MEMORANDUM for DMCI PROJECT DEVELOPERS, INC. to Love One’S City, and Have a Part in Its Advancement and Improvement, Is the Highest Privilege and Duty of a Citizen
REPUBLIC OF THE PHILIPPINES SUPREME COURT MANILA En Banc G.R. No. 213948 KNIGHTS OF RIZAL Petitioner - versus - DMCI HOMES, INC. ET AL. Respondents MEMORANDUM FOR DMCI PROJECT DEVELOPERS, INC. To love one’s city, and have a part in its advancement and improvement, is the highest privilege and duty of a citizen. – Daniel H. Burnham, architect and master planner of Manila REPUBLIC OF THE PHILIPPINES SUPREME COURT MANILA En Banc KNIGHTS OF RIZAL, Petitioner, - versus - G.R. No. 213948 DMCI HOMES, INC. ET AL., Respondents. MEMORANDUM Private respondent DMCI Project Developers, Inc. (“DMCI-PDI”), by counsel, respectfully states: Prefatory In December 1913, the Jose Rizal National Monument (“Rizal Monument”) was erected on the Luneta as a tomb and a memorial to Jose Rizal. Since its creation in 1907 as the model entitled Motto Stella up to the present, more than a century hence, it has been mired in controversy. The stat- ue of Rizal was criticized as a poor depiction of the national hero, dressed like a European in an ill-fitting overcoat, while the monument itself, according to the Official Gazette web- site, “shies away from magnificence. It does not tower, there are no ornate details, no grandiose aesthetic claims.”1 For decades after its installation until 1961, it stood alone in an empty field. Then the Knights of Rizal, petitioner in this case (“petitioner”), successfully lobbied for the building of a Rizal Memorial Cultural Center at the back of the monument, which was never built. But a towering steel shaft that reached more than 30 meters was installed on the monument, until it was removed two years later after widespread censure.
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