PLUNDER CASE vs Aquino

Republic of the Philippines OFFICE OF THE OMBUDSMAN Agham Road, Quezon City KILUSANG MAGBUBUKID NG PILIPINAS, as represented by RAFAEL V. MARIANO, WILFREDO A. MARBELLA, and NESTOR A. VILLANUEVA, Complainants,

- versus -

FOR: Violation of Republic Act 7080 or the Anti-Plunder Law; Violation of Republic Act 9184 or the Government Procurement Reform Act; Violation of Republic Act 3019 or the Anti-Graft and Corrupt Practices Act; Violation of Republic Act 6713 or the Code of Conduct and Ethical Standards for Government Officials and Employees; Malversation of Public Funds; and Grave and Serious Misconduct

President BENIGNO SIMEON AQUINO, III; FLORENCIO ABAD, Secretary of the Department of Budget and Management; VIRGILIO DELOS REYES, Secretary, Department of Agrarian Reform (DAR); NARCISO B. NIETO, Undersecretary, DAR FMAO;JERRY PACTURAN, Undersecretary, DAR Support Services Office,MARIO L. RELAMPAGOS, Undersecretary,

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Department of Budget and Management; TERESITA O. REYES, ASHLEY BAUL, BENHUR LUY, SIMPLICIO GUMAFELEX, JOHN RAYMUND DE ASIS, JOHN B. LIM, NEMESIO PABLO, JR.,JANET LIM NAPOLES, AND JOHN AND JANE DOES, Respondents. x------------------------------x

COMPLAINT-AFFIDAVIT WITH URGENT MOTION TO ISSUE ORDER FOR PREVENTIVE SUSPENSION KILUSANG MAGBUBUKID NG PILIPINAS as represented herein by Rafael V. Mariano, Wilfredo A. Marbella, and Nestor A. Villanueva, unto the Honorable Office, most respectfully avers that: The Parties 1.

The complainant Kilusang Magbubukid ng Pilipinas (KMP) is a national organization of Filipino farmers, which was organized and existing under the laws of the country. It has various regional and provincial chapters all over the country. For purposes of this case, it is being represented by Rafael V. Mariano, its Chairperson , Wilfredo A. Marbella, its deputy secretary general; and Nestor A. Villanueva, the spokesperson of Katipunan ng mga Samahang Magbubukid sa Timog Katagalugan (Kasama-TK), KMP’s regional chapter in Southern Tagalog.

The complainant may be served with notices, orders, resolutions, and other processes of the Honorable Office at 217-B Alley 1, Road 7, Project 6, Quezon City .

2.

The respondent President BENIGNO SIMEON AQUINO III is being charged in this case as he approved the release of Malampaya Funds for projects or purposes not in accord with the law. His acts of approving the release of the funds to projects or purposes not related to those which the law, specifically Presidential Decree 910, so provides lead to the plunder of the funds by bogus non 2

government organizations (NGO) in conspiracy with the officials of the Department of Budget and Management (DBM) and the Department of Agrarian Reform (DAR).

Under the Constitution, this Office has the power to investigate or conduct an independent investigation even of a sitting President to determine his complicity on the offenses charged for purpose later on of filing an impeachment case against him. He can be served with subpoena, notices, orders, resolutions and other processes of the Honorable Office at Malacanang Palace, Manila.

3.

Secretary VIRGILIO DELOS REYES is the current Secretary of the Department of Agr arian Reform. It is under his watch that the pillage of public funds, in hundred millions of pesos, happened. He approved or caused the approval of several Memoranda of Agreement (MOA) for the implementation of projects submitted and proposed to his office by dubious NGOs. He can be served with subpoena, notices, orders, resolutions and other processes of the Honorable Office at DAR Central Office, Elliptical Road, Quezon City.

4.

Respondent NARCISO B. NIETO is an Undersecretary of the DAR Administration and Finance Department who signed the MOA with the Local Government Units (LGU) and the NGO for the implementation of projects by the proponent NGOs. He can be served with subpoena, notices, orders, resolutions and other processes of the Honorable Office at DAR Central Office, Elliptical Road, Quezon City.

5.

Respondent JERRY PACTURAN is an Undersecretary of the DAR Support Services Office who signed the MOA with the Local Government Units (LGU) and the NGO for the implementation of projects by the proponent NGOs. He can be served with subpoena, notices, orders, resolutions and other processes of the Honorable Office at DAR Central Office, Elliptical Road, Quezon City.

6.

Respondent FLORENCIO ABAD is the Secretary of the Department of Budget and Management while MARIO L. RELAMPAGOS is an Undersecretary of the Department of Budget and Management. They are being charged as principals by indispensable cooperation as they 3

are the ones who approved the release of the funds to the DAR for projects not related to energy-development which projects were proposed by, and to be implemented by the NGOs. They can be served with subpoena, notices, orders, resolutions and other processes of the Honorable Office at Department of Budget and Management, Manila.

6.

Respondents TERESITA O. REYES, ASHLEY BAUL, BENHUR LUY, SIMPLICIO GUMAFELEX, JOHN RAYMUND DE ASIS, JOHN B. LIM, are private individuals who connived and conspired with the above mentioned government officials in the commission of the offenses hereto charged. They are the Presidents of the NGOs who proposed projects to the DAR to be funded from the Malampaya Funds. They can be served with subpoena, notices, orders, resolutions and other processes of the Honorable Office at their respective address stated in the MOA. 7.

JANET LIM NAPOLES is said to be the brains of the modus operandi of using NGOs to access public funds and who benefitted therefrom. While the John and Jane Does are private individuals who, in one way or another, conspired, caused the release, and benefitted from the public funds accessed by the bogus NGOs. She can be served with subpoena, notices, orders, resolutions and other processes of the Honorable Office at Fort Sto. Domingo, Sta. Rosa, Laguna .

The Charges: 8.

The above-named respondents are being charged for the commission of Violation of Republic Act 7080 or the Anti-Plunder Law; Violation of Republic Act 9184 or the Government Procurement Reform Act; Violation of Republic Act 3019 or the Anti-Graft and Corrupt Practices Act; Violation of Republic Act 6713 or the Code of Conduct and Ethical Standards for Government Officials and Employees; Malversation of Public Funds; and Grave and Serious Misconduct.

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Facts of the Case: 9.

Under Presidential Decree 910, the Malampaya funds should be spent only for the development of energy resources of the country or to energy -related projects.

Section 8 of PD 910 provides: “Section 8. Appropriations. The sum of Five Million Pesos out of any available funds from the National Treasury is hereby appropriated and authorized to be released for the organization of the Board and its initial operations. Henceforth, funds sufficient to fully carry out the func tions and objectives of the Board shall be appropriated every fiscal year in the General Appropriations Act. All fees, revenues and receipts of the Board from any and all sources including receipts from service contracts and agreements such as application and processing fees, signature bonus, discovery bonus, production bonus; all money collected from concessionaires, representing unspent work obligations, fines and penalties under the Petroleum Act of 1949; as well as the government share representing royalties, rentals, production share on service contracts and similar payments on the exploration, development and exploitation of energy resources, shall form part of a Special Fund to be used to finance energy resource development and exploitation programs and projects of the government and for such other purposes as may be hereafter directed by the President.�

10. In 2011 or thereabouts, the Executive Department through the Office of the President and the DBM through Secretary Abad approved the release of Malampaya Funds in billions of pesos for projects or purposes not related to energy exploration, development or exploitation.

11. One of the departments who were allocated such funds is the DAR. And on several occasions, the DAR

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headed by Secretary Delos Reyes entered into Memoranda of Agreement (MOA) with several dubious non -government organizations (NGO) for the implementation of various projects not-related to energy development. In addition, the projects consist mostly of ghost projects were none of the intended beneficiaries received or derived any benefit or deliveries. Among those projects are: 11.1. The Organic Farming through the use of Vermi-Composting Program proposed and implemented by WorkPhil Foundation for the Municipality of Licab, Nueva Ecija in the amount of ten million pesos (P10,000,000.00). Copy of the MOA for the said project signed by USEC Nieto of the DAR, Wilfredo Domingo, Mayor of Licab, Nueva Ecija and Ms. Teresita Reyes, President of WorkPhil Foundation is hereto attached and marked as ANNEX “A”. The Check in the amount of P10,000,000.00 dated February 24, 2011 paid to the order of WorkPhil Foundation is hereto attached and marked as ANNEX “A-1”; the Official Receipt issued by WorkPhil Foundation for the receipt of P10,000,000.00 is hereto attached and marked as ANNEX “A-2”. The Disbursement Voucher for the said project is hereto attached and marked as ANNEX “A-3”. The Obligation Request for the project is hereto attached and marked as ANNEX “A-4”.

11.2. The Organic Farming through the use of Vermi-Composting Program proposed and implemented by WorkPhil Foundation for the Municipality of Vintar, Ilocos Sur in the amount of ten million pesos (P10,000,000.00). Copy of the MOA for the said project signed by USEC Nieto of the DAR, Jose Foronda, Mayor of Vintar, Ilocos Sur, and Ms. Teresita Reyes, President of WorkPhil Foundation is hereto attached and marked as ANNEX “B”. The Check in the amount of P10,000,000.00 dated February 24, 2011 paid to the order of WorkPhil Foundat ion is hereto attached and marked as ANNEX “B-1”; the Official Receipt issued by WorkPhil Foundation for the receipt of P10,000,000.00 is hereto attached and marked as ANNEX “B-2”. The Disbursement Voucher for the said project is hereto attached and marked as ANNEX “B-

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3”. The Obligation Request for the project is hereto attached and marked as ANNEX “B-4”.

11.3. The Organic Farming through the use of Vermi-Composting Program proposed and implemented by WorkPhil Foundation for the Municipality of Marcos, Ilocos Norte in the amount of ten million pesos (P10,000,000.00). Copy of the MOA for the said project signed by USEC Nieto of the DAR, Salvador Pillos, Mayor of Marcos, Ilocos Norte, and Ms. Teresita Reyes, President of WorkPhil Foundation is hereto attached and marked as ANNEX “C”. The Check in the amount of P10,000,000.00 dated February 24, 2011 paid to the order of WorkPhil Foundation is hereto attached and marked as ANNEX “C-1”; the Official Receipt issued by WorkPhil Foundation for the receipt of P10,000,000.00 is hereto attached and marked as ANNEX “C-2”. The Disbursement Voucher for the said project is hereto attached and marked as ANNEX “C-3”. The Obligation Request for the project is hereto attached and marked as ANNEX “C-4”.

11.4. The Organic Farming through the use of Vermi-Composting Program proposed and implemented by WorkPhil Foundation for the Municipality of Dingras, Ilocos Norte in the amount of ten million pesos (P10,000,000.00). Copy of the MOA for the said project signed by U SEC Nieto of the DAR, Marynette Gamboa, Mayor of Dingras, Ilocos Norte, and Ms. Teresita Reyes, President of WorkPhil Foundation is hereto attached and marked as ANNEX “D”. The Check in the amount of P10,000,000.00 dated February 24, 2011 paid to the order of WorkPhil Foundation is hereto attached and marked as ANNEX “D-1”; the Official Receipt issued by WorkPhil Foundation for the receipt of P10 ,000,000.00 is hereto attached and marked as ANNEX “D-2”. The Disbursement Voucher for the said project is hereto attached and marked as ANNEX “D-3”.

The Obligation Request for the project is hereto attached and marked as ANNEX “D-4”.

11.5. The Organic Farming through the use of Vermi-Composting Program proposed and 7

implemented by WorkPhil Foundation for the Municipality of Bangui, Ilocos Norte in the amount of ten million pesos (P10,000,000.00). Copy of the MOA for the said project signed by USEC Nieto of the DAR, Salvacion Cimatu, Mayor of Bangui, Ilocos Sur, and Ms. Teresita Reyes, President of WorkPhil Founda tion is hereto attached and marked as ANNEX “E”. The Check in the amount of P10,000,000.00 dated February 24, 2011 paid to the order of WorkPhil Foundation is hereto attached and marked as ANNEX “E-1”; the Official Receipt issued by WorkPhil Foundation for the receipt of P10,000,000.00 is hereto attached and marked as ANNEX “E-2”. The Disbursement Voucher for the said project is hereto attached and marked as ANNEX “E-3”. The Obligation Request for the project is hereto attached and marked as ANNEX “E-4”.

11.6. The Organic Farming through the use of Vermi-Composting Program proposed and implemented by Samahan Mags asaka sa Kapatagan at Kabundukan Foundation for the Municipality of Paombong, Bulacan in the amount of ten million pesos (P10,000,000.00). Copy of the MOA for the said project signed by USEC Nieto of the DAR, Donato Marcos, Mayor of Paombong, Bulacan, and Ms. Ashley Baui, President of Samahan Magsasaka sa Kapatagan at Kabundukan Foundation is hereto attached and marked as ANNEX “F”. The Official Receipt issued by the said foundation for the receipt of P10,000,000.00 is hereto attached and marked as ANNEX “F-1”. The Disbursement Voucher for the said project is hereto attached and marked as ANNEX “F-2”. The Obligation Request for the project is hereto attached and marked as ANNEX “F-3”.

11.7. The Organic Farming through the use of Vermi-Composting Program proposed and implemented by Samahan Magsasaka sa Kapatagan at Kabundukan Foundation for the Municipality of Samal, Bataan in the amount of ten million pesos (P10,000,000.00). Copy of the MOA for the said project signed by USEC Nieto of the DAR, Generosa Dela Fuente, Mayor of Samal, Bataan, and Ms. Ashley Baui, President of Samahan Magsasaka sa Kapatagan at 8

Kabundukan Foundation is hereto attache d and marked as ANNEX “G”. The Official Receipt issued by the said foundation for the receipt of P10, 000,000.00 is hereto attached and marked as ANNEX “G-1”. The Disbursement Voucher for the said project is hereto attached and marked as ANNEX “G-2”.

The Obligation Request for the project is hereto attached and marked as ANNEX “G-3”.

11.8. The Organic Farming through the use of Vermi-Composting Program proposed and implemented by Samahan Mags asaka sa Kapatagan at Kabundukan Foundation for the Municipality of San Pablo, Isabela in the amount of ten million pesos (P10,000,000.00). Copy of the MOA for the said project signed by USEC Nieto of the DAR, Antonio Miro, Jr., Mayor of San Pablo, Isabela, and Ms. Ashley Baui, President of Samahan Magsaka sa Kapatagan at Kabundukan Foundation is hereto attached and marked as ANNEX “H”. The Official Receipt issued by the said foundation for the receipt of P10,000 ,000.00 is hereto attached and marked as ANNEX “H-1”. The Disbursement Voucher for the said project is hereto attached and marked as ANNEX “H-2”.

The Obligation Request for the project is hereto attached and marked as ANNEX “H-3”.

11.9. The Organic Farming through the use of Vermi-Composting Program proposed and implemented by Samahan Magsasaka sa Kapatagan at Kabundukan Foundation for the Municipality of Porac, Pampangga in the amount of ten million pesos (P10,000,000.00). Copy of the MOA for the said project signed by USEC Nieto of the DAR, Condralito Dela Cruz, Mayor of Porac, Pampangga, and Ms. Ashley Baui, President of Samahan Magsasaka sa Kapatagan at Kabundukan Foundation is hereto attached and marked as ANNEX “I”. The Official Receipt issued by the said foundation for the receipt of P10,000 ,000.00 is hereto attached and marked as ANNEX “I-1”. The Disbursement Voucher for the said project is hereto attached and marked as ANNEX “I-2”. The Obligation Request for the project is hereto attached and marked as ANNEX “I-3”.

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11.10. The Organic Farming through the use of Vermi-Composting Program proposed and implemented by Samahan Magsasaka sa Kapatagan at Kabundukan Foundation for the Municipality of Benito Soliven, Isabela in the amount of ten million pesos (P10,000,000.00). Copy of the MOA for the said project signed by USEC Nieto of the DAR, Benjamin E. Sanglay, Mayor of Benito Soliven, Isabela and Ms. Ashley Baui, President of Samahan Magsa saka sa Kapatagan at Kabundukan Foundation is hereto attached and marked as ANNEX “J”. The Official Receipt issued by the said foundation for the receipt of P10,000,000.00 is hereto attached and marked as ANNEX “J-1”. The Disbursement Voucher for the said project is hereto attached and marked as ANNEX “J-2”.

The Obligation Request for the project is hereto attached and marked as ANNEX “J-3”.

11.11.The Rural Farming Reform System project proposed and implemented by Social Development Program for Farmers Foundation, Inc. in the amount of five million pesos (P5,000,000.00) for the Municipality of Infanta, Quezon. Copy of the MOA for the said project signed by USEC Pacturan of the DAR, Filipina Grace America, Mayor of Infanta, Quezon, and Benhur K. Luy, President of Social Development Program for Farmers Foundation, Inc is hereto attached and marked as ANNEX “K”. The Official Receipt issued by the said foundation for the receipt of P5,000,000.00 is hereto attached and marked as ANNEX “K-1”. The Disbursement Voucher for the said project is hereto attached and marked as ANNEX “K-2”. The Certificate of Availability of Funds for the project is hereto attached and marked as ANNEX “K-3”.

11.12. The Backyard Agri Economic Scheme project proposed and implemented by Karangyaan Para sa Magbubukid Foundation Inc. in the amount of five million pesos (P5,000,000.00) for the Municipality of Calasiao, Pangasinan. Copy of the MOA for t he said project signed by USEC Pacturan of the DAR, Mark Roy Macanlalay, Mayor of Calasiao, Pangasinan, and Simplicio Gumafelix, President of Karangyaan Para sa 10

Magbubukid Foundation Inc. is hereto attached and marked as ANNEX “L”. The Official Receipt issued by the said foundation for the receipt of P5,000 ,000.00 is hereto attached and marked as ANNEX “L-1”. The Disbursement Voucher for the said project is hereto attached and marked as ANNEX “L-2”. The Obligation Request is hereto attached and marked as ANNEX “K3” The Certificate of Availability of Funds for the project is hereto attached and marked as ANNEX “L4”.

11.13. The Farming Output Improvement Program project proposed and implemented by Kaupdan an para sa Mangunguma Foundation, Inc. in the amount of five million pesos (P5,000,000.00) for the Municipality of Dinalupihan, Bataan. Copy of the MOA for the said project signed by USEC Pacturan of the DAR, Joel Jaime Payumo, Mayor of Dinalupihan, Bataan, and John Raymond De Asis, President of Kaupdanan para sa Mangunguma Foundation, Inc. is hereto attached and marked as ANNEX “M”. The Official Receipt issued by the said foundation for the receipt of P5,000,000.00 is hereto attached and marked as ANNEX “M-1”. The Disbursement Voucher for the said project is hereto attached and marked as ANNEX “M-2”. The Obligation Request is hereto attached and marked as ANNEX “M-3” The Certificate of Availability of Funds for the project is hereto attached and marked as ANNEX “M-4”.

11.14. The Agriculture Harvest Development Strategy project proposed and implemented by Ginintuang Alay sa Magsasaka Foundation, Inc. in the amount of five million pesos (P5,000,000.00) for the Municipality of San Nicolas, Batangas. Copy of the MOA for the said project signed by USEC Pacturan of the DAR, Epifanio Sandoval, Mayor of San Nicolas, Batangas, and John B. Lim, President of Ginintuang Alay sa Magsasaka Foundation, Inc.. is hereto attached and marked as ANNEX “N”. The Official Receipt issued by the said foundation for the receipt of P5,000,000.00 is hereto attached and marked as ANNEX “N-1”. The Disbursement Voucher for the said project is hereto attached and marked as ANNEX “N-2”. The 11

Obligation Request is hereto attached and marke d as ANNEX “N-3” The Certificate of Availability of Funds for the project is hereto attached and marked as ANNEX “N-4”.

11.15. The Community Agricultural Development Scheme project proposed and implemented by Agri and Economic Program for Farmers Foundation, Inc. in the amount of five million pesos (P5,000,000.00) for the Municipality of Umingan, Pangasinan. Copy of the MOA for the said project signed by USEC Pacturan of the DAR, Eldred Tumbocon, Mayor of Umingan, Pangasinan, and Nemesio Pablo, Jr., President of Agri and Economic Program for Farmers Foundation, Inc. is hereto attached and marked as ANNEX “O”. The Official Receipt issued by the said foundation for the receipt of P5,000,000.00 is hereto attached and marked as ANNEX “O-1”. The Disbursement Voucher for the said project is hereto attached and marked as ANNEX “O-2”. The Obligation Request is hereto attached and marked as ANNEX “O-3” The Certificate of Availability of Funds for the project is hereto attached and marked as ANNEX “O-4”.

12. All of these projects were funded from the Malampaya Funds. But they are not related in any way with the exploitation, development , and utilization of energy resources in violation of PD 910.

13. More importantly, those projects were never implemented. Thus, the millions of pesos rele ased to the NGOs were squandered.

14. The DBM and DAR also failed to evaluate the records of these NGOs, which accessed the Malampaya funds. These led to the dissipation of the funds to the detriment of the public.

15. The Commission on Audit (COA), in its Audit Observation Memorandum sent to the DAR Secretary Delos Reyes had noticed that funds releas ed to these NGOS were not liquidated. Some of the NGOs were not even registered with the SEC. Some were engaged in projects totally

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unrelated to the purpose or purposes for which they were incorporated. As such, COA recommended the filing of cases against the NGOs as well as the DAR officials accountable for the transactions. Copy of the COA report is hereto attached and marked as ANNEX “P�.

16. Worst, the project proponents were using the predicament of the hapless farmers and their miserable situation as justification for the release of the public funds they have squandered. Equally revolting is the fact that these agencies of the government, the DBM and the DAR, in one way or another, facilitated, abetted and even consciously misinterpreted the law, rules and regulations to ensure the successful pillage of public funds.

17. In the case of the President and respondent public officials of the DBM, they should know and should have known that the Malampaya Funds were earmarked for energy development or energy-related projects. But despite such fact, it approved the release of the funds to the DAR, which is in no way engaged in energy development.

18. The projects that the DAR entered into with the NGOs could attest to it. Those projects are not in any way related to energy-development. Worst, those p rojects were never implemented. Not a single centavo was spent for the said projects and not a single farmer received any benefit therefrom.

19. In the same vein, Secretary Abad and Undersecretary Relampagos of the DBM should be held equally liable with the officials of the DAR. They allowed the release of such funds for those projects when the projects were highly anomalous and do not conform to the government procurement system. They should also know that the Malampaya Funds were intended to the exploration, development, and utilization.

20. Had the DBM, which has the primary duty to MANAGE public funds and their disbursement, not been remiss in its duty of monitoring the disbursement, then the scam with its magnitude could not have transpired. Thus ,

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those DBM officials are principal by cooperation to the offenses hereto charged.

indispensable

21. Clearly, the respondents-public officials and the private individuals hereto charged committed vi olation of several penal laws.

PRAYER WHEREFORE, PREMISES CONSIDERED , we most respectfully pray from the Honorable Office to: 1.

CHARGE the above-named respondents for violation of Republic Act 7080 or the Anti -Plunder Law as the amount involved hereof is more than P50,000,000.00; 2.

CHARGE the above-named respondents for violation of Republic Act 9184 for their utter failure to conduct competitive public bidding in selecting NGOs to implement the DA projects; 3.

CHARGE the above-named respondents for violation of section 3 (e) and (g) of Republic Act 3019 , which provides: Section 3. Corrupt practices of public officers. In addition to acts or omissions of public officers already penalized by existing law, the following shall constitute corrupt practices of any public officer and are hereby declared to be unlawful: (e) Causing any undue injury to any party, including the Government, or giving any private party any unwarranted benefits, advantage or preference in the discharge of his official administrative or judicial functions through manifest partiality, evident bad faith or gross inexcusable negligence. This provision shall apply to officers and employees of offices or government corporations charged with the grant of licenses or permits or other concessions.� (g) Entering, on behalf of the Government, into any contract or transaction manifestly and 14

grossly disadvantageous to the same, whether or not the public officer profited or will profit thereby.�

4.

CHARGE the above-named malversation of public funds

respondents

for

5.

CHARGE the above-named violation of Republic Act 6713;

respondents

for

6.

CHARGE the above-named respondents for grave and serious misconduct.

7.

We also urge the Honorable Office to immediately place the above-named public respondents in preventive suspension. The charges against them constitute grave criminal offenses involving gra ft and corruption and for grave and serious misconduct which would warrant dismissal from service. The evidence of guilt against them is also strong. More importantly, their continued stay in office will definitely prejudice this case because they have access to the files and records and could easily alter or forge them. They can also threaten, manipulate, and harass witnesses against them. Thus, pursuant to Section 24 of R.A. No. 6770, otherwise known as the Ombudsman Act of 1989, we most respectfully move for the issuance of preventive suspension of the above -named public respondents.

OTHER RELIEF, just and equitable under the premises is likewise prayed for.

21 January 2014, Quezon City.

RAFAEL V. MARIANO WILFREDO A. MARBELLA TINo.232-073-263-000 VIN: 7404-3970A-B025WAM10000

NESTOR A. VILLANUEVA VIN: 3405-0168A-L2957NAV10000

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SUBSCRIBED AND SWORN to before me this 21st day of January 2014 at Quezon City, I hereby certify that I have personally examined the affiant and I am satisfied that he voluntarily executed and understood the contents of his Complaint -Affidavit.

Doc. No. ___; Page No. ___; Book No. ___; Series of 2014

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