop Emeritus Julio Labayen, Francisco Nemenzo, Elizabeth Orteza, lawyers JV Bautista and Argee Guevarra and other civilians. Journalists (Malaya columnist Ellen Tordesillas, NHK reporter Charmaine Deosgracias and Maria Ressa of ABS-CBN) recounted their ordeals during the Manila siege at the Senate hearing on media arrest. Recently, 6 unidentified soldiers were probed over the siege and Antonio Trillanes also filed a manifestation apologizing to Makati Regional Trial Court Judge Oscar Pimentel, from whose courtroom the walkout began. The apology however, as Sen. Trillanes pointed out, was not directed at Mrs. Arroyo.[52]

On December 28, 2007, Sen. Antonio Trillanes IV and 16 accused by counsel Ernesto Francisco, in the November 29 Makati Rebellion, moved for partial reconsideration of the probable cause Order dated December 13, 2007, and to dismiss the case pending at the sala of Judge Elmo Alameda, Makati Regional Trial Court Branch 50.[53]

The Supreme Court of the Philippines, on June 27, 2008, per ponente Justice Conchita Carpio-Morales in a 16-page decision unanimously dismissed Trillanes' petition "to be allowed to attend Senate sessions, other plenary or committee hearings, to give interviews to air his comments to the press, to attend to his official functions and duties and to receive members of his staff at the Marine brig in Fort Bonifacio, Taguig."[54] Morales ruled: "All prisoners whether under preventive detention or serving final sentence cannot practice their profession nor engage in any business or occupation, or hold office, elective or appointive, while in detention; the fact that he is on trial for a non-bailable offense makes his rights more limited than those of the public; the 'Manila Pen Incident,' proves that petitioner's argument bites the dust. The risk that he would escape ceased to be neither remote nor nil, as in fact, the cause for foreboding became real; election, or more precisely, reelection to office does not obliterate a criminal charge; The Petitioner's electoral victory only signifies pertinently that when the voters elected him to the Senate, they did so with full awareness of the limitations on his freedom of action and with the knowledge that he could only achieve such legislative results which he could accomplish within the confines of prison."[55]


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  51. ^, Arroyo: No mercy for Trillanes[dead link]
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  55. ^ Kristine L. Alave (June 28, 2008). ", SC junks Trillanes dream to attend Senate hearings". Philippine Daily Inquirer. Retrieved May 18, 2012. 

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