Yu, Smile Christienne

Marquez, Josemaria Ignacio

Pabrua, Anna Karenina
Tangonan Julius Geoffreys

Republic of the Philippines

SANDIGANBAYAN
Quezon City

PEOPLE OF THE PHILIPPINES

Complainant,
Crim. Case No. 1234567
- versus - For: Violation of RA 7080
(Plunder)
Ramon Bong Revilla, Jr., et al,
Cambe as Chief of Staff of Sen.
Bong Revilla, Janet Lim Napoles,
Lim, De Asis, of JLN Corp.
Relampagos, Alet Nunez, Paule,
Bare of the Department of Budget
and Management
Respondents.

x------------------------------------------x

JUDICIAL AFFIDAVIT OF
JULIUS GEOFFREY TANGONAN

I, BONG REVILLA JR, 51 years old, born on September 25, 1966,

married, as a Senator of the Republic of the Philippines, after having
been swron in accordance with law, hereby depose and state:

PRELIMINARY STATEMENT

This Judicial Affidavit of JULIUS GEOFFREY TANGONAN. is

executed to serve his direct testimony in the instant case. This Judicial
affidavit is offered to prove: 1) all the allegations in the complaint for
Plunder. 2) all matters related thereto, with reservations to the resent
additional exhibits in the course of the proceedings of the instant case.

That in accordance with A.M. No. 12-8-8-SC, which prescribes

the use of judicial affidavits to serve as the direct examination testimony
Yu, Smile Christienne
Marquez, Josemaria Ignacio
Pabrua, Anna Karenina
Tangonan Julius Geoffreys

of the witness, on the basis of which the adverse party may conduct
their cross-examination on such a witness, I hereby execute this judicial
affidavit in a question and answer format;

That conformably also with section 3 (c) thereof, I hereby state under
the pain of perjury that in answering the questions asked of me, as appearing
herein below, I am fully conscious that I did so under oath, and that I may face
criminal liabilities for false testimony or perjury;

Q1: Please state your name for the record, or What is your name and
age?

A1: My Name is JULIUS GEOFFREY TANGONAN, 34 years old

Q2: What was your occupation when this case was filed against you?

A2: I am an Investigator with the Commission on Audit

Q3: How long have you been employed with the Commission on Audit,

A3: I have been employed with the Commission on Audit for 10 years

Q4: What is your relationship with the respondent BONG REVILLA JR?

A4: None, we are not related

Q5: Do you personally know Cambe, or Napoles or Revilla or

Relampagos, Alet Nunez, Paule and Bare?

A5: No, I do know any of them, prior to this case, I only knew of them
because of the assignment of auditing the Priority Development
Assistance Fund of the Senator

Q6: What are your qualifications to conduct an Investigation with the

Commission on Audit

A6: I am a certified public accountant and graduated from De La Salle

University with a degree in Accountancy, and I am a Lawyer who passed
the Bar, I studied in the De La Salle University College of Law.

Q7: Why did you file this complaint for plunder against the
respondent?
Yu, Smile Christienne
Marquez, Josemaria Ignacio
Pabrua, Anna Karenina
Tangonan Julius Geoffreys

A7: As an investigator employed in the Commission on Audit and as a

concerned citizen, after thoroughly investigating the allegations made
against the Senator, and after being instructed to do so in line with my
occupation as an investigator at the Commission on Audit, I discovered
that disbursements were made by requesting the Department of Budget
and Management that funds from his Priority Development Assistance
Fund or PDAF amounting to P199,966,000.00 be allocated for contracts
to purchase fertilizers with Kaupdanan Para sa Mangunguma
Foundation, Inc or KPMFI a Non Government Organization controlled by
Janet Lim Napoles under her Umbrella holdings organization JLN
Corporation, to be given to poor farmers to assist in farming,

Q8: What did you discover after the investigation?

A8: That the foundation Kaupdanan Para sa Mangunguma

Foundation, Inc or KPMFI a Non Government Organization controlled by
Janet Lim Napoles under her Umbrella holdings organization JLN
Corporation, never purchased and distributed fertilizers for rural under
marginalized farmers.

Q9: Is there anything else peculiar or worth mentioning ?

A9: Yes, I also noticed that the fertilizer they sought proposed to
purchase was overpriced by as much as 500 percent, but again, no such
acquisition and distribution was made.

Q10: Did you personally conduct this investigation?

A10: Yes, personally conducted this investigation.

----END OF STATEMENT----

IN WITNESS WHEREFORE, I hereunto set my hand below this 5th of

December of 2017, at Quezon City

Atty. Julius Geoffrey Tangonan

Affiant
Yu, Smile Christienne
Marquez, Josemaria Ignacio
Pabrua, Anna Karenina
Tangonan Julius Geoffreys

SUBSCRIBED AND SWORN to before me this 5th day of December

207 in Manila. Further I certify that I personally examined the herein
affiant that he voluntarily executed and fully understood his statements.

Atty. Josemaria Ignacio Mijares Marquez

Administering Officer

ATTESTATION

I, Smile Christein Yu, investigator of the Office of the Ombudsman

on my oath as the Investigator-on-Case (IOC), hereby depose and states:

That I have personally conducted the foregoing examination to

the witness-affiant BONG REVILLA JR at the Office of the Ombudsman in
Quezon City.
That I have faithfully recorded in English language the questions
asked of him and the corresponding answers that he gave in response to
the questions asked;

Neither I nor any other person/s coached this witness-affiant

regarding the answers given by her.

IN WITNESS WHEREOF, I hereunto set my hand below this 5th

day of December, 2017 at Quezon City.

Smile Christein Yu
Investigator

SUBSCRIBED AND SWORN to before me this 5th day of

December, 2017 in Quezon City. Further, I certify that I personally
examined the herein affiant that he voluntarily executed and fully
understood his statements.

Atty. Anna Karenina Pabrua

Administering Officer