Rogelio Montealto (part 4) Graft and Corruption

@tttre of tlle @rnhu[gnrrr$Agham Road, Diliman, Quezon City, philippines

ROGELIC P. MONTEALTO,Provincial Budget Officer,Province of Zamboanga del Sur,

Complainant,

-versus-

ANTONIO H. CERILLES,Former DtrNR Secretary &Incumbent Governor ofZamboanga del Sur,andAURORA E. CERILLES,Former Governor of Zamboangadel Sur & Incumbent Member oithe House of Representatives,

Respondents.X-- ---X"

Republic of the Philippines

Criminal Case No.

IC-OC- 13-O 174lc-oL-t1 - oll F

For:

Violation of Anti-Plunder Act.Violation of Graft & Corrupt

Practices Act,Malversation of Public Funds& Properties, andViolations of Other Penal Laws

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

of L6

Affidavit-ComplaintRogelio D. Montealto

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 a.rn, secondarily, executing this SupplementalAjfidavit-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 Matters

The COMPLAINANT

1. That COMPLAINANT is of legal &ge , married, Filipinoand a resident of Block 12, Lot 14, Sunrise VillageSubdivision, Tiguma, Pagadian City where judicialnotices, summons anr,l similar orders appertainingthis complaint may be addressed and served;

2. Thai COMPLAINANT is the incumbent provincialBudget Officer of the Province of Zarnboanga deSur having been appointed on January 2, 2OO(appointment attached and marked as Annex K

discharging functions, duties and responsibilitiprescribed in R.A. 7160, otherwise known as tLocal Government Code of 1991;

3. That prior to h.erein c0IvIPLAII{AI\T's appointmentas Provincial Budget officer, he was first designatecl

of L6


as Olc-Provincial Adniinistrator on July 2, 2AOI toDecember 31, 2001;

4. That as OIC--Provincial Administrator,COMPLAINANT received direct orders not oniy fromthe ACCUSED then Gc,vernor Aurora tr. cerilies butalso, most of the time, from her husband ACCUSBDAntbnio H. cerilles who was then consideredunemployed after losing his bid in the May 2001elections for the position of Member, House ofRepresentatives representing the 2.a congressionalDistrict of Zamboanga de1 Sur;

5. That COMPLAINANT, as the' then olC-provincialAdministrator, attests to the fact that almost allsignilicant decisions in running the affairs of theProvincial Government were those laid down byACCUSED Antonio H. Cerilles, including but notlimited to the biggest and most significant decisionsever made by the Cerilles Administration, thereorganization of the organizational structure of theProvincial Government" of zarnboanga del sur thatled 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, evendictated the herein COMPLAINANT (whenpresenting the reorgantzational scheme before theSangguniang Panlalatuigan) the number ofemployees to be retained when he asked: *Hla kaempleyado imong gipabilin? (How many employeesdid you retain?). COMPLAINIANT responded: "I,O2OBoss." And he shouted: Daghon pa na! (That,s stilltoo many!). And so COMPLAINANT asked: *Hla marldiag gusto nimo ipabilin, Boss?,, (How mantherefore you want to be retained, Boss?).replied: 520! At the back of his miCOMPLAINANT was figuring out from wherewhat Department further personnel reductiontaken. Difficult as it was, after restudyCOMPLAINANT was forced to bring down the figdto 721 which Antonio I-t. Cerilles finally accepted";

of 16


tae{a,ndbe1C''br

As ACCUSED Antonio H. Cerilles continuouslydictated and dominated the affairs of the ProvincialGovernment giving direct orders to COMPLAII\ANT,there were even several instances when ACCUSEDAurora B. Cerilles, for reason she felt she was nolonger prlvy to decisions and implemented withouther knowledge, she even prompted theCOMPLAINANT by saying: "Esforyahe pod ko unsayingong gisabutan ni Boss ug iyang gustoipaimplementar!" (Tell me also what the Bossdiscussed with you and what he wants to beimplemented!);

Herein COMPLAiNANT' purpbsely presented aboveantecedent facts and instances to ESTABLISH THEF.ACT that indeed r,'rhile ACCUSED Aurora E.Cerilles was the de jure Governor, being the dulyelecred incumbent to the position, it was and fromthen on up to the end of her third term, herhusband, ACCUSBD Antonio H. Cerilles was, intruth and in fact, the de facto Governor, the onewho was actually running the affairs of theProvincial Government. Henceforth, all acts, all onrecords, committed by ACCLISED then Governor,now House Representative Aurora E. Cerilles, inviolations to existing laws, rules and regulationsgoverning the use of funds andlor properties of theProvincial Government of Zarnboanga de1 Sur wereall done with the complete knowledge and uponorder of ACCUSED Antonio H. Cerilles to conjugallyenrich themselves and in furtherance thereto,perpetuated by him being now the incumbentGovernor as hereinafter enumerated;

The ACCUSED

That the ACCUSED Spouses Antonio H. Cerillesand Aurora E. Cerilles are all of legal oge, Filipinosand residents of MS Canuto Enerio Street, CapitoSite, Sto. Nino District, Pagadian City whejudicial notices, summons and similar ordeappertaining this complaint may be addressed aserved;

6.

7. Tkrut the ACCUSED Antonio I{.tr. Cerilles are, respectively,

of 16


Cerilles and Aurorathe incumbent

A.

Governor of the Province of Zarnboanga del Sur andthe Representative oi the Second CongressionaiDistrict of Zarnboanga del Sur having been bothelected in the May 10, 2OIO Local and NationalElections;

THE CHARGES

COMPLAINANT hereby accuses the ACCUSED for:

The crime of PLUNDER, MALVERSATION OFPUBLIC F.UNDS AND PROPERTIES ANDFALSIFICATION Of. PTIB.LIC DOCUMENTScommitted by raiding the finanies of the ProvincialGovernment of Zarnboanga de1 Sur for their ownself-aggrartdwement-amassing assets (specificallyincluding huge sum of cash), properties andbusiness enterprises directly and indirectly throughmisappropriations, conversions, misuse ormalversation of public funds using dummies,agents, subordinates, business associates andcombinations thereof a s evidenced by the following:

The issuance of checks in the amount ofPs54rL78r123.13 not covered or supported by dulyrequired supporting documents as indicated in theCOA Annual Audit Reports, a srtmmary portions ofwhich are hereto attached and marked as Annex "8"which form an integral part of this complaint.

That the above amount of Ps54, L78r123.13represents only a small portion of the more thanPs35O Million amount of checks issued withoutvouchers and other supporting documents whichwere only subsequently tampered and/ ormanipulated by the ACCUSED (utilizingsubordinates) to make it appear in order and inaccordance with the duly accepted accounting andauditing rules and regulations. By ordering thProvincial Auditors Valeriano B. Patangan, JrMadeline J. Majestrado and JeannetteCalamohoy through the issuance of an appropriSubpoena duces tecu.m ad Testificanduwl for isubmission before the most Honorable Office of thOmbudsman, these documents can easily beidertified and testified to by herein COMPLAINANT;

of 16


i.

In the said Annexes, the Honorable Ombudsman'sattention is hereby most respectfully invited to thefact that the payees indicated therein as: Luckysavers General Merchandise, Botica Jill and JehnCris Enterprises, are owned by one, and only oneproprietor, Lisa Aranding, who is one of theACCUSBn,* business associates responsible inghost deliveries and conversion of items supposedt" be d elivered to ttre provincial government butinstead, to the ACCUStrD's privately ownedbusinesses;

in the documents

,.\At this juncture, COIEPLAINANT hereby IMPLEADSall suppliers indicatedaforementioned;

2. The delivery of aforementioned hardware materials(per attached copies of some Trust Receiptscovering these deliveries and supported byAffidavit of Nelson Escario, marked Annex "C" forthe construction of various buildings, businessestablishments and other infrastructure facilitiesprivately owned by the AccusED as shown in theittached 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-l'to "D-13"

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 official guests and dignitaries. The hote

houses ACCUSED-owned ANCER Enterprises

dealing in the sale of CEBU Pa..ifig ti49!!-ell4

of 16


ExhibitNumbers

also manned by provincial governmentemployees. The Hotel also houses the AK Bingo

which is likewise privately-owned and operated

by the ACCUSED. The hotel's power supply is

backed up by a huge stand-by electric power

Generating Set owned by the ZDS provincial

Alindahaw Lakeview Resort, an expensively

constructed multi-million world-class vacation

hotel & restaurant resort nestled in idyllic Lake

Wood, featuring children's waterworld swimming

pools & multi-million pesos worth Quadruple

ZipLines, located at Biswangan, Lakewood;

Zamboanga del Sur. As in the Alindahaw Hotel,

the resort constrqction is funded out clf ZDS

provincial government'S fu nd.

Pensionne Yllana. Also located at the heart of

Pagadian City, it is PRIVATELY-OWNED by the

ACCUSED and also funded out of ZDS

government funds. Recently, it likewise houses

Pagadian Branch of Monterey Meatshop

franchised bv the ACCUSED.

Boss Cof$ee. Named after how the ACCUSED

wants tc be addressed, the outfit is also funded

out of government funds.

McDonal.l Branch. Franchised by the ACCUSED'

During lts inauguration, the mascot was in fact

played b'/ one of the provincial government's

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 Sovernmentfunds. 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 fordrug tests are owned by the ACCUSED's brotherand sister.Cassava Warehouse. Located

Labangait, Zamboanga del Sur,

facility i',ouses cassava produced

farmers under sale contract withCorpora:.ion. PrivatelY owned bY

in Dalapa

the 3-hec

by low-inthe San Mithe ACC

its opei"ation is financed out

of 16


of govern

Baganian Broadcasting Corporation" Aithoughcorporate papers indicate that this outfit is

owned by the ACCUSED's crony City CouncilorRoque Yamba, its real owner by the ACCUSED is apublic knowledge. The station is featured in a

case no\il pending before the Sandiganbayaninvolving transactions with the provincia I

overnment in violation of RA 184.

Shell G.isoline Station. Owned by the ACCUSED

and operates under a dummy's name (a familyfriend rn Cagayan de Oro City). Besides thestation is the ACCUSED-owned TantonMeatshop, a marketing outlet for pork producedfrom his own ,rnulti-million Piggery Farm in

Dumalinao, Zamboanga del Sur. ln the secondfloor of the Meatshop is the office of theACCUSED's daughter-in-law, Junaflor S. Cerilles(wife of ACCUSED's son Mayor Ace Cerilles),Executive Assistant lV (SG 261 of the ProvincialGovernment of ZDS, not reporting in theprovincial Capitol but takes charge of theACCUSED's family business of infrastructureconstruction projects and supplies ofconstruction materials and office supplies forthe provincial government of Zamboanga delSur using dummies. A provincial governmentemployee, Marife Ambuhot, takes charge in thesupplies deliveries and collection of paymentsthereof.

The properties mentioned in the foregoing table orepresents a small portion of ACCUSED's properwhich includes several hundreds of hec[aresfarms (a more than 400 hectares of ru

of 16


Veterans Bank. The building is owned by theACCUSED using government fund. lt housesVeterans Bank of the Philippines' PagadianBranch.

Enerio Compound occupied by the ACCUSED-

owned Pagadian Paramedic &Technical Schoot(PffS). its operation is financed by the provincialgoverni-nent and captured funds from TESDA tothe disrnay of local private vocational schools.Fronting PTTS (still inside the compound) is

ACCUSED-owned lnternet caf6, fully furnishedout of Bovernment funds. lt also houses PMCMerchandise, a supply outfit owned by theACCUSED through a dummy, cornering supplneeds of the provincial capitol (see Annex "E".)

piantation and a rubber processing facility inLakcwood, a hundred hectare mango and coconutfarrri in Kalingayan, Dumalinao, ZdS, to name afiern-);

At this juncture, on the basjs on the number 11item in the foregoing table, herein COMPLAINAI\Thereby IMPLEADS Junaflor S. Cerilles and MarifeAmbuhot, both employees of the ProvincialGovernment of Zarnboanga del Sur, who areACTIVELY engaged in the operation of privatebusinesses owned by the ACCUStrD instead ofreporting to their respective dgties in the provincialcapitol;

3. The assignment of Provincialemployees as workers in their privatelyand other business est-ablishments asthe attached sarnple copiesAccomplishment Reports, Daily TimePayrolls.

Governmentowned farmsevidenced by

of DailyRecords and

The evidence mentioned herein are only samples ofsev-eral government employees utilized by theACCUSED in their personally-owned businesses.For instance in the document marked Annex "F",government employee and I or worker ReynaldoGumera, hired under Contract of Services, isassigned to tend the ACCUSED's Mango PlantationFarm in Kalingay?fl, Dumalinao, Zarnboanga de1Sur. On the other hand, Government workerAnastacio Maglasang Annex "G" is also assigned towork as feed mixer in the ACCUSBD's multi-miilionSwine Farm at Sumadat, Dumalinao, Zamboangadel Sur. Bvidence further show as indicated indocuments marked Annex "H", another provincialgovernment worker Rolando Arnoco was assigned todeliver surfacing materials for the ACCUSED'smulti-million world-class Prawn and Lobster Farmat Barangay Balong-balong, Pitogo, Zarrrboanga de1Sur.

At thisIMPLEADSresrronsible

juncture, COMPLAINANT also heprovincial government officials whoin the perpetration of these anomal

of 16


These include, MARLENE I-S" BEI|I'SALES,

Provincial Agriculturist and ALLAN CA'BATINGAN,respectively, for directly giving the order and forcertifying the truthfulness of the montkrly

accomplishments of workers Reynaldo Gumera and

Anastacio Maglasang. Provincial AdministratorANTHOIiW FREDERICK S. PADAYHAG is hereby

also IMPLEADED for certifying that charges toappropriation/ allotmen.i; are necessary and lawfuland made under his direct supervision (see

Obligations Request attached hereto and marked as

Anng,x "F".l.

On the other hand, COMPLAINANT furtherIMPLtrADS provincial government employee RUBtrItCADORNA for certifying thetruthfulness/ correctness of the Daity Time Recordof ROLAI\DO ARNOCO. Further, Ruben Cadorna,through issuance of Subpoenct ducesTecttm, shouldbe required to present lists of provincial governmentheavy and light equipment utiHzed in ACCUSED'sprivately owned businesses;

4. The assignment of provincial government-pair1security Guard.s (whose employer security agency ishired" under Contract of Security Services by theProvincial Government of Zamboanga del Sur) to theACCUSED's various irusiness establishments asevid,enced by the attached documents marked asAnnexes "1" to "I-9".

r

In .cnnection thereto, the attention of the mosthon,trable Office of the Ombudsman is again mostrespectfully invited to the summary of securityguards assignments as marked Exhibits 1- 1 1 inAnnex "I", as indicated in the following table:

Table 2. Summary of Security Guards' Assignment Posts

Assignment Posts

(ACCUSED's PrivOwned Establish

and/or Not SuP

of 16


Name of Security GuardsAssigned

to be Covered P

1 1". Requiron, Abuinto2. Enerio, Julius

Pagadian Paramedical& Technical School(PTTS), Pagadian City

2 3.

4.

5.

Empleo, CelestinoLastirnado, NoelUngang, Arnel

Alindahaw LakeviewResort , (a world-classvacation hotel &resta ura nt resortnestled in idyllic Lake

Wood, featuringchildren's water worldswimming pools &multi-million pe'sos

worth Quadruple Zip

Line) , Biswangan,Lakewood, Zamboangadel Sur

3 1. Sudiang, Freddiel

2. Angel, JonathanGovernor's PrivatelyOwned Garrage of his

Green Plate (private)Vehicles

4 'J,. Casupanan, Pampilo2. Llena, Jonvee3. Bandarlipe, Jessie

4. Sabihon, Jhon

Dumalinao Feed Mill(Although owned byZDS ProvincialGovernment, the feedsproduced are utilized by

the ACCUSED's privatelyowned Piggery Farm)

5 1. Chang, Jonathan2. Cagulada, Nelson3. Suizo. Ronaldo4. Rambo, Rollie

5. Sabejon, Jundie6. Codilla, Raul

Mayor Ace WilliamCerilles' Residence(Guard Ronaldo Suizo is

assigned as the MayorAce children'ssurrogate, sendingthem to and fetchingthem from schools).

6 1-. Lanaja, Sulpicio Private Residence ofVicente M. Cerilles,

ACCUSED's Father,Balongating, Guipos,Zamboanga del Sur

7 L. lligan, Romeo2" Tano,

Nacianseno

Land TransportationOffice (LTO), Tiguma,Pagadian City. Buildingprivately owned by thgACCUSED & constructy'dthrough provinfialqovernment funds. /

8 1. Libre, Janeth ACCUSED's priv{telyowned lnlernet \afelocated in front of PT\S

of 16


9 1. Hermoso,George

Escort of Dr. Zenaida E.

Galicianao, a privateperson, sister of theACCUSED, long retiredfrom governmentservice.

10 1,. Lacson, Jhunal2. Cameon,

Romeo

3. Sabijon, Arthuro4" Megalleon,

Javier

ACCUSED's privately-owned Warehouse,Dalapang, Labangan,

Zamboanga delSur

At this instance, herein COMPLAINANT herebyIMPLEADS security agency ,. JKB P-EPUBLICSBCURITY AGBNCY INC Branch Head NIDA R.ROSALES and further IMPLEADS ProvincialAdministrator ANTHONY FREDERICK S.PADAYHAG for again, certifying that charges toappropriation/ allotmerrt for the payment claim ofthe security guards' employer, JKB RtrPUBLICSELURITY AGENCY INC are lawful and under hisdirect supervision;

5. The ILLEGAL USED OF TRUST FUNDS to financeACCUSED's privately-owned businesses. FromCY2OO8 Cash Overdraft of Ps28r2o4r815.34, as ofend of CY2 0 1 1 , this overdraft ballooned tostaggering Ps275r888rOL4.OZ level, more than aquarter of Zamboanga del Sur's Annual Budget (perCOA's CY2O11 Annual Audit Report attachedhereto and marked as Annex "J". Although ZDS'CY2Ol2 Pinancial Statements has yet to befinalized, the overdraft is estimated to reach an all-time high of more than Ps300Mi11ion. Following is ahistorical summary of these overdrafts:

DecemberDecemberDecemberDecember

3 1, 200831,200931,201031,201 1

Ps 28,2O4,815.34219,562,486.83252,279 ,7 15.5427 5,BB8,Ol4.O2

The. incurrence of this overdraft was brought aby 'the systematic juggling of funds, inMISAPPROPRIATION OF FUNDS. By bloannual appropriations beyond the progovernment' capability to generate/ collect

of 16


cash revenues, huge expenses were incurred for theACCUSED's privately* lwn€d businesses (as abovedescribed). As finu.ncial requirements of theACCUSED's private},y-owned businesses andprojects cannot be paid from the General Fundin :riew of shortagebalances from the Trusts Funds are used insteadresulting to its continued depletion over theyeais without means in sight to have itreplenished. AND THESE JUGGLING/MISAPPROPRIATION OF. TRUST F.UNDS AREMOST RAMPANTLY DONE DURING THEINCUMBENCY OF THE AGGUSED ANTONIO H.CERILLES AS GOVERIiIOR;

Plagued with this cash shortage, the provincialgovernment of Zarnboanga del Sur no longer wasable to pay its mandatory obligations, whichincludes, but not limited to the non-remittance ofthe government and employeesGSIS/PAGIBIG/PHILHEALTH premiums, suppiiersand employees withholding taxes to the BIR andemployees loan repa,/ments to private creditor-banks per COA Aud; t Report for calendar years

Lately, for the first time in Zarnboanga del Surprovincial government's history, representationand* transportation allowances (RATA) aredisallowed by COA and are no longer paid toofficials entitled thereto in view of this CASHOVERDRAFT as evidenced by a series of COA'sdisallowances, some copies of which are heretoattached and marked as Annexes n'K" to "K-5";

6. Another means of siphoning funds from the ZDSprovincial government's coffers for the ACCUSED'sself-aggrandizement, to further enrich themselves,is the wanton availment of cash advances. Makinguse of employees as payees, cash advances arewithdrawn in the guise of utilizing it for confidentiaand intelligence expense and other purposes.funds were not actudly used as intended andaccordance with guidelines, rules and regulatiogoverning its use, the poor employee who representsas payee finds it dif{'icult to liquidate. Based on

Page t3 of 16

Affidavit-ComplaintRogelio B. Montealto

latest statement provided by COA, a copy of whichis hereto attached and marked as Annex "L", and"L-I" to "L-8", one employee-payee's unliquidatedcash advances now amounted to Ps73,426r752.O2"It may be noted that the reasons of its non-iiquidation are clearly manifested in COA'sseries of letters to the ACCUSED as attachedhereto 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:

Investigated and criminally charged with thecrimes of PLUNDER, GRAFT AND CORRUPTPRACTICES ACTS, MALVERSATTON OFPUBLIC FUNDS AND PROPERTIES andFALSIFICATION OF PUBLIC DOCUMENTS;Administratively charged for Grave Abuse of

Placed under PRE\IENTM SUSPENSIONpursuant 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.

MONTEALTOplainant

of 16

Affidavit-Complaint'Rogelio D. Montealto

1.

2.

3.

suBSCRTBED-Np_SWoRN to nerofl,4ilJ&ffi&*day of January, 2611rf, S6J*JWB&,, rniippi"*",-'an*",Rogelio P. Montealto exhibir-ing to me his Driver's LicenseNo. JO3-98-023512 issued by the Land TaransportationOffice with expiration date on August 2, 2014.

AITHDoc. x". \ffiPage No. 11Book No. Yl

!

Series ol_28l-3

I.IflTNRi,rd 0 T,rR rAr.

"rpj'ry1:srlyliL iffiiffif

Gl,t

fr

*r* *0.[1t#" ?,,?P.q9I?36? t ry{ n* MtA,, u *, H;*:,.1* ry ri i i6,,frth,rtrSffi-mry.:i6,tfihfi^4cL

E,aeilm.*itr6- i# _*rfiggt; or,

Republic of the Philippines)Cityof l\ttanila". "...) SS

VERIFICATIONAND

CERTIFICATION OF NON-FORUM SHOPPING

I, ROGELIO D. MONTtrALTO, of legal &ge, Filipinoand resident of Pagadian City, after having been dulysworn to in accordance with law, do hereby depose andsay: .

ATHAT I am the Private Complainant and I have

caused the preparation of the foregoing Complaint-Affidavit;

of 16

Affidavrt-ComplaintRogelio D" Montealto

THAT I have personalinformation, statements andare true and correct toknowledge;

knowledge and that atr1 theallegations contained hereinthe best of my personal

set myCity of

BTHAT I hereby certify that I have not commenceclany other action or proceeding involving the same issues

ln 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 supreme court,the court of Appeals of diff<rr*rf oi.tisions thereof, or anyother tribunal, court or agency; and

TH.,'T should I learn that a similar action orproceeding has been filed or is pending before thesupreme court, the court of Appears or the differentdivisions thereof, or any other tribunal, court or agency, Ishall ,so notify the court within five (5) days rroir srich

Knowtedge.

IN WITNESS WHEREOF, I have hereuntohand on this 28th day of January, 2013, at theManila, Philippin

ONTEALTOplaint

JAN S S fS13SUBSCRIBED AND SWORN tO bcfOr" 'Xl'ir,1"g

ZI"{Iday of January, 20rc[f,fatsFytll$Hiephilippines, AffiantRogelio P. Montealto exhibiti"g i; ffi rrl" Driver,s LicenseNo. JO3-98-023512 issued by the La rtationOffice with expiration date on Augu

Doc. No.Page No.Book No. IiLr i r- ..i i i: : ,:;:j -rj

pTi? NL'l. OigSti--i? : i1: ;12 lv'lLA-{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{) of 16


{r/'---T-t/

2,2014"

Series of 2O 13

Rogelio Montealto (part 4) Graft and Corruption

Documents

Transcript of Rogelio Montealto (part 4) Graft and Corruption