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COMPLAINT-AFF'IDAVIT
I, MANUEL P. MEJORADA, of legal age, Filipino, married, and a resident of 19-11 La Belle St., Pavi4 Iloilo, after having been sworn in accordance with law, do hereby depose
and state:
1.
cITy MAyoR
JED
a. b.
c.
d.
Perjury; and
Grave misconduct and such other offenses covered by Republic Act No. 3019
and Republic Act No. 6713;
Committed in connection with his Statements of Assets, Liabilities and Net Worth
(SALN) for the year 2010 in relation to the year 2007 and other years which are
Iloilo City
and assumed
a. b.
file, Statements of Assets, Liabilities and Net Worth (SALN) in compliance with Republic Act No. 6713 for the periods covered;
3. Respondent may be served
Honorable Office at his temporary office at the 3'd Floor, Robinsons Place, Ledesma
St.,
Iloilo City, or at the New Iloilo City Hall once the Iloilo City govenrment shall
have transferred to the new'edifice; 4. The criminal and adminishative offenses were committed by respondent as follows:
5. Respondent reported in his SALN for the y.ear ending December 31, 2010 the
following pertinent financial information with respect to his assets, liabilities and net
worth:
a. b.
Declarant's Annual Gross Income: P564,743.40; Annual Gross Family Income: P8,400,000.00
Real properties and vehicles: P43,346,600.30;
c.
d. e.
i.
P71,106,600.30;
f.
A print out of the digrtal copy of respondent's SALN for the year ending
December 31, 2010 furnished the undlrsigned by the SALN custodian in the
"{";
(B"), respondent Jed
In his SALN for the year ending Decembeq 31,2A07 @rinted copy from digital
image furnished by the OMB-V custodian is attached as Annex
Patick E. Mabilog, who was then City Vice Mayor of Iloils City, reported the
following pertinent information about his assets, liabilities and net worth:
a. b.
Total real properties: P44,91.0,376.00; Total personal and other properties (including vehicles): P22,256,224.00; Total liabilities: P22,7
12,1
c.
68.00;
forthe
a grant
--
leap
-- in his net worth by P26,652,168.30; a. This upsurge in net worth definitely falls under the definition of unexplained
wealth under Section 8 of Republic Act No. 3019, which is quoted hereunder: 'osection 8. Primafacie evidence oj*adismissal due to unexplainedwealth. If in accordance with the provisions of Republic Act Numbered One thousand three hundred seventy-nine, a public official has been found to have acquired during his incumbency, whether in his name or in the rurme of other persons, an amount of property and/or money manifestly out of proportion to his salary and to his other lawful income, that fact shall be a ground for dismissal or removal. Properties in the name of the spousie and unmarried children of such public official may be taken into consideration, when their acquisition through legitimate means cannot be satisfactorily shown. Bank deposits in the ftlme of or manifestly excessive expenditures incurred by the
r
I
public official, his spouse or any of their dependents including but not limited to activities in any club or association or any ostentatioui display of wealth including frequent travel abroad of a non-offrcial character by any public official when such activities entail expenses evidently out of proportion to legitimate income, shall likewise be taken into consideration in the enforcement of this section. The circumstances hereinabove mentioned shall constitute valid ground forthe adrniniptrative suspension ofthe public official concemed for an indefinite period until the investigation ofthe unexplained wealth is completed."
b.
manifesfly out of proportion to his salary as clty Mayor, and vice Mayor for
the years 2008 and 2009, and his other legitimate income;
i.
The annual gross family income he declared in his SALN for the year 2010 --- P8,400,000.00 --- is inadequate to push his wealth by
P26,652,169.30;
a)
The amorurt stated is Annual Gross Family Income, which would incorporate that of his wife who is working abroad as finance manager of a canadian geodetic company, and his businesses;
b)
Even if respondent was not assessed and paid income taxes, and scrimped on living expenses without spending a single centavo
of
a. b.
Neither could he keep himself and his family starving just for the sake of amassing wealth;
d) Granting that his living expenses in Iloilo and that of his wife who
is based in Canada would be P200,000.00 a month (considering
their status and lifestyle;, then that will reduce his total yeady
income by approximately P2,400,000.00;
e) With these conseryative estimates of deductions for taxes and
or less as being available for additional invesfonents and prpperty acquisitions; Assuming this to be the level of his net income for the'years 200g, 2009 and 2010, respondent could only acquire properties in the
PRoPoRTIoN to his salary and business income and that of his wife, and in the contemplation of Section 8, RA 3019, is pRIMA
FACIE EVIDENCE OF IINDGLAINED WEALTH.
DISIIONEbTY
In disclosing the required informafion about his assets, tiaUitities and net worth in
compliance with section 7 of RA 3019 and section I, RULE
vII
of
the
a.
a residential
i.
This inforrnation is false, because the same property had been previously reported in respondent's sALN for 2007,'and he clearly
indicated the acquisition cost to be p30,000,000.00;
ii.
it appear that his real properties and vehicles owned dwing the year
2010 was only P43,346,600.30;
b.
Respondent also listed a Lexus lunrry vehicle among his assets for the year 2010, but did not disclose the year it was purchased;
i.
2010;
ii.
Respondent declared the acquisition cost for the Lexus vehicle at P1,500,000.00;
iii.
The aforementioned amount for the acquisition cost of the Lexus car is grossly understated, because the price range of thib luxury vehicle is between P2,000,000.oo to p4,000,000.00, depending on the model;
iv. Again, the motive for this uirderstatement of the acquisition cost is to
hide the true magnitude of his fast-growing wealth;
vehicle and
1.
of P2,000,000.00;
ii.
d.
Lapaz,Iloilo city with an acquisition cost of p5,000,000.00, and placed the year it was purchased as the year 2000;
i.
This property was not disclosed in respondent,s SALN for the years 2A04 @copy is hereto attached as Annex *C-),Z0OS (a copy is
attached as Annex
"D"), 2006
ii.
iii.
It is unlikely that respondent had acquired the property inLapaz, Iloilo Clty in 2000 as indicated in his SALN for 2010;
Respondent must have provided a wrong date to make it appear it had
been in his SALNs for previous yeaxs and hide the fact that
it is one of
1.
iv. Even if indeed this piece ofiroperty had been in his name since 2000,
then respondent is liable for failure to disclose material information,
e.
Respondent did not disclose the value of his jewelrips and cash in bank for the year 2010 which, in his 2007,was reported to be p10,000,000.00;
i.
This failure to report/disclose his jewelries/cash in banh an item that consistently appeared in his previous years, sALirIs in the amount of
P3,300,000.00, is a deliberate act to hide the true worth of his wealth,
ii.
deflating, decreasing and hiding the tue net worth of respondent, which could represent another P20,000,000.00 that should have been added to his 2010 SALN for the portion on net worth;
b.
('
If the true values ofthe properties above-cited are taken into consideration,
respondent's net worth could reach p90,000,000.00, and the spike --- the sudden surge -- of his net worth is actually about p50,000,000.00 in just three years;
PERJURY
9.
The statements under the preceding heading "DISHoNESTY,, also form the factual and legal basis to hold respondent liable for PERIURY, as the SALNs were filed in accordance with law and were swom to before a competent administering
officer;
10' In addition to
UNEXPLAINED WEALTH, respondent is also liable for violating the mandate for simple living among public officials and avoid ostentatious display of
a.
In his various SALNs up until the latest filed for the year.20l0, respondent has acquired numerous vehicles --- hxury vehicles --- in close proximity to each other and by the latest count, had a total of seven (7) cars/SUVs, as
follows:
Make/IVIodel
Ford Everest
Year acouired
2004 2006
2AO7
Acquisition eost
P 1,400,000.00
700,000.00
2,246224.00
2AO7
2008
firirgt
c.
The Lexus, Dodge Durango, Toyota camry, Isuzu Altierra and Ford Everest
are upscale vehicles that evenjust one of them
car owner;
Having all four of them, and buying these vehicles at the rate of almost one every year since 20A7, is lavish spending, rightfully belonging under the
lifeslyle of the rich, and a sharp departtre from the Nonn of conduct for Public officials and Employees, particularly section 4, paragraph (h), of
Republic Act No. 6713 on"simple Living,,;
under Section 8, Republic Act No. 3019, mandates that ostentatious display of wealth "shall likewise be taken into consideration inthe enforcement of
this sectiod', and would by itse$ also constitute gftwe misconduc[
11. The circumstances by which respondent amassed so much wealth during his
incumbency as City Councilor, Vice Mayor and IVIayor of Iloilo Crty are mysterious
by any standmds;
12. Respondent's legitimate income in the form of salary as a public
of his wife and business, do not match with the pace by which his wealth grew; 13. Section 8, RA 3019 is clear on this poinf such circumstances are prima facie
evidence of unexplained wealth as he amassed assets manifesfly out ofproportion to his legitimate income;
14. The documentary evidence also prove the falsification, dishonesty and perjury;
15- Clearly, respondent hansgressed
RA 3019, RA 6713 and other relevant laws on falsification, dishonesty andperjury, and a criminal and administative investigation
I am executingthis complaint affidavit forthe pu{pose of attesting to the truthflrlness ofthe foregoing statements and file this criminal and administrative
complaint against the respondent;
17. Further,
affiant sayethnaught.
set my hand
this /O!1,
IVIANLJEL p.
k"F!h, trdldneoe
in Iloilo City,
Complainant-Affi\J
SLIBSCRIBED AI.ID SWORN to before me this
Philippines. I he,reby certify that I have personally .r,u-io"d the affiant and I atII fully satisfigdthat he vohmtarily executed and understood his complaint-affidavit.
@ fu(d,OoW
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