1. Iv
Republic of the Philippines)
City of Manila .) SS
J O INT C O MPLi.IiN,I-AFFIDAVI
/-
Wtr, RU,,lL G. MOLINA and T','RCNB D. SINGGO, bof of legal ag;e,
Filipinos, and -'esidents of Kumalarang, Zamboanga de1 Sur and Pagacliart
City, respectively, after being duly sworn to in accordance rvith la",',
hereby depose and say: That-
THE PRIVATtr COMPLAINANTS
1. I, i?uei G. Molina, used to work in the Provincial Covertrrneril. of
Zarnboanga rle1 Sur. I was first appointed ers Dxecutive Assistiiiti. ii bi'
then Governor Aurora tr. Cerjiles on July 2, 2OAl wherr she serrrcri ittr'
llrst term of ollice as Pro.zincial Govr:rnor. tr rvas assig:rcd i;:i tlr: ijillc':: ci'
the Provincial Governor. Thereaftcr, on Ffebruati' 1, 200'1, slte ilr:s;i,nairlr.i
nle as her Chief oi Stafi. Frior: io my einploymcnt in tf e i)i r','it.it:j'.rl
Government, I was a meml--er of the para-lega1 staff of Artrora C,erilles in
1999 when sire was then the Representr.Ltive of the )rtd iJislr"ici. 01' l
Zam'rsoanga clcl Sur. Ii[52 salaries a.s a Secretary ii, functi<-ritin3-, ,1s pl]1-ii-
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1ega1 staff of Rep. hurora Ceri1les, however, were drawn fi'oi'ri thi:
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Depar+.ment of Environment ancl Naturai R.e sources iDDlif':) ''uht'.1') '-ii,"
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incumhent Provincia] Governol: Antr-:lio H. Cr:riiies was then thc llt:crr'l.ar'',' --.i".;
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of the DtrNR. Subsequently, i was r.rppointecl by Aurora Ccl'ilies, -"'.l1r{,' ",v;ls .-1
1y
then the Representative of the ),tct [)istrict, as her Legisiativi: Stai'i t
,1
Assistant Iil on December 1, 1999. I resigned fror:r my last pcsiticn ii: i.Lt:
Provincial Gor rnment on Januaiy l, 2AA9;
2. i, '.iyrone D. Singgo, was first employed'in t'he Provjtrciai
Government of Zanr,boanga dci Sur on July 2,2AO 1 as Executirre rtssistarrt . ,
of thc Provinciai Governor. I worked" under ituel G. Molina, the Chie{ rf i 1
Staff of then Governor Aurora Cerilles. On January 1,2AAg,l reltl:rcc,ll-. i
him as Chief of Staff. I resigneci on June 30, 2010 but stiil serve ihern iLi ''i
an unofficial capacity until December 2011, I completely terminatcil inr i' i
services and cut-off any contact u,'i[h the cortple in January 2A12 v,,'hert 'J',. /i :.
co-worker Mustapha P. Piang was a.mbushed; i]-
il
3. We may bc served r,vith iegai processes, orCers atrd irotic{rs .11 i
the following addresses:
Ruel G. Molina
Poblacion, Kumaiaran€{
Zambcanga del Sur
Page 1 of 18
Joint Com p taint-Aff idavit
Ruel G. Molina llt Tyrone D. Singgo

2. Tyrone D. Singgo
Purok Manga, Sto. Nino District
Pagadian City
THE RESPONDEN'IS
4. Antonio H. Cerilles is the incumbent Provinciaj. Governor of
Zamboanga del Sur. He used to be the Secretary of the Department of
Environment and Natural Resouces (DtrNR) and Representative of the 2^d
District of Zarnboanga del Sur;
5" Aurora tr. Cerilles was the Provincia-l Governor of Zamboanga
dei Sur during thB period 2001 to 2t,110, and is now the Representative of
the province's 2,a District. The Ceriiles couple exchange positions after
serving the maximum three terms of office;
6. For purposes of service of legal processes, "Antonio H. Cerilles
and Aurora E. Cerilles may be served with legal processes, orders and
notices, at their officia-l resid.ence in Sumadat, Dumalinao, Zarnbaanga del
Sur, however, they actually reside at Canuto Enerio Street, Sto. Nino,
Pagadian City;
ANTtrCtrDENT FACTS
1
r i ./.,
7. Both of us were trusted staff and confidants of spouses Antonio Itti
ti
H. Cerilles and Aurora E. Cerilles (hereinafter referred to as "Ceri11es )wr
Ir !
ilt
couple") both of whom have held and are still holding powerful positions in
the provincial and national governlnents;
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*11 I
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8. As trusted staff and confidants, we were directed to perform ilI
it tt /
various tasks for the Cerilles couple, including personal ci1es, and often
worked beyond regular working hou,'s and days. We wqre even required to
i
report to their residence in Pagadiarr City, and were on their beck and call
2417. Sensitive and confidential matters were discussed with us by the
Cerilles couple ranging from the pol itical, business to personal ones, and
when circumsrances warranted, we were the few ones assigned personally
by the Cerilles coupie to act decisively on any of these matters. We were
then perceived by the public as authoritative and powerful staff of the
Cerilles coupie. Our ascendancy extended over the rank and file in the
Provincial Government as well as in their household workforce;
9 - But we have reached the point in our lives that we could no
longer, in conscience, foilow the orders of the Cerilles couple. We could
not allow ourselves to be forever used as instruments and implementers of
their corrupt and criminal acts, not to mention their penchani to inflict
physical harm upon their politlcal and personal enemies even to the point
of committing murder;
Page 2 of 18
Joint Conrplai nt-A,ff idavit
Ruel G. Molina & Tyrone D. Singgo

3. 10. In tlie latter part of 2011, we received information that out'
names were ii :luded in a "hit list" of the Provincia-l Special Operations
Group (PSOG), notorious for the extr4judicial kiliings of political and
personal enemies of the Cerilles couple. The PSOG, with headquarters
inside the provincial capitoi complex, is headed by Board Member Ernesto
Mond.arte, a rabidly loyal Cer:illes foilower. The first four names in the
alleged "hit list" are as follows:
1) Balong Molina
2) Tyrone Singgo
3) Raui Ganub
4) Mustapha Piang
11. At first, we entertained doubts on the veracity of the "hit 1ist"
and considered it as empty threats and a psy-war tactic to pievent or
hinder us in our daily routine. But subsequent events made us reaiize
that the information on the threats to our lives is reliable, serious a.nd
bound to happen:
a) On November 18, 2O11, Raul Ganub, third man in the "hit list",
was gunned down in Barintawak, Pagadian City rnhiie ciriving
his public utility val. The gunman was one of his passeilgers
and a member of the PiiOG. I-Iis assailant has never br:en
arrested;
b) On January 28, 2OL2, a close friend of ours, Mustapha P.
Piang, a former community organizer of the Cerilies couple and I
the fourth man in the "hit list", was ambushed along Dao road
in Pagadian City. Fortunately, he suruived the attempt against I
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his life. He was able to identify his assailants as members oi
I
j
the PSOG. Piang was advised by tris family and relatir,'es not to
pursue any 1ega1 action against the perpetrators since they
believed that it would only be an exercise in futiiity, given ihe
immense power and influence of the Cerilles couple, as what
happened to the Ganub kiliing;
I
c) in tandem'on motorcycles, withcut
Surveiliance teams riding
plate numbers, are often seen near our iesidences, asking
peopie nearby for our whereabouts. We have also observed that
we are also being foiiou,ed or tailed by these teams. Initierliy,
the surveiliance teams wet e members of the PSOG but are norv
'$-
augmented by other armed groups riding in four-wheel vehicles
' without license plates;
12. We consider the foregcing events and circumstances as
precursors of ;erious attempts against our 1ives. We strongiy believe, as
former truste.: staff and conficlan',s of the Cerilles couple, that oul:
knowledge of the corrupt and criminal acts of the Cerilles couple during
Page 3 of L8
Joint Complaint-Affidavit
Ruel G. Molina & Tyrone D. Singgo

4. our employment under them is connected to these events ano
circumstances;
13. Thus, before the Cerille:s couple succeed in permanently
silencing us, ,,: have decid.ed to expose their corrupt and criminal acts
against the people of Zamboanga dei Sur and Pagadian City whom thev
have sworn to serve;
CORRUFTI & CRIMINAL PRACTICES
. 14. As trusted staff and confidants of the Cerilles coupie, we wert3
active participants and first hand witnesses to the highly anomaious,
irregular, corrupt and criminal practices of the couple in the provinciai
government. Due to their overwhelming dominance over us and their
subtle empioyment of pressure and threats on usi we could not Co
otherwise but follow all their orders and instructions to the letter;
Prouincial Funds and Equipntent Spent
And Used For Priuate Pu'rPoses
15. Ail through-out the three consecutive terms (2001-2010) of
then Governor and now Representalive Aurora Cerilles, provinciai funds
were freely spent and heavy equipmrrnt of the provincial governrnent vo'ere
used for the construction or renovation of buildings and establishments
owned by the ferilles couple. Office supplies and equipment, as weii as
grocery supplies and kitchen utensils, for their personai and household
use were also paici by the Provincia-l Government;
Modus Operandi
16. Both Governor Antonio Cerilles and then Governor Aurora
Cerilles personally gave specific instruction to us to withdraw the needed
construction materials, office supplies and equipment, and grocery
supplies, on a "va1e" arrangement, from favored sirppliers, namely; Golden
Daughter Enterprises, AJ Enterprises, Lucky Savers and Crishamie. The,
same instruction was given to us for the needed. hear,y anc-l lighr: a
equipment from the Provincial Engineer's OlTice. The suppliers and the
Provincial trngineer had earlier been instructed by the Cerilles couple to
act favorably and promptiy to all our requests;
17.' When construction materrials or office supplies were needed, a
bill of materials was given to us by the construction foreman. We then
issued a ovale" slip for the needeil materials to be presented to the
supplier. A government truck was used to haul the materials from the
store to the intended private es,.ablishment of the Cerilles couple^
Page 4 of 18
Joint Cornplaint-Affidavit
Ruel G. Molina & Tyrone D. Singgo

5. Thereafter, the documents to supi:ort the payment of the withdraw-n
materials were prepared, such as Purchase Request for a "ghost" deiivery
or fictitious project, Abstract of Canvas, Purchase Order, Receiving ar-rd
Inspection Report, etc. A11 the supporting documents of the disbursement
vouchers werc falsified. Upon pal'ment of the materials, the Cerilles
couple still demanded for a 3Oo/" kickback from the supplier. It was for
this reason that the prices of the materials were jacked-up b5r the
suppliers to which the Cerilles couple allowed;
18. When heavy or light equipment Was required in the project
privately owned by the Ceriiles couple, we asked the provincial engineer to
assign the needed heavy or light equipment to the project site. The heavy
or:light equipment 'uvas utilized without payment of any rental. The fuel of
the equipment was paid by the Provincial Government using faisified
documents;
19. When we need cash for some urgent malter or activity, the
Cerilles coupie woulci instruct us to get the amount from any of the
favored. suppliers. The supplier was paid, with interest, by again falsifying
the procurement papers of a "ghost" delivery or fictitious project;
Specific Aclis
20. Among the materials we withd.rew from the Golden Daughier
Enterpri.ses and delivered to the private and business establishments and
residence of the Cerilles couple and paid by the Provincial Govel'nirrent
were the folior' ;ng:
Hotel Alinduhaw, Paqcldian Citlt
a) Following the specific instruction of the Cerilles coupie, we
withdrew from the Golden Daughter Elrterprises varioris
construction materials for the renovation of Hotel Alindahavr
which is owned by the couple. The hotei is located along Rizal /
Avenue, Pagadian City. Most of these construction rnaterials i j
al-c cement, deformed Uii] S, lliC_lts, ll(J(Jt tiies d-ILLl G.I. $rt-LLr.;-
are cellrellL, LICIUIIIICL_L bars, nails, floor .L1ICS and -r.1. sheets.- -
Below afe liUIIlC of the said I-tli:tLCIlalls withdrawn frorn the l. .
i
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IIt]IUW tll C some Ul LI-[t, Ui:LlLl materials ryllll.rrawrr 11 urar Lrru
,t,t
Golden Daughter trnterprises and delivered. to the Hotei 11 l'-. ll i
Alindahaw in 2006: ti
1
A-*,'-+ -_-l D^^^1.^/ by:
Trust Receipt Date Descriplion Amount Received h'- I U
No.
BOOO 2l24l06 Deformed P 81,200.00 A11an Jamili
bars, cement
& paint
Page 5 of 18
oint Complaint-Affidavit'
J
Ruel G. Molina & Tyrone D. Singgo

6. 7995 3l3l06 Steel bars & 130,300.00 Alian Jamiii
cement
3l24l06 G.I. sheets, 107,578.50 Vanessa villarra i
2514 I
cement, steel l
l
bars, nails I
62,205.OO Vaness Villarta
2515 s l24l06 Cement, steel
bar, ho1low
blocks, etc
25L6 3l24l06 Flloor tiles & 29,290.O0 Vanessa Viliarta
cement
4losl06 Cement, etc 90,100.00 Allan Jamll
8672
7984 2 l28l06 Cement 290,000.00 Allan Jamll
c
3l23l06 Cement, steel 66,673.O0 Vanessa Villarta
2513
bars, hollow
blocks, etc
6l07l06 Steel bars, 87,467.OO Nelson lrscarlo
3015
cement,
pl1.wood, 4
I
nails, etc. ,f.
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2999 6l13l06 Cement 58,000.00 1 Vancssa vrlla-rta --t+
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16663 6173/06 Cement,
deformed
75,000.00 Nelson Hsca11o
,-ffi tt
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bars
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Cement 87,000.00 A1lan Jamrlr
77325 BIL l06
3642 8l3tl06 Deformed 77,800.00 Arlan Jamili
bars, cernent
Nelson Escario l
16660 eltrl06 Cement, 131,160.00
><
deformed
bars, G.I.
sheets, etc.
v_
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copies of the afore-stated "Trust Receipts' covering tire
materials withdrawn and deiivered are attached' hereto and
mad.e an integral part hereof as Annex "A" to."N";
b) The ceriiles couple even ciirected. us to Pa], the amount of
P2,000.00 for the telephone connection of the Hotei Alirrdahar'r,'.
Page 6 of 18
Joint ComPlaint-Affidavit
Ruel G. Molina & TYrone D. Singgo

7. We got the amount frorn the Goiden Daughter Enterprises as
instructed, payable with ir:terest in the amount of P3,600.00,
as shown in the attached Trust Receipt No. 3897 {Annex "o")
and made an integral part hereof. The amount'l'as received by
Allan Molde as indicated ii:, the trust receipt;
Philippir;:,. Parq-Medtcal and Technical scttool /PPTS)
c) Upo,r instruction to us by the Cerilles couple, various office
supplies and equipment and plastic chairs were withdrawn on
different dates in 2OOT from the Golden Daughter Enterprises
and deiivered to the Philippine Para-Medical and Technical
School (PPTS). We know for a fact that PPTS is a school actually
owned by the cerilles couple. It is located in their privately
owned land known as Enerio cornpound, Sto. Nino, Pagadian
city (The middle name of then Governor "A,r.ot, cerilles is
"Enerio"). The foilowing are some of the materials withdrawn
from the Golden Daughter Enterprises and delivered to PPTS:
Trust Receipt Date Description Amount Received by:
No.
3756 sl28l07 Floor wax P 840.00 William Macapobre
4293 6/te /07 Carbon 18,082.00 Leah Del Singgo
paper &
other
supplies
4751 7 ll la7 Lunch 16,600.00 William Macapobre
packs,
spoon & fork
18535 712107 White board 1,380.00 Leah Del Singgo
& extension
wire
4784 7 /5147 Ballpen & 895.00 Leah Dei Singgo
RER forms
18534 7l2l07 Air L0,767.50 Leah Del Singgo
freshener,
coffee
other
supplies
/ of 18
Page
Joint Cornplaint-Affidavit
Ruel G. Molina & Tyrone D. Singgo

8. 4799 7 le /47 Stand fan, 25,863.00 Leah Del Singgo
computer
inks, &
other r:ffi.ce
supplies
4365 7 l13l07 Coffee & 4,946.00 Leah Del Singgo
various
oflice
supplies
4439 7 /23107 Ofiicial 460.00 Kim Pelones
Receipt
forms &
aLcohol
4504 7l27l07 USB, coffee 6,725.4O Kim Pelones
& other
supplies
24824 812l07 I.D. holders, t3,979.50 Kim Peiones
bookpapers,
piery bank
& other
supplies
4649 8lL4l07 Offi.ce 2,550.OO Kirn Felones
supplies
388 1 lL /6 /07 Comput:r 7,928.04 Kim Pelones
inks,
signpens *ffi)
other ,--11 i
supplies i! /
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/
t?
/
3970 LLlL4lOT Oflice 1,360.00 Kim Pelones
supplies
601 1 LL/22/07 Coffee 708.00 Junie Singgo i)
(i
3832 LL 126 /o7 Computer 13,440.00 Vincent Meria ( :r,
inks & other
supplies
',,
1i'
5027 11/28107 Computer 13,300.00 Junie Singgo J-,/
V
inks & other
supplies
6151 Ll l2e /07 OIIice 3,150.00 Kim Pelones
supplies
Page I of 18
Joint Compi.rint-Affidavit
Ruel G. Molina & Tyrone D. Singgo

9. 6069 fil30la7 Piastic 69,860.00
chairs w I
desk an:r
5111 L2lsloT Steel ca.binet 14,200.00 Marilyn Catalino
5139 72l70l07 Alcohol & 3,558.00 Junie Singgo
other office
supplies
Copies of the afore-stated. 'Trt.rst Receipts' covering the
materials withdrawn ancl d.elivered' are attached hereto and
mad.e al integral part hereof as Annex "FD to "JJ";
Fi.shpond located in Htogo, Zamboanga ciel Sur
d) Upon specific instructions of the Ceriiies couple to us, variot-is
construction materials, such as cement, plyrvood, G.1. sheels
and nails, were withdrawn fi'om the Golden Daug[ter
Enterprises on September 24, ?.OO7 and delivererl io
t"heir'
privately owned fishpon'-r located in Barangay Balongbaiong, .,
Pitogo, Zamboanga del :jur. These materiais were usecl to ,i
cor:,struct their resthousc, fishpond. gates, and hatche:-y in tirc ^
iV
said fishpond. The deljvery is c.overed by Trust Receipt No- ]F
4054 dated SepternLrer 24, 2OO7 in the total amount of #
P127,583.00, a copy of which is attached hereto as Al1ncx "KL'' S i
anrl mad.e an integral part hereof. Due to the unavailabilit-v of a '-t' !
government truck, a private truck was hired and the cleliven' il i
charge of P 6,000.00, as indicated in the.trust receipt, 'i'as '/,,,'
advanced. by Golden Daughter Enterprises which charged the
Provincial Government the amount of P9,800.00, or a whoppirf /
63'/0 interest!; I
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il
cerittes Residence. paaadian citu i I ['.1
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e) As ordered by the Cerilles couple, we withdrew from the Go1de" til_/
Daughter trnterprises certain items and delivered the same to l
. their residence in Pagadian City. Some of these items are the
following:
Pag't 9 of 18
Joint ComL laint-Affidavit
Ruel G. Molina & TYrone D. Singgo

10. Trust Receipt Date Descript.ion Amount Received by:
No.
18594 sle /07 Rice, red P 72,300.O0 House helper I
I
wine i
I
3803 lLli2l07 Power 12,600.00 Driver- Gerardo
washer Aranas
3939 t7l7sl07 Videoke set, 90,807.00 A1lan Jamili
water
dispenser
38 15 11l2Bl07 Kitchen 93,500.O0* Imeida Verdida
utensils
*Similar to t?rc Deliuery Charge mentioned in paragraph "d" (lboue, Goldett
DaugL*er Enterprises aduanced- the amourrt of P 55,O0O.OO (actual cost of
the items) to the kitchen utensil supplier. The Prouincial Gouernmer* tlrcn
paid Golden Daughter Ertterpises P 93,5OO.00, tthich includeai th.e "cast
of moneg", againfor a uthopping 7O9o interesi!
Copies of the afore-stated "Trust Receipts" covering the
materials withdrawn and delivered are attached hereto al-id
made an integral part hereof as Annex "LL" to "OO';
I
:l--
Even the grocery, including personal hygiene itenrs, ol liir ttv'
t!n
Cerilles household were paid by the Provinciai Go'.'erninent- A" -41r1
i(1
W-r
lavored supplier would be asked to deliver the groccry irems Lc VI
ii)
sE1l
the Cerilies resjdence in Pagadian City. A clisbursement 9d
-$
ti
l.4
voucher, together with the supporting documents of a ghost --Jt'i
lJ! i
d"elivery, was then prepared to pay lhe delivered grocery itr:ins; 'l I
/
Cerilles Warehause. Labangan, Zamboanaa d-el Sur
I
s) Again, per standing ins;iruction of the Cerilles couple, we I
withdrew from the Goiden Daughter Enterprises varicus a-[
har4ware materials-^";;';;;.r;J ;;. ;; i" ;;t;;r*""'.q
corflpound in Laban gan, Zamboanga dei Sur. These materiais'
were used for the renovation of the warehouse which they
earlier purchased, Below are some of the materials delivered:
Trust Receipt Date Description Amount I ReceiveC by:
No.
2420 I le /06 Deformed P 782,175.80 | Ace Soriano
bars,
Page 10 of 18
J oint Complaint-Affidavit
Ruel G. Molina & Tyrone D. Singgo

11. cement,
angle bars,
PVC pipes,
etc
8364 3116/06 Furlins, 177,910.00 Allan Jamili
angle trars,
G.I. sheets
77275 7 /27 /06 Ply'wood, 267,789.OO A1lan Jamili
cement,
corrugated
sheets, etc
16653 tllrsl06 Deformed 435,879.00 A1lan Jarrr;.li
bars,
cement,
galvalume
roofs,
purlins, etc
4147 6lBlo7 Deformed 228,880.00 Ailan Jamili
bars,
galvalume
roof, cement
ll^,
it
Copies of the afore-st2ted. "Trust Receipts' covering the
materials withdrawn and d"elivered are attached heret-o and gi
,41
mad.e an integral part heri:of as Annex "PP' to "TT'; I
tri
i/
Campaign materials inthe 2OO7 Elections V
h) Even the personal campaign materials and oftice suppiies of the
party headquarters of the cerilles couple were paid by the.
-U
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Provincial Government. These materials include tarpaulin,l
Streamers, Sweat shirts, pack lunch containers, Computer inks,
)o:r
eners/ drinks, coffee, minerai wa.ter, etc. The following are /l I )-..'
/
some of the materials taken from the Golden Daughter t,/
Enterprises and used in the 2OO7 campaign: U
Trust Receipt Date Description Amount Receiveri by:
No.
18286 4-le l07 Tarpuline, P 212,905.00 A1lan Jamili
streamers,
computer
Page i1 of 18
Joint Complaint-Affidavit
Ruel G. Molina l3t Tyrone D. Singgo

12. inks, s'weat
shirths
1B238 4l2L/07 Bond paper, 59,880.00
cartolina.
t7874 4l2sl07 Long sleeves 28,000.00
shirts I
I
17886 4l2sl07 Streamers, 39,300.00
,,1
mineral
I water
t7897 4l27l07 Ballpens, 98,634.00
pencil,
envelopes,
i' etc
!
i 17806 4l30/07 Sweat L54,240.O@
shirts, pack
lunch
containers,
spoons and
forks, etc.
178OB 4l31l07 Sweat 359,133.00
shirts, etc.
4207 sl4l07 Energr 24,484.O0 Imelda Verdida
drinks,
minera-l
water
18607 s /4 /o7 Computer 36,522.OO William Macapobre
inks, styro
cups, etc. I
3900 10l23l07 Coffee 44,842.85
Copies of the afore.stated "Trust Receipts' covering the
materials withdrawn and delivered are attached her,eto: andr
made an integral part hereof as Annex "UU' to '{DDD'; r' i :
i'
)NTDOCTJMENTS. I,
27. We were tasked by the Cerilies couple to cause the pr"eparation
of the necessary documents to justify the payments o_fl the mattriais
withdrawn from the Golden Daughler trnterprises, and destroy or br.Lrn
Page i2 of 18
oint Compl,rint-Aff idavit
J
Ruel G. Molina & Tyrone D. Singgo

13. the corresponding deiivery/trust receipts once the materials were paiC by
the Provincial Government. In compliance with their order, we conferred
with the Provincial Budget Officer, Roger Montealto for the payment of the
delivered materials. We ca11ed him the "Magician" for his task. He was the
person directed by the Ceriiles couple to prepare the necessary documents
for the delivered materials. Thus, as stated earlier, fictitious projects were
fabricated to serve as bases for the d.ocuments, and that the fatsified
d"ocuments (i.e. requisition, purchase order, canvas, disburseilent
voucher, check, etc.) were, most often, prepared simultaneously in c.rne
day. Per prior agreement with the Cerilles couple, the falsified
"supportingl documents were prepared by the Gold"en Daughter
Enterprises;
22. The materials delivered 1o the private residence anci personal
business establishments and buildir:gs of the Cerilles couple were charged
to certain on-going projects, mostly to the Amusement,and Events Center
(AtrC) in the provincial capitol compound. Among our inner circie, we
called the AEC center the "graveyard of shit" where most "ghost" deliveries
were charged. Incidentaily, the initials of then Governor Aurora Cerilles is
"AEC";
23. Upon payment of the materials, as directed by the Cerilles
couple, we would ask from the Golden Daughter trnterprises the 3A"/"
"SOP" or kickback based on the amount o[ the check. We personally
received fi:om the supplier's representative the "SOP" which was usualiy
placed inside a sealed envelope and gave the same to either of the Cerilies
couple but most of the time to Governor Aurora Cerilles;
24. In view of the limited funds of the Provincial Government, the
account of the Golden Daughter trnterprises and a few other favoured
suppliers was always prioritized for payment per instruction of the Cerilles
couple. Governor Aurora Cerilles decides which supplier to be paid and
for how much. Attached, as Annex "EEE', "FFF'.and "GGG", are some of
the lists given by Governor Aurora Cr:rilles to the Provincial Treasurer;
i
25. As earlier stated, after the materials indicated in the "T;:ust
Receipt" were paid, these receipts were destroyed or burned as ordered by
the Cerilles couple. Fortunateiy, we overlooked to destroy a few of these
trust receipts which are now being used as documentary evidence of the
couple's corrupt and criminal practices. We are, however, searching for
other documents for future filing of other criminal complaints;
Page 13 of L8
Joint Complaint-Affidavit
Ruel G. Molina & Tyrone D. Singgo

14. 26. We were present when tiie Cerilles couple told Jacqueline C"
Delos Reyes, the proprietor of the Golden Daughter Enterprises, about
their desire to withdraw materials from her store on a "vale" arrangement
and that we were authorized to withdraw the materials, a:ld that the
Provincial Go,r'ernment would pay for the materials. She requested,
though, that the prices be "adjusted" or jacked-up to compensate for the
cost of money considering that the processing of the payment in the
capitol takes a iong period of time;
ILLEGAL "SUE?RES' NUMBERS GAME
l; Tyrone D. Singgo, was prrvy to the operation of the illegai "SUETRtrS"
numbers game, and further state: THAT-
27. Sometime in the middle part of 2009, then Governor Aurora
Cerilles asked me to approach the operator of the "SUETRtrS" numbers
garne and to negotiate and demand "protection mone/ and monthly
payola for the Cerilles couple. I declined citing my heary rvorkload as her
Chief of Staff. Another trusted staff, Imelda "Neneng" Verdida and Riclq,
Libre were instead given the task. The negotiation with the .SUtrTRtrS'
operator resulted in having the said operator hand to the Cerilles couple
the amount of P10.0M and monthl-1r payola of P3.0M. However, in less
than a month, the Cerilles couple had the "SUETRES" operator raideC for
failing to give them a larger share o1'the operations which they ciemanded
after receiving the aforementioned amount of P10.0M;
iun
tf
-Rt
tfl
I
28. The Cerilles couple asked a certain Liza Aranding, the .#l
proprietor of another favored supplier "Lucky Savers" to operate the
"SUETRES" game on a 50%o-50ozt profit-sharing basis with them. *#l
lt
tt i
Aranding and Libre went around the province conveying the instruction cf tit
the Cerilles couple to all the municipal mayors, who are affiliated with the /
/
Nationalist People's Coalition (NPC), to allow the operation of "SUtrTRtrS"
in their respective municipalities;
29. However, due to the ineptness of Lrza Aranding in operating the
"SUETRES" which resulted in low profits, the Cerilles, couple persoirally
took over the operations in the last week of July 2010. Under the directg
"^.- _.. ---
control of the Cerilles couple, the operations were being managed by
provinciai government-paid employees Allan Abuyog and Ruel Quirabo.
Abuyog is an ExecutiVe Assistant of Governor Antonio Cerilles and over-a,li
in charge of the provincial livelihood prograrn, while Quirabo is a
livelihood'coordinator assigned in Sta. Lucia District, Pagadian City;
30. All the municipal liveiihood coordinators of the Provincial
Government were made as "SUETRtrS' coordinators in their respective
areas. Remittances of collections ,r'rrre actually made in the residence of
Page 14 of 18
Joint Com pla int-Aff idavit
Ruel G. Molina & Tyrone D. Singgo

15. the cerilles couple in Pagadian city, particularly in the basement of their
house;
31. However in october 2011, then Governor Aurora cerilles took over
Antonio
the operations of the "SUETRES" when she discovered that Governor
in the Miss
Cerilles had a 22-year old mistress who was a runner-up .5gETRES"
;;"-rb;";* del sur beauty pageant in 2008, and used the She also
collections to buy a SUV vehicle (Montero) for his young mistress'
collections to
found out that Governor Antonio cerilles also used "SUETRES"
and
pay her college tuition fees, monthly allowance of not less than P20'000'00
for the rent of her furnished apartment in Iligan city;
32. personally witnessed the rage of then Governor Aurora cerilles
I
contestant'
when she discovered her husband's dalliance with a former beauty
she was fuming mad. I have never seen her so very enraged before'
on the
tame and
other hand., I have never seen Governor Antonio Cerilles so very
paniclry before. uncharacteristically d.ocile, he obeyed whatever
his wife
ordered. him to do. A complete opposite to his image as
a feared political
the 22-year
warlord in the province. Shortly after the discovefY, the house of
gunmen'
old girl in Guipots, zarnboanga d.el sur was strafed by unidentified
FortunatelY, nobodY was injured;
33. When then Governor Aurora cerilles took over the 'SUETRES"
Antonio'
operations in october 2o11, with nary a whimper from her husband
she assigned another person, a certain Cabarubias, to manage its
day-to-day
operations up to the present time. The operations were transferred
to a house
oi a political leader in Anonang, Dumalinao, Zag,'boanga del Sur;
g4. The Cerilles couple is using "SUETRES" collections to maintain a so-
who
called .,reward fund" for PSoG "hif' activities. A PSOG member or "asset"
executed a "hit project" was given a reward money drawn from this "reward
fund";
CRIMINAL AND ADMINISTRATIVE CASES
35. We are exeicuting this Joint Affidavit-complaint for the purpose of
filing PLUNDER, MALVERSATION and FALSIFICATION cases' and
administrative cases against Governor Antonio H. cerilles and former Governor
Sur), and
Aurora E. Cerilles (now Representative, 2"d District of Zamboanga del
and
all persons who in one way or another might havePconspired', confabulated
and in
confederated in the commission of the foregoing crimes and offenses
support of our application in the Witness Protection, Security and Benefit
Program, and for all other legal intents and purposes'
Page 15 of 18
Joint ComPlaint-Affidavit
Ruel G. Molina & TYrone D. Singgo