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Republic of the philippines)
         Cityof       Maniia        ....   .) SS



                                      APFIDAVIT.COMPLAINT

                     I,
                 PEDRO D. RAMIREZ, JR., of legal
                                                         sge, Filipino, and resident of
         Pagadian City, after being duly sworn
                                               to in accordance with law, hereby depose
         and say: That-


                                             THE COMPLAINANT

                 '   1' I was appointed as Assistant
                                                Provincial Treasure r of zarnboanga del
        sur gn April      2oo2 and designated as oIC provincial
                            15 ,
        2072', vice Filomena B. pongon, up                         Treasurer on May 2,
                                           to the present time;

             2' I may be served with notices, orders and resolution
        Purok Pag-Asa, Sto. Nino District, pagadian                 at my address at
                                                    City

                                            THE RESFONDENTS

              3' Antonio H' cerilles is the incumbent provinciai
        zamboanga del Sur'                                          Governor of
 ,l                         ^A.urora E. cerilles was the provincial Governor
        Zamboanga del Sur during the period                                  of
                                                2oo1, to 2olo, and is now the
ryil    Representative      of the province,s 2ao District;

                 4' Fo' PurPoses of service of legal processes, Antonio H. cerilles and
       Au'ora E' cerilles may be served with notic.s,
                                                         ord"ers and resolution, at their
       official residence in sumadat, Dumalinao,
                                                    zarnboanga der sur, although, they
       actually reside at canuto Enerio street, sto.
                                                     Nino, pagadian city;

                                   ALLEGATIONS OF CzuMINAL ACTS

             5' when I was appointed in 2ao2, the Provincial
       Aurora E' ceriltes who is now the Rep:resentative               Governor then was
                                                             of the 2,a Legislative District
       of zarnbaanga del sur. After the enc of her third
       husband Antonio H' cerilles became the Provincial
                                                                 term in ]une 2o10, her
                                                                Governor. He used. to be
       the Representativ,-: of the 2"d Legislative
                                                   District;

            6' As the oIC Provincial rreasurer, I am in charge in
       taxes' fees and charges, and monies for the provincial the collection of
       Zamboanga del Sur, and the disbursement                    Government of
                                                    of government funds for the
       payment of provincial obrigation to craimants,
                                                      suppliers, contractors, etc.;

             7' ln addition to my d.uties and responsibilities as oic         provincial
       Treasurer' I was      also designated by the Provincial Governor
                                                                        as member of the
                                                   Page L of 1!.
                                      Affidavit of pedro   CI.   Ranlirez, Jr.
Bids and Awards committee (BAC). I
                                                 am also a mernber of the Locai Finance
        Cornmittee and pi:.ovincial Appraisa-l Committee;

                 8'
                  since I assumed office, I have not been fully
                                                                and freely performing my
       tasks as oIC Provincial Treasurer as these were
                                                            restricted and controlled by
       then Governor Aurora cerilies and tr"ater continued
                                                                   by Governor Antonio
       cerilles' In fact, even during the three terms of then Governor
                                                                         Aurora ceritrtres,
       her husband then Rep. Antonio Cerilles activeiy interfered
       provinciai government, especialty on the finances;
                                                                     in the affairs of the

              9' I could not do otherwise but to follow all the instructions
       of the cerilles couple for fear of loss of my employment              and orriers
                                                                ana ev* of roy iife. The
       cerilles coupie wield immense pcwer aerd influence in the province.
      power and influence are not limited cver the                             And rheir-
                                                        rank and fiie of the provir:cial
      Goverrnment but extend to the officiais and personnel
                                                                of the different national
      agencies, inclur ;rg the Philippine National police,
                                                                   National Bureau cf
      investigation ano Phiiippine Drug Enforcement
                                                            Agency, by reason of their
      strong connection with former President Gloria
                                                             Macapagal-Arroyo and her
      cabinet members. Although somewhar diminished,
                                                              they still hoid power and
      influence under the ad'ministration of Pr:esident Noynoy
                                                                Aquino. They use tlreir
      weaith effectively to rnaintain and expand their influence;


      Absolute and Exclttsiue Control Of t-und.s;
  I   Ereakdawn of the Internal Contral;

ru{          10'   Then Governor Aurora cerilles and later Governor Antonio
                                                                                  cerilles
      absoluteiy and exclusively control the disbursement of
                                                                funds of the provi*cial
      Government. They dictate who gets paid first and for how
                                                                    much. No check is
      prepared with<lut the directive of the governor. They
                                                                  even sign the checks
      ahead of me! I have become a counter-signatory. sometimes,
                                                                          they aiso pre-
      sign the disburseroent vouchers. such is the reversal of
                                                                 roles in the processing
      of the disbursement vouchers anc the issuance of the
                                                              checks in the provincial
      Government' The affixing of my signature, as well as that
                                                                       of the provincial
      Accountant, has become "rninisterial" and "mechanical,
      Everything is controlled and dictated by the cerilles coupie.
                                                                         on olrr part.
                                                                            Attached,, as
      Annex uA" to Annex uJ', are pictures of checks and disbursement
                                                                           vouchers pre-
      signed by Governor Antonio Ceritrles antl made an integratr part
                                                                        hereof;

             1   1' Thus the established ccntrols as provided for in the Ne-*r
      Government Accounting system (NGAS), in the provincial
                                                                         tsudget office,
      Provincial Accounting office and Provincial rreasurer's
                                                                office in the processing
      of the riisbursement vouchers are totaltry disregarded. There is
                                                                                no prio::
      determination whether the expend,iture is necessa-ry and trawful,
                                                                         and ccverec by
      all atr]propriation and aliotroent; whether the aliotment has been
                                                                           obligateri an.d
      the expenditure has supporting documents; and whether funds
                                                                           are a'aiiai:le.
      Thus, accounts were paid even without appropriations, checks
                                                                            were issued

                                            Page ?   of 11
                                 Affldavlt of Fedno D. Ramireu, Jr.
even without the covering disbursement vouchers
                                                     and supporting documents,
     and sometimes checks even bounced;


     Checks Withowt Disbursernent Vouchers
     And Suppor-ting Doqiments

           12' During the years 2008 and 2oo9, then Governor Aurora cerilles
     ordered me to prepare checks even without the covering
                                                              disbursement
    vouchers and supporting documents. initially, I refused
                                                            and ad.vised her that it
    was illegai' The cashier trikewise refused. tsut Governor
    persisted and pressured us to follow her order'.
                                                                   Aurora cerilles
                                                      Fearing that i may"lose my
    employment {she had strong influence in the Department
                                                             of Finance during the
    Arroyo Administration) and physicar harm might befali
    reluctantly
                                                          on my person, i
                 acceded to her order;

         13' Fortunately, the coA diseovered the anomaly during the
                                                                    reguiar
    annual  audit of the books of accounrs for the years 2008 and 2o0g.
    warning of CoA to me and Provincial Accountant ordonez The stern
                                                                           for-ced then
    Governor Aurora cerilles to stop the iilegal practice
                                                              which I could not have
    otherwise prevented. trn its audit for the y.rru 2009 (Audit
I                                                                   Finding No. i) and
    2008 (Audit Finding lrtro. 1), the CoA dis.covered that checks
                                                                   in the total amount
    of P 57,12O,197'24 and P 16,053,L34.4a, respectively, were
                                                                    issued in the said
d   years. The COA Audit Reports state as follows:


          2O09 Auciit Report

          L. Check paymoute in the total amount of F5?,LA0,1S?"?4
             crere not supported. with dutry approved Diebuu,sernemt
             vouchers, contrary to sound internar contror p*licies,
             ca*si,ug doubt on the varldity and regatity of the
             transaations, accureelr of the escount balances, ieategri*y ef
             the accounting and eash records, reakiag the reopeative
             asset and expenae &ceounts overstated.


          2O08 Audit Report

          1.   claims without dury approved vouchers totaring
               P16,CI53rt 34.40 were taken up 6,a prepaid e*Ile*&es,
               contraqr to existiag rules and reguxatlons, reeuliing to
               qrverstatement of, aseets and uuderstatemest
                                                                     {3fl
               corresponding aeset or expellse accoqlrtte.

    The above audit findings were one of the reasons for the issuance
                                                                          o{ an
    ADVERStr oPINIoIri of the coA on th.: {inancial statements of     provincial.
                                                                  the
    Governrnent for the years 2O0g and 2OOg;


                                            Page 3 of lt
                               ,&ffidavit of Pedro D. Rarnirez,Ir.
14' The checks issued in 2oag, without the covering
                                                                     disbursemenr
           vouchers   and supporting documents, urere mostly payable
                                                                        to favored suppiiers,
           Lucky saver Geni'ral Merchandise and Botica JiIl
                                                               both ownec by LizaAranding
           u'ho is a relative of Governor Aurora cerilles. The
                                                                said L;;;;;"ding is also a
           big financier of the ceriiles couple during eiections.
                                                                  A copy of
           checks Issued without supporting Dotuments, consisting the coA List of
           attached as Annex "r{" to Annex "K*s" and made
                                                                             of six pages is
                                                             an integral part hereof;

           Illegal Disbwrsement of Trust Rtnd.s

                  15' with the absoiute control of the cerilles coupie over the firiances
           the Provinciai Government, the provincial funds are being                      of
                                                                     spent illegaily,
           wastefully; whimsically and uncontroliably. It was not surprising
                                                                              that tirrre anc
           again the General Fund became depleted. when this
                                                                     happened, the cerilies
           coupie (then Governor Aurora cerilles during her
                                                                three terms and incumbent
           Governor Antonio Ceriiles) ordered me to transfer
                                                                  the funds from the Trust
           F''und to the General Fund' when I objected and
                                                              explained to them that Trust
           Funds could only be spent for the specific purpose for
 1                                                                  which it was createc cr
           received, they further pressured me until I reluctantly
                                                                   acceded,;
  I

                  16' Expectediy, the CoA      d.i.scovered the aforementionec illega-l
t$ tr      disbursements in its annual audit in the years 2011 (Audit
      ti
      iI   2o1o (Audit Finding No. 1 on cash Managementj,2oog (Audit
                                                                      Finding No. g),
                                                                     Fincing Nos. 2 &
      V    3), and 2aa4 (Audit Finding No. 4). Thus, the coA Audit
                                                                     Reports state as
           follows:


                 2011 Audit.Rer:ort (During the telrn of Governor Antonio ceriiles)

                 8. tra&sfer of funds from Trust F.uad to General Fund, speef,e,l
                    Educatlon E und {sEs.}, and Ecouomic Developmeat $.und,
                    (EBF'!, vis-r&-vis in the total amouqt of F 43r2ooro6s.ss
                                                                              wrere
                    nnade without authority es provided, uqder seqtiorne gos
                    e,,d &s5 of r€epublic Act {R.A.} ?L6o and $ection s4{2} {b}  ef
                    P.p. L445 thus, the purpose for rs,hie& it was created c&&Erst
                    be pursued.

                 2010 Audit Report (During the terms of the cerilles couple)

                 tr. cash resemred. for trust ftrnds has a uegative belart,ce of p
                     262,,?.79,715.s4 in vioration of seetioro 4{3} of president{atr
                     Deeree 1.445, cauoing doubts oa the propriegr and vnlidity
                     of the transactions alrd the integrity ef the accountirug amd
                      ce,eh reeords.




                                                  Page 4 of lL
                                       Affidavit of Fedro D. Ramirer, Jr.
2' cash pertarniug to truet filnds                      has a
                total amount of p zgraodrgls.a* aegative baxance in tfue
                                                 *fro*iog governmerat
                fuuds to possible loss andler roisuse, causiag doubts
                                                                      ore the
                propriety and vatridity of the transactions
                                                            and the rntegrity
                ofthe accounting and cash records.
        3. In'tenfu;rd transfers have urEreeorded transactions
           7,272,&94.CIO and unreplenished balauce of &"
           17'471,833.84 as at year-eud, causing                 of p
           propriety and validity of the trausactior.s
                                                        doubts on th.e
                                                       and the imtegraty
                of the accounting and cash records.



        4. Trausfer of funds betweeu differemt projects
           Fuud amd between ?rust F.uad to General
                                                            within Trusf
                                                     s-uud amou&tcd te
           P I''281,76s.62 (Aanex '.8,! in violatiqn
                                                     of, $ection s4(t! of
                FD So. !.jt45.


 Intelligence Fwnd

       77   '
           The Intelligence Fund. is often being used
                                                       other than the purpose foi.
which it was created' Heavy withdr awals of
                                                   this fund were rnacie during
elections' In April 2010, prior to the IMay 2o1o
                                                 elections, then Governor Aurora.
cerilies withdrew the total amount of P3o.0M
                                                   in one week, with instructi.on
that the money be in denominations of P100 and p500,
                                                        - - ' the withdrawais v,zere
                                                              <-v "r'e
made as foilows:

                      a+                              Arnount
                  Aprii 1"9,201O                P   1O,OOO,OOO.OO
                  April 23, ZOLO                   5,000,000.00
                  April 26,2O1O                   15.000.000.00
                     Total                      P 30,000.000.aa

Attached, as Annex uL" to oN,, are copies of the
                                                 acknowledgernent receipts
signed by Elma Sebuco who counted the money
Governor Aurora Ceriiles;
                                                  in the presence of then

     18. The audited financial statements of the province
                                                          for
2010, 2OAg and 200g would show that tl:e Confidential the years ZAt1,
expenses were used in the 2010 elections. The
                                                             and Intelligence
                                                 totai expenses for the sairi
years are as follows:



                                            page ti of   X.X.

                                 Affidavit of   pede,o D. Rarnirez,.!r,
Total Expenses
                                      Year
                                2A11 (a year after the etrections)                 P 5,105,939.g3
                                2010 (election year)                               P 47,642,199.00
                                2009 (a year before elections)                     P 22,6A5,513.00
                                20OB itwo years before elections)                  P 5,551,440.OO
                             19' The above figures ctrearly inclicate that the ceiiles
                                                                                       couple used the
                     confrdential ai:c Intelligence fund.s for political
                     pllrposes' trn 2008 or two before the elections,campaign and eieciion
                                                                                total [onficentiai and
                     Inteliigence expenses r,/as relatively low at p 5,551,44o.oo
                                                                                   only. trt increased i:y
                     a-bout 450% or iri the amount of p 22,6as,s13.00
                                                                              in 2009, w,hich ie a 3.ea.i-
                     before the  etrections when the cerilles couple started to prepare
                                                                                        and strengthen
                     their politicai organization. In the eiection year 2010,
                                                                               the expenses more than
                     doubled when the total' confidential and .tntelligence
                                                                                     expenses ::eaci-red.
                     P47,642,1q9.CIo, and. trso,OoG,Ooo of the saic
                                                                         amount was withdrarvn in a
                     week's time (Apnl 79-26,2010). Ttie expense$
                                                                         substantially tapered cff afier
            l        the elections, the totai arnounted onry r,, p 6,10s,g3g.g3
            I
                                                                                 in 2011;
     _.1




        l
                     Canstru ction Maieria'Ls, Afrfice Swpplies,
     rf
adffi                Gracet'ies Far The Friuate EstabtishrrLerrts
ti/&i
i{ 'ru
                     And Residence; t*;e of Gouemrment Heaug
                     Equipment Without Rental, etc.
                Il
                l          2a' For three consecutive terms of then Governor Auroi-a           cer-iiles,
                     various construction materials, of{ice supplies, grocery
                                                                                    items, etc" -i,vere
                     withdrawn from favored suppliers and deliverecl to the private
                                                                                       establishrients
                     owned by the Cerilles couple, inciuding their residence
                                                                             in Fagadian ciqy. Tirese
                     materiais were covered by delivery or trust receipts and
                                                                               duly acknowlecged iry
                     the workers in the said estabtrishments" These establisi:ments
                     followiag:
                                                                                              are tl.ie

                           a)      Fiotel Alindahaw, pagadian City
                           b)      Aiindahaw L,akeview Resort, Lakeview, zamboanga del s*r
                           ^
                           v)      Pensionne Yilana, Fagadian Cily
                           d)      Boss Coffee, Pagadian City
                           e)      ivfcDonald's, Pagadian City
                           0       Building Resources, pagad"ian City
                           oI
                           bt      Jetti Gas Station, pagadian ")ity
                           h)      I-and Transportation Office, :ragadian Cifv
                           i)      cerilles (sKT) Labangan warehoue, Labangan, zanaboanga dei         sur
                           i)      Bb-gan;an Broaccasting cortr,oration Eruilding, pagadian
                                                                                            ci{y
                           ki      She11 Gasol"ine Station, pagadian City
                           1)      Vetera^rs Bank Btlilding, pagaciian Ciqy
                           m)      Philippine Para-&{edicai arid Techni.cal school, Enericl co:iipaui:.c,
                                   Pagadian City


                                                               Page 6 of 3.i
                                                   &ffidawit cf Fedro #. ffiai.nireu,.!n.
21' Then Governor Aurora ceilles assigned Ruel
                                                                G. Moli*a anc tlrr,rne
           singgo, who  were her chiefs of staff, to overse" trr* withdrawal
           and their delivery to the private estahlishments                   of the mareria-ts
                                                                of the cerilles coupie. The
           couple also assigned Provincial Er.ldget officer,
                                                             Roger Monteaito, to oversee tire
           preparation of the necessary d.ocurnents for
                                                             the payment of the delivered
           materials' And I was instfi-lcted to issue the check for
                                                                         the r:ayr.nent ol ti:*
           covering ciisbu rseirrent vouchei-"

                  22'  The "sl:pporting cocurnents", such as purchase request,
                                                                                absir-a.*1; ci
           canvass' BAC re;olution, purchase order, inspection
                                                                  and acceptance i.epcrr,
           etc', of the disbursement vouchers were all FALSIFitrD.
                                                                     These were prepare*
           by the suppiier upon the direction of Roger Montealto.
                                                                      i{e is kno,wn as the
           "Idagician" for being able to com.e up with the
                                                           source of funds, the pro;es:i io
           whicir  these rnaterials were charged, anc devise a .,ghost
           construction rnateriais, off?ce materials and" equipment.        ceiiveryl cf
                                                                      The construction
           materials welre often charged *.o the Amusement and
                                                                   Events centei. {AEC),
           located inside the Provincial capitoi cornplex, whi.ch
                                                                  has been an o^t*g;ing
           project for a long period of tirne;

                23' As soon as the "suppoi:ting papers" were completed,
 I
          disbursernent rrouchers were theri prepaied and
                                                                           the cciv*ring
                                                             the corresporlrling checks
 /        issued' These checks were prioritized for payment- as emphaticaily
                                                                             ordered 1:-v
          the Ceilles cou.ple;
m$
.   r.
     ll
     II       24' Thus, i hereby support and ,;onfirm the allegations of
     iland xlrrone D' singgo in their Joint complaint-Affr<lavit
                                                                         Ruel G. Mc.lina
                                                                  whichr they signeri on
     U Jarruary 11, 2Q12 iir the City of Man..la that
                                                       various constructiori materrais,
       office supplies and equipment and ev:n bags of rice anc
                                                                    grocery iren:s vere
       u'ithcrawn frorrr r-he Golden Daughter Enterprises on different
                                                                          accasions *nd
       delivered to the private establishrnents and residence
                                                               of the ceriiles ccui:ie. i
       have personal knowledge of these deliveries for the reason
                                                                      that i signei rhe
          disbursernent   vor-1.c1-lers   and the checks covering these delivered materials;


          Fauored &sppliers an"d" Contractors

                 25'   As repeatedtry instructed to rne by t.he Cerilles cor:ple, the
                                                                                       favoreu
          suppiiers and contractors of the coupl.e were paid first. As
                                                                         soon as the Internal
          Revenue Allotment {IRA} was received, the cerilies couple
                                                                       gave rne lists or iictes
          indicating the suppiiers and contractors to be paid and the
                                                                        respective ar-ncunts.
          The foiiowing are the favored suppliers and conti-actors
                                                                       of the Cerilies rvhich
          have been granted most of the supply and consiruction projects
                                                                              an4 p::;*rit;;re*
          for payment:

                a)   Lr.rciqy Saver General Mercharrdise
                b] Golden Daughter Enterprises
                c) A..J. Enterr:rises

                                                       Page / of 13.
                                           &ffidawit of Fed:"o D. Rannlrez, Jn.
d) E.L.B" Enterpises
            e) Alajeno Construction
            f)    ZMS Construction

     Attached, as Anrrex oo" to Annex *L)o, are copies
                                                          of some of the directives af ihe
     ceriiles couple t{, -r.e, and mace an intr.gral part hereof;

            26'   wher: I issued checks without the afore-said prior directive,
                                                                                 then
     Governor Aurora ceriltres asked me to exptrain and
                                                           show my basis for issuing
     the checks, especially wLren these were i.ssued to orcinary
                                                                 suppliers. ALtache.l,
     as Annex "V', is a copy of a witten order for rne to
                                                            expiain which is maie an
     integral part hereof;


     unrernitted Brfi withhotding Toxes & Gsfs contribwtians

            27 ' The Eross rnismanagement of the fund.s
                                                                 resultec in the r.,on-
     payment of rnanCatory obligations, non-rerni.ttance
                                                          of v/ithholcing          io tiie
     BIR and Pl"erniurns and. Salary. Loan antortizations to the Taxes ,*rhichl
                                                                          GSIS,
     consequently disqualified the provinciatr employees front
                                                                avaiiing of t1:e 1:e*ef;ts
     fnorn the GSIS;

          28' The comrlrission on Audit {CcA} has discovered r-ire faiiure
   Provincial Governrnent to rernit to ttre aforementioned agencies
                                                                              cf the
l regular annuatr audit. Thus,                                          curi::g its
lt                              one of, the IinAlings in the COA Audit Reparr in tj^re
II years 2010" 2009 and 2008, include tire non-remittance of Withhoiding Taxes
   to the BIR;
rl
           2O 1O    Audif Egpprt (During the terrns of the Ceriiles couple)

          LS. E.Im.rexm,i*ted wi&hheld taxes +fl #SSrI"69r?B#.#6 iasesee.sed
                                                                                 fuy
             $#.v*V@/a f'nom prexriowe yee!. of #S$r4Ar[rf*f.fe
                                                                  f.xe s'iola'&$.sm
             &o *xistf.mg BXR ruXes e,md regulati,ome"

           2oo9 Audit Report (During the term of Governor Aurora cerilles)

           s'   E{uge aro.oex$.t of w"i&&.&etrd gexee &ota!}*ug wfl sss,4&q$?Bf.$*
                 remaixaed r.anrepe,r,Eted &s at year-errd, iru wiarletiom t*r
                 exi.stimg B$$Q. rqelee amd regaalatiCIrls e&$eslmiug gewerruxmenr.&
                 fil*nds t<r posei&Ee Loss am,d/CIr mis&se.

          2Qo8     4udit Report {During the term of Go,,,ernor Aurora cerilies}
          4.     wi,tfu3aeEd. taxce {m t&e tcta} mxsaou.mt o$"           p
                                                                         xd,4#sos#?.x$$
                 rexms.$med, ae at Srear-emd, im viwlatiern to exi.s&terg
                                                                                rarles, am*
                 regtalat{c,ses isn. the wi,*hfu*}d.i,xrg ms}d remittaru*e e,f .f,m-rses
                                                                                      amm,
                 exposing So.lsegffime*t {tsmds *o poesibSe loss *md,1tlr lminrase,


                                              Fage i of 13.
                                   AffidavEt of Fedro D" Rarmirez, Jr.
' Ti:e year-end balances of Due to
           29
  Provincial Gcvernrnent faiied                Gstrs clearly shorv that
  empl0yees'
                                to ren:it to the G*IS the premiums the
                Ioan amortizations. per ccA                                   and
  2AA7 ta 2a11, the amounts                  Audit Report for the past fiv* ye*rs,
                            Due to    GSILT,          are as foil0ws:
                       Year
                                                                       Arnount
                      201 1
                                                                 P 74,29a,991.?g
                      20 i0
                                                                 tr   74,261,006.55
                      2009
                                                                P 90, 199,355.41
                      2008
                                                                P 75,946,966.53
                      2AA7
                                                                tr 78,53 7,919.43
 Attached, as Annex ,.Ifr/, to
                               Annex ..yr, are copies of a fe-w
         ."0 Dernancl Letters sent hv the GSIS                  of tl:e l.{ot_ice cl
 3:nH:,                                              to then Governoi. Au-rr:r:r

       30' As orderec b'y then Governor
 GSIS' were not prioritized"            Aurora cerilles, payments to
                             Even though I have the chect<s          But ai:.,:r
 prepared' these   I/ere not i'eieased per                 t" these agencies
                                           her order, her.ce, they became
 coA Audit Report lbr the years                                              sta,e. ,rhe
                                     2a06 anc 200g include a
 s{-aie c}iecks' A copy                                          finding cf unreleasecl
                        of a- list of stale checks mcstly
                                                             to the BIR for the pcr:ir:ci
                           attached, as Anne N"z,,and
                                                           ,{nnex *z-t,,and
ffi[i;#ffi]_:;l*'"                                                                    rcarle an

       3   i ' I am executing this Affidavit
                                             ior the purpose of {rling the
 crirninaL and adininistrative                                              appr:r:p; iate
                                  cases against Govemor Antonio
former Gorerrlor {urora tr' cerilles                                   L{. ceriiles afld.
zamboanga del                                 {now Representative, Znd Disti-ict oi
                    l*"1)' and all persons who in one way or another might have
':onspired' confabulated and
                                  corrfecerated in the commission
:rimes and offenses; in support                                       of ti:e foregcing
                                      of our application in the witness
securiqr and Beneflt Prograil;                                               Fi-otecticn,
                                   to confirrn the allegation" .r
                                                                  nu"r
                        in their J.int complaint-Afndavit which G. L4oLina and
*n-Jr rlti'f*t
     '--*--J *'' oJ12 in the city of                                  they signed on
                                       Maniia; anc for aii other lega-l
purposes.                                                                  intenrs ar:d

     IN wlTllEss WHEREOF, I have
                                     }:ereunto set my hand on ihis rrlr: -,r.:i, . .
                                                      fiano or} **+ r/ -- ii.r,]'il,r
January,2013 atthe cityof
                          hilanila, Fhilippin""]"1rry


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                     SUTSCRIEED AND SWORN
                                                 to before me
                2073 at the c1Y:lnn""rl-,"ir.lrippi*"*.
                                                        orn.r, ,on this _   day of january,
                                                                                           exhibited to me his
               i:Tffi",i'i, iffi '"';l t             :[ # xil p                       e'lu-Ti::: 1L",, * c ,lri.,,,er,s
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        lr    Poblacion, Kumalafang, i-rn
                               .
                                                               ^Bjt Filipino and resident of
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              sa]':                                                                O"po*" ..,.c
        U
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                      TI-{AT      I have personal
             and allegations contained knowtredge and tirat ail the information, sta.l.enients
                                       herein are irue ancl correct to
             personal          knowlerige;                                 the best                                              cf     rnri

                                                                          h

                     ?HAT I herel:y certify that i
             'prcceecing invoiving the                irr* not commencec any othe;^ aciion or.
                                                  issues i* 1i-r"'supreme c"rl.t,
                                           "*rr.there"t ; -r,
              Appeals, or different Divisions                                     the court cf
              rind that to the best of *y p"rronal_know1ed.ge, ";;;;;;d;r*runal      oi- aseiicy
              pending in the supreme br,rrt,                     no such action c
              l-hereof, or any othei tribunaf
                                                    the court'-ol appeals or d;;I;:"xi.iTI;I
                                              *u* or agency; and
                     TFIAT should        I iearn
                                       that simiiar
             is pending b'efore the supremeacourt, a-ction or proceecing has been filec, c;.
                                                    the corr.t of Appeals or the clifferent

                                                Affidavrr     J;-;-H"J.'*u*,n*,,,,
j"-x-;'"'-'*""-
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          divisions thereof'.-or any
          court within five (5) days other tribunal, court or agency,                                           tr srrarl so   norii..
                                     frorn such                    knowledge.                                                   _ __.^*,   t1:,;


          ,*,,,*l},         Hf::,f'fiY:,k*il:ffi;T::,1", *, hand on thi s i 7.,. n6;,                                                       .',f
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             SUBSCRIBED AND SWORN                         *i,[N t $ 2il13
                                          to before me
       2013rat the cir{:lrvranila,
       License No'                  itiiippirr-".-irnrit.on this _ to day of Ja.r-ru;rry,
                                    -i""u"a               exhibited      rne his
                   'Io4-95-oqglaz
       February Zl,2Ol2 and,t"               by the i,and-Transportaticn Di:i,,,er,s
                                ."pi._ on February 13, 2015.                   office oil




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Pedro Ramirez Affidavit (part 2) Graft and Corruption

  • 1. Republic of the philippines) Cityof Maniia .... .) SS APFIDAVIT.COMPLAINT I, PEDRO D. RAMIREZ, JR., of legal sge, Filipino, and resident of Pagadian City, after being duly sworn to in accordance with law, hereby depose and say: That- THE COMPLAINANT ' 1' I was appointed as Assistant Provincial Treasure r of zarnboanga del sur gn April 2oo2 and designated as oIC provincial 15 , 2072', vice Filomena B. pongon, up Treasurer on May 2, to the present time; 2' I may be served with notices, orders and resolution Purok Pag-Asa, Sto. Nino District, pagadian at my address at City THE RESFONDENTS 3' Antonio H' cerilles is the incumbent provinciai zamboanga del Sur' Governor of ,l ^A.urora E. cerilles was the provincial Governor Zamboanga del Sur during the period of 2oo1, to 2olo, and is now the ryil Representative of the province,s 2ao District; 4' Fo' PurPoses of service of legal processes, Antonio H. cerilles and Au'ora E' cerilles may be served with notic.s, ord"ers and resolution, at their official residence in sumadat, Dumalinao, zarnboanga der sur, although, they actually reside at canuto Enerio street, sto. Nino, pagadian city; ALLEGATIONS OF CzuMINAL ACTS 5' when I was appointed in 2ao2, the Provincial Aurora E' ceriltes who is now the Rep:resentative Governor then was of the 2,a Legislative District of zarnbaanga del sur. After the enc of her third husband Antonio H' cerilles became the Provincial term in ]une 2o10, her Governor. He used. to be the Representativ,-: of the 2"d Legislative District; 6' As the oIC Provincial rreasurer, I am in charge in taxes' fees and charges, and monies for the provincial the collection of Zamboanga del Sur, and the disbursement Government of of government funds for the payment of provincial obrigation to craimants, suppliers, contractors, etc.; 7' ln addition to my d.uties and responsibilities as oic provincial Treasurer' I was also designated by the Provincial Governor as member of the Page L of 1!. Affidavit of pedro CI. Ranlirez, Jr.
  • 2. Bids and Awards committee (BAC). I am also a mernber of the Locai Finance Cornmittee and pi:.ovincial Appraisa-l Committee; 8' since I assumed office, I have not been fully and freely performing my tasks as oIC Provincial Treasurer as these were restricted and controlled by then Governor Aurora cerilies and tr"ater continued by Governor Antonio cerilles' In fact, even during the three terms of then Governor Aurora ceritrtres, her husband then Rep. Antonio Cerilles activeiy interfered provinciai government, especialty on the finances; in the affairs of the 9' I could not do otherwise but to follow all the instructions of the cerilles couple for fear of loss of my employment and orriers ana ev* of roy iife. The cerilles coupie wield immense pcwer aerd influence in the province. power and influence are not limited cver the And rheir- rank and fiie of the provir:cial Goverrnment but extend to the officiais and personnel of the different national agencies, inclur ;rg the Philippine National police, National Bureau cf investigation ano Phiiippine Drug Enforcement Agency, by reason of their strong connection with former President Gloria Macapagal-Arroyo and her cabinet members. Although somewhar diminished, they still hoid power and influence under the ad'ministration of Pr:esident Noynoy Aquino. They use tlreir weaith effectively to rnaintain and expand their influence; Absolute and Exclttsiue Control Of t-und.s; I Ereakdawn of the Internal Contral; ru{ 10' Then Governor Aurora cerilles and later Governor Antonio cerilles absoluteiy and exclusively control the disbursement of funds of the provi*cial Government. They dictate who gets paid first and for how much. No check is prepared with<lut the directive of the governor. They even sign the checks ahead of me! I have become a counter-signatory. sometimes, they aiso pre- sign the disburseroent vouchers. such is the reversal of roles in the processing of the disbursement vouchers anc the issuance of the checks in the provincial Government' The affixing of my signature, as well as that of the provincial Accountant, has become "rninisterial" and "mechanical, Everything is controlled and dictated by the cerilles coupie. on olrr part. Attached,, as Annex uA" to Annex uJ', are pictures of checks and disbursement vouchers pre- signed by Governor Antonio Ceritrles antl made an integratr part hereof; 1 1' Thus the established ccntrols as provided for in the Ne-*r Government Accounting system (NGAS), in the provincial tsudget office, Provincial Accounting office and Provincial rreasurer's office in the processing of the riisbursement vouchers are totaltry disregarded. There is no prio:: determination whether the expend,iture is necessa-ry and trawful, and ccverec by all atr]propriation and aliotroent; whether the aliotment has been obligateri an.d the expenditure has supporting documents; and whether funds are a'aiiai:le. Thus, accounts were paid even without appropriations, checks were issued Page ? of 11 Affldavlt of Fedno D. Ramireu, Jr.
  • 3. even without the covering disbursement vouchers and supporting documents, and sometimes checks even bounced; Checks Withowt Disbursernent Vouchers And Suppor-ting Doqiments 12' During the years 2008 and 2oo9, then Governor Aurora cerilles ordered me to prepare checks even without the covering disbursement vouchers and supporting documents. initially, I refused and ad.vised her that it was illegai' The cashier trikewise refused. tsut Governor persisted and pressured us to follow her order'. Aurora cerilles Fearing that i may"lose my employment {she had strong influence in the Department of Finance during the Arroyo Administration) and physicar harm might befali reluctantly on my person, i acceded to her order; 13' Fortunately, the coA diseovered the anomaly during the reguiar annual audit of the books of accounrs for the years 2008 and 2o0g. warning of CoA to me and Provincial Accountant ordonez The stern for-ced then Governor Aurora cerilles to stop the iilegal practice which I could not have otherwise prevented. trn its audit for the y.rru 2009 (Audit I Finding No. i) and 2008 (Audit Finding lrtro. 1), the CoA dis.covered that checks in the total amount of P 57,12O,197'24 and P 16,053,L34.4a, respectively, were issued in the said d years. The COA Audit Reports state as follows: 2O09 Auciit Report L. Check paymoute in the total amount of F5?,LA0,1S?"?4 crere not supported. with dutry approved Diebuu,sernemt vouchers, contrary to sound internar contror p*licies, ca*si,ug doubt on the varldity and regatity of the transaations, accureelr of the escount balances, ieategri*y ef the accounting and eash records, reakiag the reopeative asset and expenae &ceounts overstated. 2O08 Audit Report 1. claims without dury approved vouchers totaring P16,CI53rt 34.40 were taken up 6,a prepaid e*Ile*&es, contraqr to existiag rules and reguxatlons, reeuliing to qrverstatement of, aseets and uuderstatemest {3fl corresponding aeset or expellse accoqlrtte. The above audit findings were one of the reasons for the issuance o{ an ADVERStr oPINIoIri of the coA on th.: {inancial statements of provincial. the Governrnent for the years 2O0g and 2OOg; Page 3 of lt ,&ffidavit of Pedro D. Rarnirez,Ir.
  • 4. 14' The checks issued in 2oag, without the covering disbursemenr vouchers and supporting documents, urere mostly payable to favored suppiiers, Lucky saver Geni'ral Merchandise and Botica JiIl both ownec by LizaAranding u'ho is a relative of Governor Aurora cerilles. The said L;;;;;"ding is also a big financier of the ceriiles couple during eiections. A copy of checks Issued without supporting Dotuments, consisting the coA List of attached as Annex "r{" to Annex "K*s" and made of six pages is an integral part hereof; Illegal Disbwrsement of Trust Rtnd.s 15' with the absoiute control of the cerilles coupie over the firiances the Provinciai Government, the provincial funds are being of spent illegaily, wastefully; whimsically and uncontroliably. It was not surprising that tirrre anc again the General Fund became depleted. when this happened, the cerilies coupie (then Governor Aurora cerilles during her three terms and incumbent Governor Antonio Ceriiles) ordered me to transfer the funds from the Trust F''und to the General Fund' when I objected and explained to them that Trust Funds could only be spent for the specific purpose for 1 which it was createc cr received, they further pressured me until I reluctantly acceded,; I 16' Expectediy, the CoA d.i.scovered the aforementionec illega-l t$ tr disbursements in its annual audit in the years 2011 (Audit ti iI 2o1o (Audit Finding No. 1 on cash Managementj,2oog (Audit Finding No. g), Fincing Nos. 2 & V 3), and 2aa4 (Audit Finding No. 4). Thus, the coA Audit Reports state as follows: 2011 Audit.Rer:ort (During the telrn of Governor Antonio ceriiles) 8. tra&sfer of funds from Trust F.uad to General Fund, speef,e,l Educatlon E und {sEs.}, and Ecouomic Developmeat $.und, (EBF'!, vis-r&-vis in the total amouqt of F 43r2ooro6s.ss wrere nnade without authority es provided, uqder seqtiorne gos e,,d &s5 of r€epublic Act {R.A.} ?L6o and $ection s4{2} {b} ef P.p. L445 thus, the purpose for rs,hie& it was created c&&Erst be pursued. 2010 Audit Report (During the terms of the cerilles couple) tr. cash resemred. for trust ftrnds has a uegative belart,ce of p 262,,?.79,715.s4 in vioration of seetioro 4{3} of president{atr Deeree 1.445, cauoing doubts oa the propriegr and vnlidity of the transactions alrd the integrity ef the accountirug amd ce,eh reeords. Page 4 of lL Affidavit of Fedro D. Ramirer, Jr.
  • 5. 2' cash pertarniug to truet filnds has a total amount of p zgraodrgls.a* aegative baxance in tfue *fro*iog governmerat fuuds to possible loss andler roisuse, causiag doubts ore the propriety and vatridity of the transactions and the rntegrity ofthe accounting and cash records. 3. In'tenfu;rd transfers have urEreeorded transactions 7,272,&94.CIO and unreplenished balauce of &" 17'471,833.84 as at year-eud, causing of p propriety and validity of the trausactior.s doubts on th.e and the imtegraty of the accounting and cash records. 4. Trausfer of funds betweeu differemt projects Fuud amd between ?rust F.uad to General within Trusf s-uud amou&tcd te P I''281,76s.62 (Aanex '.8,! in violatiqn of, $ection s4(t! of FD So. !.jt45. Intelligence Fwnd 77 ' The Intelligence Fund. is often being used other than the purpose foi. which it was created' Heavy withdr awals of this fund were rnacie during elections' In April 2010, prior to the IMay 2o1o elections, then Governor Aurora. cerilies withdrew the total amount of P3o.0M in one week, with instructi.on that the money be in denominations of P100 and p500, - - ' the withdrawais v,zere <-v "r'e made as foilows: a+ Arnount Aprii 1"9,201O P 1O,OOO,OOO.OO April 23, ZOLO 5,000,000.00 April 26,2O1O 15.000.000.00 Total P 30,000.000.aa Attached, as Annex uL" to oN,, are copies of the acknowledgernent receipts signed by Elma Sebuco who counted the money Governor Aurora Ceriiles; in the presence of then 18. The audited financial statements of the province for 2010, 2OAg and 200g would show that tl:e Confidential the years ZAt1, expenses were used in the 2010 elections. The and Intelligence totai expenses for the sairi years are as follows: page ti of X.X. Affidavit of pede,o D. Rarnirez,.!r,
  • 6. Total Expenses Year 2A11 (a year after the etrections) P 5,105,939.g3 2010 (election year) P 47,642,199.00 2009 (a year before elections) P 22,6A5,513.00 20OB itwo years before elections) P 5,551,440.OO 19' The above figures ctrearly inclicate that the ceiiles couple used the confrdential ai:c Intelligence fund.s for political pllrposes' trn 2008 or two before the elections,campaign and eieciion total [onficentiai and Inteliigence expenses r,/as relatively low at p 5,551,44o.oo only. trt increased i:y a-bout 450% or iri the amount of p 22,6as,s13.00 in 2009, w,hich ie a 3.ea.i- before the etrections when the cerilles couple started to prepare and strengthen their politicai organization. In the eiection year 2010, the expenses more than doubled when the total' confidential and .tntelligence expenses ::eaci-red. P47,642,1q9.CIo, and. trso,OoG,Ooo of the saic amount was withdrarvn in a week's time (Apnl 79-26,2010). Ttie expense$ substantially tapered cff afier l the elections, the totai arnounted onry r,, p 6,10s,g3g.g3 I in 2011; _.1 l Canstru ction Maieria'Ls, Afrfice Swpplies, rf adffi Gracet'ies Far The Friuate EstabtishrrLerrts ti/&i i{ 'ru And Residence; t*;e of Gouemrment Heaug Equipment Without Rental, etc. Il l 2a' For three consecutive terms of then Governor Auroi-a cer-iiles, various construction materials, of{ice supplies, grocery items, etc" -i,vere withdrawn from favored suppliers and deliverecl to the private establishrients owned by the Cerilles couple, inciuding their residence in Fagadian ciqy. Tirese materiais were covered by delivery or trust receipts and duly acknowlecged iry the workers in the said estabtrishments" These establisi:ments followiag: are tl.ie a) Fiotel Alindahaw, pagadian City b) Aiindahaw L,akeview Resort, Lakeview, zamboanga del s*r ^ v) Pensionne Yilana, Fagadian Cily d) Boss Coffee, Pagadian City e) ivfcDonald's, Pagadian City 0 Building Resources, pagad"ian City oI bt Jetti Gas Station, pagadian ")ity h) I-and Transportation Office, :ragadian Cifv i) cerilles (sKT) Labangan warehoue, Labangan, zanaboanga dei sur i) Bb-gan;an Broaccasting cortr,oration Eruilding, pagadian ci{y ki She11 Gasol"ine Station, pagadian City 1) Vetera^rs Bank Btlilding, pagaciian Ciqy m) Philippine Para-&{edicai arid Techni.cal school, Enericl co:iipaui:.c, Pagadian City Page 6 of 3.i &ffidawit cf Fedro #. ffiai.nireu,.!n.
  • 7. 21' Then Governor Aurora ceilles assigned Ruel G. Moli*a anc tlrr,rne singgo, who were her chiefs of staff, to overse" trr* withdrawal and their delivery to the private estahlishments of the mareria-ts of the cerilles coupie. The couple also assigned Provincial Er.ldget officer, Roger Monteaito, to oversee tire preparation of the necessary d.ocurnents for the payment of the delivered materials' And I was instfi-lcted to issue the check for the r:ayr.nent ol ti:* covering ciisbu rseirrent vouchei-" 22' The "sl:pporting cocurnents", such as purchase request, absir-a.*1; ci canvass' BAC re;olution, purchase order, inspection and acceptance i.epcrr, etc', of the disbursement vouchers were all FALSIFitrD. These were prepare* by the suppiier upon the direction of Roger Montealto. i{e is kno,wn as the "Idagician" for being able to com.e up with the source of funds, the pro;es:i io whicir these rnaterials were charged, anc devise a .,ghost construction rnateriais, off?ce materials and" equipment. ceiiveryl cf The construction materials welre often charged *.o the Amusement and Events centei. {AEC), located inside the Provincial capitoi cornplex, whi.ch has been an o^t*g;ing project for a long period of tirne; 23' As soon as the "suppoi:ting papers" were completed, I disbursernent rrouchers were theri prepaied and the cciv*ring the corresporlrling checks / issued' These checks were prioritized for payment- as emphaticaily ordered 1:-v the Ceilles cou.ple; m$ . r. ll II 24' Thus, i hereby support and ,;onfirm the allegations of iland xlrrone D' singgo in their Joint complaint-Affr<lavit Ruel G. Mc.lina whichr they signeri on U Jarruary 11, 2Q12 iir the City of Man..la that various constructiori materrais, office supplies and equipment and ev:n bags of rice anc grocery iren:s vere u'ithcrawn frorrr r-he Golden Daughter Enterprises on different accasions *nd delivered to the private establishrnents and residence of the ceriiles ccui:ie. i have personal knowledge of these deliveries for the reason that i signei rhe disbursernent vor-1.c1-lers and the checks covering these delivered materials; Fauored &sppliers an"d" Contractors 25' As repeatedtry instructed to rne by t.he Cerilles cor:ple, the favoreu suppiiers and contractors of the coupl.e were paid first. As soon as the Internal Revenue Allotment {IRA} was received, the cerilies couple gave rne lists or iictes indicating the suppiiers and contractors to be paid and the respective ar-ncunts. The foiiowing are the favored suppliers and conti-actors of the Cerilies rvhich have been granted most of the supply and consiruction projects an4 p::;*rit;;re* for payment: a) Lr.rciqy Saver General Mercharrdise b] Golden Daughter Enterprises c) A..J. Enterr:rises Page / of 13. &ffidawit of Fed:"o D. Rannlrez, Jn.
  • 8. d) E.L.B" Enterpises e) Alajeno Construction f) ZMS Construction Attached, as Anrrex oo" to Annex *L)o, are copies of some of the directives af ihe ceriiles couple t{, -r.e, and mace an intr.gral part hereof; 26' wher: I issued checks without the afore-said prior directive, then Governor Aurora ceriltres asked me to exptrain and show my basis for issuing the checks, especially wLren these were i.ssued to orcinary suppliers. ALtache.l, as Annex "V', is a copy of a witten order for rne to expiain which is maie an integral part hereof; unrernitted Brfi withhotding Toxes & Gsfs contribwtians 27 ' The Eross rnismanagement of the fund.s resultec in the r.,on- payment of rnanCatory obligations, non-rerni.ttance of v/ithholcing io tiie BIR and Pl"erniurns and. Salary. Loan antortizations to the Taxes ,*rhichl GSIS, consequently disqualified the provinciatr employees front avaiiing of t1:e 1:e*ef;ts fnorn the GSIS; 28' The comrlrission on Audit {CcA} has discovered r-ire faiiure Provincial Governrnent to rernit to ttre aforementioned agencies cf the l regular annuatr audit. Thus, curi::g its lt one of, the IinAlings in the COA Audit Reparr in tj^re II years 2010" 2009 and 2008, include tire non-remittance of Withhoiding Taxes to the BIR; rl 2O 1O Audif Egpprt (During the terrns of the Ceriiles couple) LS. E.Im.rexm,i*ted wi&hheld taxes +fl #SSrI"69r?B#.#6 iasesee.sed fuy $#.v*V@/a f'nom prexriowe yee!. of #S$r4Ar[rf*f.fe f.xe s'iola'&$.sm &o *xistf.mg BXR ruXes e,md regulati,ome" 2oo9 Audit Report (During the term of Governor Aurora cerilles) s' E{uge aro.oex$.t of w"i&&.&etrd gexee &ota!}*ug wfl sss,4&q$?Bf.$* remaixaed r.anrepe,r,Eted &s at year-errd, iru wiarletiom t*r exi.stimg B$$Q. rqelee amd regaalatiCIrls e&$eslmiug gewerruxmenr.& fil*nds t<r posei&Ee Loss am,d/CIr mis&se. 2Qo8 4udit Report {During the term of Go,,,ernor Aurora cerilies} 4. wi,tfu3aeEd. taxce {m t&e tcta} mxsaou.mt o$" p xd,4#sos#?.x$$ rexms.$med, ae at Srear-emd, im viwlatiern to exi.s&terg rarles, am* regtalat{c,ses isn. the wi,*hfu*}d.i,xrg ms}d remittaru*e e,f .f,m-rses amm, exposing So.lsegffime*t {tsmds *o poesibSe loss *md,1tlr lminrase, Fage i of 13. AffidavEt of Fedro D" Rarmirez, Jr.
  • 9. ' Ti:e year-end balances of Due to 29 Provincial Gcvernrnent faiied Gstrs clearly shorv that empl0yees' to ren:it to the G*IS the premiums the Ioan amortizations. per ccA and 2AA7 ta 2a11, the amounts Audit Report for the past fiv* ye*rs, Due to GSILT, are as foil0ws: Year Arnount 201 1 P 74,29a,991.?g 20 i0 tr 74,261,006.55 2009 P 90, 199,355.41 2008 P 75,946,966.53 2AA7 tr 78,53 7,919.43 Attached, as Annex ,.Ifr/, to Annex ..yr, are copies of a fe-w ."0 Dernancl Letters sent hv the GSIS of tl:e l.{ot_ice cl 3:nH:, to then Governoi. Au-rr:r:r 30' As orderec b'y then Governor GSIS' were not prioritized" Aurora cerilles, payments to Even though I have the chect<s But ai:.,:r prepared' these I/ere not i'eieased per t" these agencies her order, her.ce, they became coA Audit Report lbr the years sta,e. ,rhe 2a06 anc 200g include a s{-aie c}iecks' A copy finding cf unreleasecl of a- list of stale checks mcstly to the BIR for the pcr:ir:ci attached, as Anne N"z,,and ,{nnex *z-t,,and ffi[i;#ffi]_:;l*'" rcarle an 3 i ' I am executing this Affidavit ior the purpose of {rling the crirninaL and adininistrative appr:r:p; iate cases against Govemor Antonio former Gorerrlor {urora tr' cerilles L{. ceriiles afld. zamboanga del {now Representative, Znd Disti-ict oi l*"1)' and all persons who in one way or another might have ':onspired' confabulated and corrfecerated in the commission :rimes and offenses; in support of ti:e foregcing of our application in the witness securiqr and Beneflt Prograil; Fi-otecticn, to confirrn the allegation" .r nu"r in their J.int complaint-Afndavit which G. L4oLina and *n-Jr rlti'f*t '--*--J *'' oJ12 in the city of they signed on Maniia; anc for aii other lega-l purposes. intenrs ar:d IN wlTllEss WHEREOF, I have }:ereunto set my hand on ihis rrlr: -,r.:i, . . fiano or} **+ r/ -- ii.r,]'il,r January,2013 atthe cityof hilanila, Fhilippin""]"1rry > z_@=..-=- <---- rpg>je$ 1)" ffinmruufl, J;r*. Affiant-Compiainant Page $ ,:rf 3.1 Affldav[t of Fedra S" Ramire;,.fr.
  • 10. ),--"',' -JAhJ g 2tri3 i SUTSCRIEED AND SWORN to before me 2073 at the c1Y:lnn""rl-,"ir.lrippi*"*. orn.r, ,on this _ day of january, exhibited to me his i:Tffi",i'i, iffi '"';l t :[ # xil p e'lu-Ti::: 1L",, * c ,lri.,,,er,s -; 3o ; " n{i "; ATIY rr[i noc. rrto. dJl Page No. b,)^ N0TARi,r,r. r nir;,r,,,.,-l,l ll, - r.L -','.i I lrJ,it..,J1I '- ' 1't:: 3Jz20tji r.. i.]-r,r q :l )-r li t't' ll;2.a5g ''-ti2'QF Eook No. rV ! ri :i.r Series of 2O13 rr-rR Nr-l, .t -ui, r*],1o; ; Il.l l,:,,:,: rap r,,:, . ,4 LA^ ::.?. r ,, ':i j=,-,;ir, ".i,11'i;o'r, ,:l/'l',' 2,rrr MLA. ivxCLE clrtu4Lrl,,l,',-J'.',1 'i ')r;3 - Za3 j c oA,rFr- i.rr.lCr hio" I V _'OffiffilC, Republic of the trhiiippin es) r.litf of Manila ..) SS VES*.I$.IC.&TEAi{ / AffiM fl MS*T$F-,CILT'TO N 6 F' TW$ I N. FO R,{JMffi SF{@ FPXXH ffi *,j# I, ptrDF(O D" RAMIRtrZ, JR., of legal lr Poblacion, Kumalafang, i-rn . ^Bjt Filipino and resident of b'o^nga del Sur, and Pagadial after having been duly swo.., t" City, in accordance with iaw, do hereby respecii,-.r_. sa]': O"po*" ..,.c U *4, ,h" r";X*lJ 3x',,.'$:,:tfiffitrpr*i"'lt and I have canrsed the prepar:alion or TI-{AT I have personal and allegations contained knowtredge and tirat ail the information, sta.l.enients herein are irue ancl correct to personal knowlerige; the best cf rnri h ?HAT I herel:y certify that i 'prcceecing invoiving the irr* not commencec any othe;^ aciion or. issues i* 1i-r"'supreme c"rl.t, "*rr.there"t ; -r, Appeals, or different Divisions the court cf rind that to the best of *y p"rronal_know1ed.ge, ";;;;;;d;r*runal oi- aseiicy pending in the supreme br,rrt, no such action c l-hereof, or any othei tribunaf the court'-ol appeals or d;;I;:"xi.iTI;I *u* or agency; and TFIAT should I iearn that simiiar is pending b'efore the supremeacourt, a-ction or proceecing has been filec, c;. the corr.t of Appeals or the clifferent Affidavrr J;-;-H"J.'*u*,n*,,,,
  • 11. j"-x-;'"'-'*""- ... divisions thereof'.-or any court within five (5) days other tribunal, court or agency, tr srrarl so norii.. frorn such knowledge. _ __.^*, t1:,; ,*,,,*l}, Hf::,f'fiY:,k*il:ffi;T::,1", *, hand on thi s i 7.,. n6;, .',f L'1 ,,:----sEryk0 B. $*eesrsqm:4* J$r" Afiiant-Complair:t ?E.., ^arn ftY,-^*-- SUBSCRIBED AND SWORN *i,[N t $ 2il13 to before me 2013rat the cir{:lrvranila, License No' itiiippirr-".-irnrit.on this _ to day of Ja.r-ru;rry, -i""u"a exhibited rne his 'Io4-95-oqglaz February Zl,2Ol2 and,t" by the i,and-Transportaticn Di:i,,,er,s ."pi._ on February 13, 2015. office oil ( _ ) ->- Doc. No. s {f ATTY L Page No. fuf Nfi"['ntii' i]UEi-lC* l.rt'1L IrEC. 3t,?(r1t ,Book No. X f NOTAitlAl". tS1trl!1:;!10 2,]iA.tl5s r). Rlr*L ,.lir. 7ll(r:S Series of 2O13 FTl+ Nil, Of g3it"52 r /i t12 NlLA.' tUp Nf:r. 86/.1^1 ?f,i It/2'::.iZ'illi ML,,A. i Ffltt l]Jltr 1',:,,Itl5 ']"nW- Zi]13] h,l CL H ( 0ri,,lEri- i,rLi{(. E i,l0_ t V " n0 0 g l65ft page i3. of lt Affidarrit *f Fedrc D. Rannirez,,!r.