Rogelio Montealto (part 4) Graft and Corruption


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Provincial Budget Officer of Zamboanga del Sur

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Rogelio Montealto (part 4) Graft and Corruption

  1. 1. Republic of the Philippines @tttre of tlle @rnhu[gnrrr$ Agham Road, Diliman, Quezon City, philippinesROGELIC P. MONTEALTO, Criminal Case No.Provincial Budget Officer,Province of Zamboanga del Sur, IC-OC- 13-O 174 Complainant, lc-oL-t1 - oll F -versus-ANTONIO H. CERILLES,Former DtrNR Secretary & For:Incumbent Governor ofZamboanga del Sur,andAURORA E. CERILLES, Violation of Anti-Plunder Act.Former Governor of Zamboanga Violation of Graft & Corruptdel Sur & Incumbent Member oi Practices Act,the House of Representatives, Malversation of Public Funds & Properties, andRespondents. Violations of Other Penal LawsX-- ---X" AFFIDAVIT.COMPLAINT I, ROGELIO D. MONTEALTO, Filipino, of 1egal oge,married and a permanent resident of pagadian city,Province of zarnboanga del sur but, presently, staying inMetro Manila for security reason, after having been dulysworn to in accordance with law, do hereby depose andsay THAT: Prefatory Statements Previously, I executed an Affidavit, couched. igeneral terms, concerning the anomalies, irregularitieillegaiities and criminalities committed bv Antonio Icerilles and Aurora E. cerilies. It r,vas subscribed befoNotary Public, Atty. Juanit,, L" Garcia, of Maniia Ci Page 1 of L6 Affidavit-Complaint Rogelio D. Montealto
  2. 2. entered as Docket No. 427, page No. 86, Book No. XI,Series of 2013; and dated January 24, 2013. My said 24January2ar3 Affidavit was annexed tothe Joint complaint-Affidavit of Ruel G. Molina andTyrone D. singgo in filing criminal cases against AntonjoH. cerilles and Aurora tr. cerilles. The said Jointcomplaint-Affidavit of Ruel G. Molina and ryrone D.Singgo had already been filed with the office of theombudsman and, in the meantime, had been docketed asIC-OC- 13-O L74. I am, primarily, e:,:ecutinig. this SupplementairAffidavit-complaint to suppiemeni tt is ombuhiman rc- oc- 13-o *74. I this Supplemental a.rn, secondarily, executingAjfidavit-complaint to supplement all complaints,Affidavits and other sworn statements concerning theanomalies, irregularities, illegalities and criminalitiescommitted by Antonio H. cerilles and Aurora E. cerillesin the Province of zamboanga del Sur and elsewhere thatthis supplemental Affidavit-complaint finds pertinent,material and relevance. Jurisdictional MattersThe COMPLAINANT 1. That COMPLAINANT is of legal &ge , married, Filipino and a resident of Block 12, Lot 14, Sunrise Village Subdivision, Tiguma, Pagadian City where judicial notices, summons anr,l similar orders appertaining this complaint may be addressed and served; 2. Thai COMPLAINANT is the incumbent provincial Budget Officer of the Province of Zarnboanga de Sur having been appointed on January 2, 2OO (appointment attached and marked as Annex K discharging functions, duties and responsibiliti prescribed in R.A. 7160, otherwise known as t Local Government Code of 1991; 3. That prior to h.erein c0IvIPLAII{AITs appointment as Provincial Budget officer, he was first designatecl Page 2 of L6 Affidavit-Complaint Rogelio D. Montealto
  3. 3. as Olc-Provincial Adniinistrator on July 2, 2AOI to December 31, 2001;4. That as OIC--Provincial Administrator, COMPLAINANT received direct orders not oniy from the ACCUSED then Gc,vernor Aurora tr. cerilies but also, most of the time, from her husband ACCUSBD Antbnio H. cerilles who was then considered unemployed after losing his bid in the May 2001 elections for the position of Member, House of Representatives representing the 2.a congressional District of Zamboanga de1 Sur;5. That COMPLAINANT, as the then olC-provincial Administrator, attests to the fact that almost all signilicant decisions in running the affairs of the Provincial Government were those laid down by ACCUSED Antonio H. Cerilles, including but not limited to the biggest and most significant decisions ever made by the Cerilles Administration, the reorganization of the organizational structure of the Provincial Government" of zarnboanga del sur that led to the retrenchmer;t of more than two thousand (2 ,000) regular arrri non-regular ernployees, depriving them of their means of livelihood. Anc in connection with this reorganwatron d.ecision, it is a fact that ACCUSED Antonio H. cerilles, even dictated the herein COMPLAINANT (when presenting the reorgantzational scheme before the Sangguniang Panlalatuigan) the number of employees to be retained when he asked: *Hla ka empleyado imong gipabilin? (How many employees did you retain?). COMPLAINIANT responded: "I,O2O Boss." And he shouted: Daghon pa na! (That,s still too many!). And so COMPLAINANT asked: *Hla marl diag gusto nimo ipabilin, Boss?,, (How man therefore you want to be retained, Boss?). tae replied: 520! At the back of his mi {a, COMPLAINANT was figuring out from where nd what Department further personnel reduction be taken. Difficult as it was, after restudy 1C br COMPLAINANT was forced to bring down the figd to 721 which Antonio I-t. Cerilles finally accepted"; Page 3 of 16 Affidavit-Complaint Rogelio D. Montealto
  4. 4. As ACCUSED Antonio H. Cerilles continuously dictated and dominated the affairs of the Provincial Government giving direct orders to COMPLAIIANT, there were even several instances when ACCUSED Aurora B. Cerilles, for reason she felt she was no longer prlvy to decisions and implemented without her knowledge, she even prompted the COMPLAINANT by saying: "Esforyahe pod ko unsay ingong gisabutan ni Boss ug iyang gusto ipaimplementar!" (Tell me also what the Boss discussed with you and what he wants to be implemented!); Herein COMPLAiNANT purpbsely presented above antecedent facts and instances to ESTABLISH THE F.ACT that indeed r,rhile ACCUSED Aurora E. Cerilles was the de jure Governor, being the duly elecred incumbent to the position, it was and from then on up to the end of her third term, her husband, ACCUSBD Antonio H. Cerilles was, in truth and in fact, the de facto Governor, the one who was actually running the affairs of the Provincial Government. Henceforth, all acts, all on records, committed by ACCLISED then Governor, now House Representative Aurora E. Cerilles, in violations to existing laws, rules and regulations governing the use of funds andlor properties of the Provincial Government of Zarnboanga de1 Sur were all done with the complete knowledge and upon order of ACCUSED Antonio H. Cerilles to conjugally enrich themselves and in furtherance thereto, perpetuated by him being now the incumbent Governor as hereinafter enumerated;The ACCUSED 6. That the ACCUSED Spouses Antonio H. Cerilles and Aurora E. Cerilles are all of legal oge, Filipinos and residents of MS Canuto Enerio Street, Capito Site, Sto. Nino District, Pagadian City whe judicial notices, summons and similar orde appertaining this complaint may be addressed a served; 7. Tkrut the ACCUSED Antonio I{. Cerilles and Aurora tr. Cerilles are, respectively, the incumbent Page 4 of 16 Affidavit-Complaint Rogelio D. Montealto
  5. 5. Governor of the Province of Zarnboanga del Sur and the Representative oi the Second Congressionai District of Zarnboanga del Sur having been both elected in the May 10, 2OIO Local and National Elections; THE CHARGES COMPLAINANT hereby accuses the ACCUSED for:A. The crime of PLUNDER, MALVERSATION OF PUBLIC F.UNDS AND PROPERTIES AND FALSIFICATION Of. PTIB.LIC DOCUMENTS committed by raiding the finanies of the Provincial Government of Zarnboanga de1 Sur for their own self-aggrartdwement-amassing assets (specifically including huge sum of cash), properties and business enterprises directly and indirectly through misappropriations, conversions, misuse or malversation of public funds using dummies, agents, subordinates, business associates and combinations thereof a s evidenced by the following:i. The issuance of checks in the amount of Ps54rL78r123.13 not covered or supported by duly required supporting documents as indicated in the COA Annual Audit Reports, a srtmmary portions of which are hereto attached and marked as Annex "8" which form an integral part of this complaint. That the above amount of Ps54, L78r123.13 represents only a small portion of the more than Ps35O Million amount of checks issued without vouchers and other supporting documents which were only subsequently tampered and/ or manipulated by the ACCUSED (utilizing subordinates) to make it appear in order and in accordance with the duly accepted accounting and auditing rules and regulations. By ordering th Provincial Auditors Valeriano B. Patangan, Jr Madeline J. Majestrado and Jeannette Calamohoy through the issuance of an appropri Subpoena duces tecu.m ad Testificanduwl for i submission before the most Honorable Office of th Ombudsman, these documents can easily be idertified and testified to by herein COMPLAINANT; Page 5 of 16 Affidavit-Complaint Rogelio D. Montealto
  6. 6. In the said Annexes, the Honorable Ombudsmans attention is hereby most respectfully invited to the fact that the payees indicated therein as: Lucky savers General Merchandise, Botica Jill and Jehn Cris Enterprises, are owned by one, and only one proprietor, Lisa Aranding, who is one of the ACCUSBn,* business associates responsible in ghost deliveries and conversion of items supposed t" be d elivered to ttre provincial government but instead, to the ACCUStrDs privately owned businesses; ,. At this juncture, COIEPLAINANT hereby IMPLEADS all suppliers indicated in the documents aforementioned;2. The delivery of aforementioned hardware materials (per attached copies of some Trust Receipts covering these deliveries and supported by Affidavit of Nelson Escario, marked Annex "C" for the construction of various buildings, business establishments and other infrastructure facilities privately owned by the AccusED as shown in the ittached lists of properties supported by corresponding pictures marked as Annexes "D-1" to *D-12", artd. summartzed as in the following table: Table 1. Partial Lists of Establishments Private-owned by the ACCUSED as shown in the Attached Pictures Marked as Annexes "D-lto "D-13" Exhibit Numbers Establishments DecriPtions Hotel Alindahaw, located at the heart and business hub of Pagadian City, specifically Rizal Avenue, Pagadian City. Purchased as acquir asset from a local bank, the hotel was imp and fully renovated out of provincial governm funds surreptitiously done through gh deliveries and conversions. The Hotel capt almost all functions (conferences, meet symposia, forums and similar events) host ZDS provincial government, including the bil of officialguests and dignitaries. The hote houses ACCUSED-owned ANCER Enterprises dealing in the sale of CEBU Pa..ifig ti49!!-ell4 Page 6 of 16 Affidavit-Complaint Rogelio D. Montealto
  7. 7. also manned by provincial governmentemployees. The Hotel also houses the AK Bingowhich is likewise privately-owned and operatedby the ACCUSED. The hotels power supply isbacked up by a huge stand-by electric powerGenerating Set owned by the ZDS provincialAlindahaw Lakeview Resort, an expensivelyconstructed multi-million world-class vacationhotel & restaurant resort nestled in idyllic LakeWood, featuring childrens waterworld swimmingpools & multi-million pesos worth QuadrupleZipLines, located at Biswangan, Lakewood;Zamboanga del Sur. As in the Alindahaw Hotel,the resort constrqction is funded out clf ZDSprovincial governmentS fu nd.Pensionne Yllana. Also located at the heart ofPagadian City, it is PRIVATELY-OWNED by theACCUSED and also funded out of ZDSgovernment funds. Recently, it likewise housesPagadian Branch of Monterey Meatshopfranchised bv the ACCUSED.Boss Cof$ee. Named after how the ACCUSEDwants tc be addressed, the outfit is also fundedout of government funds. McDonal.l Branch. Franchised by the ACCUSED During lts inauguration, the mascot was in fact played b/ one of the provincial governments Building Resources. The building is owned by the ACCUSED and rented by Building Resources hardware dealer Jetti Gas Station. Owned by the ACCUSED and constructed out of provincial government funds The gas service station corners all fuel supply contracts of the Office of the Provincia I LTO Office. Owned by the ACCUSED, the building was constructed out of provincial Sovernment funds. Occupied by LTO under lease contract agreement, it is a one stop shop catering clients needs on such allied services as drug tests, insurance, test driving, restaurant, etc. Clinics for drug tests are owned by the ACCUSEDs brother and sister. Cassava Warehouse. Located in Dalapa Labangait, Zamboanga del Sur, the 3-hec facility i,ouses cassava produced by low-in farmers under sale contract with the San Mi Corpora:.ion. PrivatelY owned bY the ACC its opei"ation is financed out of govern Page 7 of 16 Affidavit-Complaint Rogelio D. Montealto
  8. 8. Baganian Broadcasting Corporation" Aithough corporate papers indicate that this outfit is owned by the ACCUSEDs crony City Councilor Roque Yamba, its real owner by the ACCUSED is a public knowledge. The station is featured in a case noil pending before the Sandiganbayan involving transactions with the provincia I overnment in violation of RA 184. Shell G.isoline Station. Owned by the ACCUSED and operates under a dummys name (a family friend rn Cagayan de Oro City). Besides the station is the ACCUSED-owned Tanton Meatshop, a marketing outlet for pork produced from his own ,rnulti-million Piggery Farm in Dumalinao, Zamboanga del Sur. ln the second floor of the Meatshop is the office of the ACCUSEDs daughter-in-law, Junaflor S. Cerilles (wife of ACCUSEDs son Mayor Ace Cerilles), Executive Assistant lV (SG 261 of the Provincial Government of ZDS, not reporting in the provincial Capitol but takes charge of the ACCUSEDs family business of infrastructure construction projects and supplies of construction materials and office supplies for the provincial government of Zamboanga del Sur using dummies. A provincial government employee, Marife Ambuhot, takes charge in the supplies deliveries and collection of payments thereof. Veterans Bank. The building is owned by the ACCUSED using government fund. lt houses Veterans Bank of the Philippines Pagadian Branch. Enerio Compound occupied by the ACCUSED- owned Pagadian Paramedic &Technical Schoot (PffS). its operation is financed by the provincial governi-nent and captured funds from TESDA to the disrnay of local private vocational schools. Fronting PTTS (still inside the compound) is ACCUSED-owned lnternet caf6, fully furnished out of Bovernment funds. lt also houses PMC Merchandise, a supply outfit owned by the ACCUSED through a dummy, cornering suppl needs of the provincial capitol (see Annex "E".)The properties mentioned in the foregoing table orepresents a small portion of ACCUSEDs properwhich includes several hundreds of hec[aresfarms (a more than 400 hectares of ru Page 8 of 16 Affidavit-Complaint Rogelio D. Montealto
  9. 9. piantation and a rubber processing facility in Lakcwood, a hundred hectare mango and coconut farrri in Kalingayan, Dumalinao, ZdS, to name a fiern-); At this juncture, on the basjs on the number 11 item in the foregoing table, herein COMPLAINAIT hereby IMPLEADS Junaflor S. Cerilles and Marife Ambuhot, both employees of the Provincial Government of Zarnboanga del Sur, who are ACTIVELY engaged in the operation of private businesses owned by the ACCUStrD instead of reporting to their respective dgties in the provincial capitol;3. The assignment of Provincial Government employees as workers in their privately owned farms and other business est-ablishments as evidenced by the attached sarnple copies of Daily Accomplishment Reports, Daily Time Records and Payrolls. The evidence mentioned herein are only samples of sev-eral government employees utilized by the ACCUSED in their personally-owned businesses. For instance in the document marked Annex "F", government employee and I or worker Reynaldo Gumera, hired under Contract of Services, is assigned to tend the ACCUSEDs Mango Plantation Farm in Kalingay?fl, Dumalinao, Zarnboanga de1 Sur. On the other hand, Government worker Anastacio Maglasang Annex "G" is also assigned to work as feed mixer in the ACCUSBDs multi-miilion Swine Farm at Sumadat, Dumalinao, Zamboanga del Sur. Bvidence further show as indicated in documents marked Annex "H", another provincial government worker Rolando Arnoco was assigned to deliver surfacing materials for the ACCUSEDs multi-million world-class Prawn and Lobster Farm at Barangay Balong-balong, Pitogo, Zarrrboanga de1 Sur. At this juncture, COMPLAINANT also he IMPLEADS provincial government officials who resrronsible in the perpetration of these anomal Page 9 of 16 Affidavit-Complaint Rogelio D. Montealto
  10. 10. These include, MARLENE I-S" BEI|ISALES, Provincial Agriculturist and ALLAN CABATINGAN, respectively, for directly giving the order and for certifying the truthfulness of the montkrly accomplishments of workers Reynaldo Gumera and Anastacio Maglasang. Provincial Administrator ANTHOIiW FREDERICK S. PADAYHAG ishereby also IMPLEADED for certifying that charges to appropriation/ allotmen.i; are necessary and lawful and made under his direct supervision (see Obligations Request attached hereto and marked as Anng,x "F". l. On the other hand, COMPLAINANT further IMPLtrADS provincial government employee RUBtrIt CADORNA for certifying the truthfulness/ correctness of the Daity Time Record of ROLAIDO ARNOCO. Further, Ruben Cadorna, through issuance of Subpoenct ducesTecttm, should be required to present lists of provincial government heavy and light equipment utiHzed in ACCUSEDs privately owned businesses;4. The assignment of provincial government-pair1 security Guard.s (whose employer security agency is hired" under Contract of Security Services by the Provincial Government of Zamboanga del Sur) to the ACCUSEDs various irusiness establishments as evid,enced by the attached documents marked as Annexes "1" to "I-9". r In .cnnection thereto, the attention of the most hon,trable Office of the Ombudsman is again most respectfully invited to the summary of security guards assignments as marked Exhibits 1- 1 1 in Annex "I", as indicated in the following table: Table 2. Summary of Security Guards Assignment Posts Assignment Posts Name of Security Guards (ACCUSEDs Priv Assigned Owned Establish and/or Not SuP to be Covered P Page 10 of 16 Affidavit-Complaint Rogelio D. Montealto
  11. 11. 1 1". Requiron, Abuinto Pagadian Paramedical 2. Enerio, Julius & Technical School (PTTS), Pagadian City2 3. Empleo, Celestino Alindahaw Lakeview 4. Lastirnado, Noel Resort , (a world-class 5. Ungang, Arnel vacation hotel & resta ura nt resort nestled in idyllic Lake Wood, featuring childrens water world swimming pools & multi-million pesos worth Quadruple Zip Line) , Biswangan, Lakewood, Zamboanga del Sur3 1. Sudiang, Freddiel Governors Privately 2. Angel, Jonathan Owned Garrage of his Green Plate (private) Vehicles4 J,. Casupanan, Pampilo Dumalinao Feed Mill 2. Llena, Jonvee (Although owned by 3. Bandarlipe, Jessie ZDS Provincial 4. Sabihon, Jhon Government, the feeds produced are utilized by the ACCUSEDs privately owned Piggery Farm)5 1. Chang, Jonathan Mayor Ace William 2. Cagulada, Nelson Cerilles Residence 3. Suizo. Ronaldo (Guard Ronaldo Suizo is 4. Rambo, Rollie assigned as the Mayor 5. Sabejon, Jundie Ace childrens 6. Codilla, Raul surrogate, sending them to and fetching them from schools).6 1-. Lanaja, Sulpicio Private Residence of Vicente M. Cerilles, ACCUSEDs Father, Balongating, Guipos, Zamboanga del Sur7 L. lligan, Romeo Land Transportation 2" Tano, Office (LTO), Tiguma, Nacianseno Pagadian City. Building privately owned by thg ACCUSED & constructyd through provinfial qovernment funds. /8 1. Libre, Janeth ACCUSEDs priv{tely owned lnlernet afe located in front of PTS Page 11 of 16 Affidavit-Complaint Rogelio D. Montealto
  12. 12. 9 1. Hermoso, Escort of Dr. Zenaida E. George Galicianao, a private person, sister of the ACCUSED, long retired from government service. 10 1,. Lacson, Jhunal ACCUSEDs privately- 2. Cameon, owned Warehouse, Romeo Dalapang, Labangan, 3. Sabijon, Arthuro Zamboanga delSur 4" Megalleon, Javier At this instance, herein COMPLAINANT hereby IMPLEADS security agency ,. JKB P-EPUBLIC SBCURITY AGBNCY INC Branch Head NIDA R. ROSALES and further IMPLEADS Provincial Administrator ANTHONY FREDERICK S. PADAYHAG for again, certifying that charges to appropriation/ allotmerrt for the payment claim of the security guards employer, JKB RtrPUBLIC SELURITY AGENCY INC are lawful and under his direct supervision;5. The ILLEGAL USED OF TRUST FUNDS to finance ACCUSEDs privately-owned businesses. From CY2OO8 Cash Overdraft of Ps28r2o4r815.34, as of end of CY2 0 1 1 , this overdraft ballooned to staggering Ps275r888rOL4.OZ level, more than a quarter of Zamboanga del Surs Annual Budget (per COAs CY2O11 Annual Audit Report attached hereto and marked as Annex "J". Although ZDS CY2Ol2 Pinancial Statements has yet to be finalized, the overdraft is estimated to reach an all- time high of more than Ps300Mi11ion. Following is a historical summary of these overdrafts: December 3 1,2008 Ps 28,2O4,815.34 December 31,2009 219,562,486.83 December 31,2010 252,279 ,7 15.54 December 31,201 1 27 5,BB8,Ol4.O2 The. incurrence of this overdraft was brought a by the systematic juggling of funds, in MISAPPROPRIATION OF FUNDS. By blo annual appropriations beyond the pro government capability to generate/ collect Page 12 of 16 Affidavit-Complaint Rogelio D. Montealto
  13. 13. cash revenues, huge expenses were incurred for the ACCUSEDs privately* lwn€d businesses (as above described). As finu.ncial requirements of the ACCUSEDs private},y-owned businesses and projects cannot be paid from the General Fund in :riew of shortage balances from the Trusts Funds are used instead resulting to its continued depletion over the yeais without means in sight to have it replenished. AND THESE JUGGLING/ MISAPPROPRIATION OF. TRUST F.UNDS ARE MOST RAMPANTLY DONE DURING THE INCUMBENCY OF THE AGGUSED ANTONIO H. CERILLES AS GOVERIiIOR; Plagued with this cash shortage, the provincial government of Zarnboanga del Sur no longer was able to pay its mandatory obligations, which includes, but not limited to the non-remittance of the government and employees GSIS/PAGIBIG/PHILHEALTH premiums, suppiiers and employees withholding taxes to the BIR and employees loan repa,/ments to private creditor- banks per COA Aud; t Report for calendar years Lately, for the first time in Zarnboanga del Sur provincial governments history, representation and* transportation allowances (RATA) are disallowed by COA and are no longer paid to officials entitled thereto in view of this CASH OVERDRAFT as evidenced by a series of COAs disallowances, some copies of which are hereto attached and marked as Annexes nK" to "K-5";6. Another means of siphoning funds from the ZDS provincial governments coffers for the ACCUSEDs self-aggrandizement, to further enrich themselves, is the wanton availment of cash advances. Making use of employees as payees, cash advances are withdrawn in the guise of utilizing it for confidentia and intelligence expense and other purposes. funds were not actudly used as intended and accordance with guidelines, rules and regulatio governing its use, the poor employee who represents as payee finds it dif{icult to liquidate. Based on Page t3 of 16 Affidavit-Complaint Rogelio B. Montealto
  14. 14. latest statement provided by COA, a copy of which is hereto attached and marked as Annex "L", and "L-I" to "L-8", one employee-payees unliquidated cash advances now amounted to Ps73,426r752.O2" It may be noted that the reasons of its non- iiquidation are clearly manifested in COAs series of letters to the ACCUSED as attached hereto and marked as Annexes (L-1" to *L-8". PRAYER. In view of the gravity and seriousness of theforegoing facts presented, trerein COMPLAINANT herebymost respectfully PRAYS that the ACCUSED beimmediately: 1. Investigated and criminally charged with the crimes of PLUNDER, GRAFT AND CORRUPT PRACTICES ACTS, MALVERSATTON OF PUBLIC FUNDS AND PROPERTIES and FALSIFICATION OF PUBLIC DOCUMENTS; 2. Administratively charged for Grave Abuse of 3. Placed under PREIENTM SUSPENSION pursuant to Section 24 of R.A. 6770. IN WITNESS WHEREOF., the COMPLAINANThereunto set his hand on this 2}th day of January in theCity of Manila, Philippines. MONTEALTO plainant Page 14 of 16 Affidavit-Complaint Rogelio D. Montealto
  15. 15. suBSCRTBED-Np_SWoRN to nerofl,4ilJ&ffi&* day of January, 2611rf, S6J*JWB&,, rniippi"*",-an*", Rogelio P. Montealto exhibir-ing to me his Drivers License No. JO3-98-023512 issued by the Land Taransportation Office with expiration date on August 2, 2014. AITH Doc. x". ffi I.IflTNRi, Page No. 11 rd 0 T,rR rAr. "rpjry1:srlyliL iffiiffif Book No. Yl *r* *0.[1t#" ?,,?P.q ! u *, 9I?36? t ri n* MtA, ry{ Series ol_28l-3 , H;*:,.1* ry i i6,,frth, rtrSffi-mry.:i6,tfihfi ^4cL E,aeilm.*itr6- i# _*rfiggt; or, Republic of the Philippines) Cityof lttanila". "...) SSGl,t VERIFICATIONfr AND CERTIFICATION OF NON-FORUM SHOPPING I, ROGELIO D. MONTtrALTO, of legal &ge, Filipino and resident of Pagadian City, after having been duly sworn to in accordance with law, do hereby depose and say: . A THAT I am the Private Complainant and I have caused the preparation of the foregoing Complaint- Affidavit; Page 15 of 16 Affidavrt-Complaint Rogelio D" Montealto
  16. 16. THAT I have personal knowledge and that information, statements and allegations contained atr1 the are true and correct herein to the best of my personal knowledge; B THAT I hereby certify that I have not commenceclany other action or proceeding involving the same issuesln the supreme court, the cJurt or nplears,".. JJil*",Divisions thereo! or any other court, iiiuurral or agencyarr^d that to the best of my personal knowle,Cge, no"suchactiorr or proceeding rs plr,aing in the supremethe court of Appeals of diff<rr*rf oi.tisions thereof, court, or anyother tribunal, court or agency; and TH.,T should I learn that a similar actionproceeding has been filed or is pending before or thesupreme court, the court of Appears or the differentdivisions thereof, or any other tribunal, court or agency, Ishall notify the court within five (5) days rroir srich ,soKnowtedge. IN WITNESS WHEREOF, I have hereunto set myhand on this 28th day of January, 2013, at the City ofManila, Philippin ONTEALTO plaint SUBSCRIBED AND SWORN tO bcfOr" JAN S S ZI"{I fS13day of January, 20rc[f,fatsFytll$Hiephilippines, Affiant Xlir,1"gRogelio P. Montealto exhibiti"g i;No. JO3-98-023512 issued by the La ffi rrl" Driver,s License rtationOffice with expiration date on Augu 2,2014"Doc. No. {r/Page No. ---T-Book No.Series of 2O 13 t/ IiLr i r- ..i i i: : ,:;:j -rj pTi? NLl. OigSti--i? : i1: ;12 lvlLA- {Rp Nl:I.864.124 :,t i;: ;:;].: 1!_A" ( FrlR 111E 1,r::i{l5 :11".}iA Ziii; l MCLE c0rilPUAt{gE N0. lV O0s9lrr{) Page 16 of 16 Affidavit-Complaint Rogelio D. Montealto