THE Commonwealth Casino Commission is “respectfully requesting” Gov. David M. Apatang and Finance Secretary Tracy B. Norita to pay the commissioners a total of $650,000, as well as the $280,000 in outstanding office rental debt.
This request was the CCC’s immediate response the day after Executive Order 2025-2 took effect, when the House of Representatives failed to act on the Senate’s rejection of the EO on July 31, 2025. Issued by then-Gov. Arnold I. Palacios, EO 2025-2 abolishes the CCC and transfers its duties and regulatory authority to the Commonwealth Lottery Commission.
In his letter dated Aug. 1, 2025, CCC Chairman Edward C. Deleon Guerrero said the ongoing Chapter 11 bankruptcy proceedings involving the defunct Imperial Pacific International ended with an auction of IPI assets to Team King (CNMI), LLC. The federal court gave Team King up to nine months to secure a casino license transfer. As part of this transfer, Team King is required to “cure” the amounts owed by IPI to the CCC.
Under P.L. 18-56, the commission is supposed to be funded by an annual regulatory fee collected from the sole license holder, IPI. However, for nearly five years, the hotel-casino investor has failed to meet its obligations to the CNMI government and is currently undergoing bankruptcy proceedings in federal court.
Deleon Guerrero provided the governor and the finance secretary with the following breakdown of IPI’s debts:
– Outstanding casino license fees from 2020 to July 2025 owed to the CNMI government — $93,015,420.
– Outstanding casino regulatory fees from 2020 to July 2025 owed to the CCC — $20,775,000.
Deleon Guerrero said $650,000 is owed to the casino commissioners. He added that the CCC also owes its landlord $280,000 for office rent at Springs Plaza in Gualo Rai. He said payment of these obligations is part of the “curing” process and noted that the CCC has an accounts receivable balance of over $20 million from IPI.
Deleon Guerrero is requesting that Finance issue payments to the six casino commissioners and Springs Plaza for all outstanding rent debt.
Aside from Deleon Guerrero, the other commissioners are Ralph S. Demapan, Mario Taitano, Thomas A. Manglona, Ramon S. Dela Cruz, and Martin Mendiola.
Deleon Guerrero also provided the governor and the finance secretary with a copy of proposed amendments to the casino law. These proposed changes, he said, would enable the CNMI’s casino industry to succeed amid current economic challenges.
Unconstitutional
Regarding the Senate communication reporting its rejection of the EO, House legal counsel Joseph M. Hallahan issued a legal memorandum stating that the EO is unconstitutional.
He said CNMI Supreme Court precedent indicates that abolishing the Commonwealth Casino Commission and expanding the Commonwealth Lottery Commission’s jurisdiction would be viewed as an unlawful restructuring that exceeds the governor’s powers under Article III, Section 15.
Hallahan said while the governor may reassign functions among existing executive offices to promote administrative efficiency, that authority does not extend to dissolving statutory agencies or transferring their powers to fundamentally different entities. Though currently inactive, the CCC “remains a valid statutory body with legally defined powers, protections, and governance,” the House legal counsel said. Its abolition and the reassignment of its duties to the Lottery Commission — an agency created for unrelated purposes — constitutes an impermissible structural transformation that invades legislative authority. Under binding precedent, such action is unconstitutional and void, he said.
In her legal opinion, Senate legal counsel Antonette Villagomez said that while the governor has the authority to reallocate offices under Article III, Section 15 of the CNMI Constitution, that authority is limited and does not allow him to legislate by executive order.
