REPUBLIC OF THE PHILIPPINES

HOUSE OF REPRESENTATIVES
House of Representatives Complex
Constitution Hills, Quezon City

IN THE MATTER OF THE IMPEACHMENT OF RODRIGO ROA DUTERTE AS

PRESIDENT OF THE REPUBLIC OF THE PHILIPPINES,

REPRESENTATIVES NIEL C. TUPAS JR., JOSEPH EMILIO A. ABAYA, LORENZO R.

TANADA III, REYNALDO V. UMALI, ARLENE J. BAG-AO (other complainants
comprising at least one-third (1/3 of the total Members of the House of
Representatives are indicated below), Complainants.

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VERIFIED COMPLAINT FOR IMPEACHMENT

Undersigned COMPLAINANTS most respectfully file this duly Verified Complaint for
the Impeachment of the Honorable Rodrigo Roa Duterte, currently the President of
the Republic of the Philippines (hereafter, “Respondent”), upon the grounds of
Betrayal of Public Trust, Culpable Violation of the Constitution, Graft and Corruption,
Bribery, and Other High Crimes as follows:

PREFARATORY STATEMENT

That on June 30, 2016, the respondent took his oath as the 16th President of the
Republic of the Philippines stating:

"I do solemnly swear that I will faithful and conscientiously fulfil my duties as
President of the Philippines, preserve and defend its constitution, execute its laws,
do justice to every man, and consecrate myself to the service of the nation. So help
me God."

This complaint for impeachment is based on the following grounds:

1. Betrayal of public trust, bribery, culpable violation of the Constitution,

and other high crimes;

2. Betrayal of public trust, bribery, graft and corruption, culpable

violation of the Constitution, and other high crimes;
 3. Graft and corruption and other high crimes;

4. Unexplained wealth; and

5. Predicate crimes for plunder.

Pursuant to the Constitution which provides:

"Section 2. The President, the Vice President, the members of the Supreme
Court, the members of the constitutional commission, and the Ombudsman
may be removed from office, on impeachment for and conviction of, culpable
of the Constitution, treason, bribery, graft, and corruption, other higher crimes
or betrayal of public trust. "

NATURE OF THIS ACTION

Therefore, this action for impeachment is brought against President Rodrigo Roa
Duterte in accordance with the provisions of Section 2, Article XI of the 1987
Constitution, on the grounds of: (a) Betrayal of Public Trust; (b) Culpable Violation of
the Constitution; (c) Graft and Corruption; and (d) Bribery; and (e) Other High
Crimes

THE PARTIES

Complainants are current Members of the House of Representative, responsible

Filipino citizens and taxpayers, and are all of legal age. For purposes of the instant
Verified Complaint for Impeachment, complainants may be served with pleadings,
notices and processes at the House of Representatives, Constitution Hills, Batasan
Complex, Quezon City. They bring this action for and on behalf of the People of the
Republic of the Philippines by authority of the 1987 Constitution, consistent with
their civic and constitutional duties as citizens, public servants, members of the bar,
and Members of the House of Representatives as agents of the People, the various
sectors of the nation and other people’s organizations.

Respondent Rodrigo Roa Duterte is the incumbent President of the Philippines and
is being sued in his official capacity. He may be served with summons and other
processes at his office address at the Supreme Court Building, City of Manila.
 GENERAL ALLEGATIONS

When Respondent was then Mayor of Davao City, he was link with the alleged
Davao Death Squad that deals with a number of cases linking deaths in the city.
When respondent assumed office as President on June 30, 2016, he strongly
despises the use of drugs of Filipino people and he strongly believes that the
problem of the country that occurring is the effect of using drugs. He centered his
policy making ideology in combating drugs more importantly those distributing and
using of illegal drugs. In his strong policy against drugs a lot of Filipino people that
he swore to protect was jailed or killed by the Police by inducing the latter for
conducting such policy for money incentives, promotions and protection from the
law.

GROUNDS OF IMPEACHMENT

Respondent betrayed the Public Trust, committed Culpable Violation of the

Constitution and Graft and Corruption in the following manner:

ARTICLE I

RESPONDENT BETRAYED THE PUBLIC TRUST THOUGH HIS POLICIES IN

DEALING WITH THE DANGEROUS DRUGS AND PUTTING THE GENERAL PUBLIC
THROUGH A HIGH-RISK LOW-REWARD SCHEME OF “OPLAN TOKHANG”

ARTICLE II

RESPONDENT COMMITTED CULPABLE VIOLATION OF THE CONSTITUTION

AND/OR BETRAYED THE PUBLIC TRUST WHEN HE FAILED TO DISCLOSE TO
THE PUBLIC HIS STATEMENT OF ASSESTS, LIABILITIES AND NET WORTH AS
REQUIRED UNDER SEC. 17, ART. XI OF THE 1987 CONSTITUTION.

ARTICLE III

RESPONDENT BETREYED THE PUBLIC TRUST AND/OR COMMITTED GRAFT

AND CORRUPTION WHEN HE FAILED AND REFUSED TO ACCOUNT FOR THE
ELEVEN THOUSAND GHOST EMPLOYEES WHEN HE WAS STILL THE INCUMBER
MAYOR OF DAVAO CITY WHICH RESULTED FOR AN P708 MILLION OF PESOS
OF PUBLIC FUNDS MALVERSED
 ARTICLE IV

RESPONDENT COMMITTED CULPABLE VIOLATION OF CRIMES AGAINST

HUMAN RIGHTS WHEN HE WAS STILL THEN MAYOR OF DAVAO CITY IN
AUTHORIZING THE DAVAO DEATH SQUAD

DISCUSSION OF THE GROUNDS FOR IMPEACHMENT

1. Betrayal of public trust, bribery, culpable violation of the Constitution, and other
high crimes

• The complaint alleges that Duterte "willfully and culpably committed the High
Crimes of bribery, multiple murder and/or Other Crimes Against Humanity" by
adopting a state policy of inducing policemen, other law enforcement officers
and/or members of "vigilante groups" into extrajudicial killings of more than
8,000 persons merely suspected of being drug pushers or users.

• Duterte also exported and expanded the "dubious and gruesome work of his
infamous Davao Death Squad (DDS), which is reported to be responsible for
the murder and deaths of at least 1,424 individuals in Davao City from 1998
to 2015, to the entire country."

• Contrary to his oath of office and to the Constitution and prevailing laws,
Duterte publicly adopted a policy of "promoting, encouraging, as well as
aiding and abetting in the extrajudicial killing of persons suspected of being
drug pushers, drug users and/or committing other crimes..."

• In encouraging, aiding, and/or abetting the violation of laws, Duterte

"undermined the integrity of his office, has brought disrepute upon the
Presidency, has betrayed the trust reposed upon him as President of the
Republic, and has acted in a manner subversive of the rule of law and justice,
to the manifest injury of the people of the Republic of the Philippines," the
complaint said.

2. Betrayal of public trust, bribery, graft and corruption, culpable violation of the
Constitution, and other high crimes
 • With Duterte's patronage, backing and/or support as mayor, vice mayor or
congressman, and now as president, policemen and/or other law
enforcement officers and their "force multipliers, including rebel returnees"
were organized into an "anti-crime task force" which killed an estimated 1,400
persons. This group later evolved into the dreaded DDS, which is reportedly
responsible for the murder and deaths of at least 1,424 in Davao City as of
2015.

3. Graft and corruption and other high crimes

• The Commission on Audit had questioned the hiring of 11,000 contractual

workers in 2014 when Duterte was still Davao City mayor. This cost the city's
coffers P708 million.

• Passing the blame for the hiring of these contractuals to his alleged
predecessor, former mayor Benjamin de Guzman, is "clearly preposterous"
since it was his daughter Sara who actually served as mayor before him, and
he (Duterte), before Sara.

• Considering the P708 million, Duterte is being charged with malversation of

public funds, violation of the Anti-Graft and Corrupt Practices Act, and
plunder.

4. Unexplained wealth

Documents given to Senator Antonio Trillanes IV showed that P2.207 billion, more
or less, flowed into the bank accounts of Duterte from 2006 to 2015.

Besides Duterte's bank accounts, the accounts of Sara Duterte-Carpio, incumbent

mayor of Davao City, Paolo Duterte, incumbent vice mayor, and Sebastian Duterte,
were beneficiaries. All in all, money amounting to over P360 million flowed into the
accounts of the Duterte children, broken down as follows:

• Sara Duterte-Carpio – P121 million, more or less

• Paolo Duterte – P104 million, more or less
• Sebastian Duterte – P143 million, more or less

Common-law wife Cielito "Honeylet" Avanceña recorded transactions amounting to

nearly P187 million from July 2004 to March 2016.
Samuel Uy, Duterte's campaign contributor and alleged business partner,
"deposited and/or transferred to the bank accounts" of Duterte's children and/or
common-law wife amounts totaling about P118 million from October 25, 2011 to
April 10, 2013.

These were never reported in his Statement of Assets, Liabilities, and Net Worth
(SALN), where Duterte claimed to have a net worth of P24.08 million only in his
latest 2016 SALN. The complaint mentioned a net worth of "around 23.5 million".

Trillanes also uncovered at least 40 properties, including houses, condominiums,

and lots in the names of his children, plus another 10 known to be publicly owned by
him and/or his children.

These are separate from the 12 other properties reported in the SALN filed for the
year ending December 2014. Four of these properties are in the name of daughter
Veronica who was a minor aged 10 at the time.

5. Predicate crimes for plunder

Funds derived from the 11,000 contractual employees amounting to P708 million in
2014 alone have apparently been transacted and/or laundered through the bank
accounts of the Dutertes.

Given the "unlawful activities" or "predicate crimes" provided in the Anti-Money

Laundering Act of 2001, "there is clearly a basis for the House of Representatives to
direct/order the Anti-Money Laundering Council (AMLC) to submit and/or open
subject bank accounts and properties" of Duterte and/or his children.

RESOLUTION and PRAYER

WHEREFORE, pursuant to the procedure laid down by Section 3, Article XI of the

1987 Constitution on Accountability of Public Officers, the undersigned
Complainants, as Members of the House of Representatives, constituting at least
one-third of all the members thereof, hereby file the instant Verified
Complaint/Resolution of Impeachment against Respondent President Rodrigo Roa
Duterte. Accordingly, it is most respectfully prayed that in accordance with Rule IV
of the Rules of Procedure in Impeachment Proceedings promulgated by the House
of Representatives, to transmit to the Senate of the Philippines the instant Verified
Complaint/Resolution of Impeachment to serve as the Articles of Impeachment for
trial.
Thereafter, undersigned Complainants respectfully pray that the Honorable
Members of the Senate conduct trial forthwith and thereafter, render a judgment of
conviction against Respondent President Rodrigo Roa Duterte. Other reliefs, just
and equitable, are likewise prayed for.

Quezon City, Metro Manila, February 18, 2020.