Iv Republic of the City of Manila Philippines) .) SS J O INT C O MPLi.IiN,I-AFFIDAVI /- Wtr, RU,,lL G. MOLINA and T','RCNB D. SINGGO, bof of legal ag;e, Filipinos, and -'esidents of Kumalarang, Zamboanga de1 Sur and Pagacliart City, respectively, after being duly sworn to in accordance rvith la\",', hereby depose and say: That- THE PRIVATtr COMPLAINANTS 1. I, i?uei G. Molina, used to work in the Provincial Covertrrneril. of Zarnboanga rle1 Sur. I was first appointed ers Dxecutive Assistiiiti. ii bi' then Governor Aurora tr. Cerjiles on July 2, 2OAl wherr she serrrcri ittr' llrst term of ollice as Pro.zincial Govr:rnor. tr rvas assig:rcd i;:i tlr: ijillc':: ci' the Provincial Governor. Thereaftcr, on Ffebruati' 1, 200'1, slte ilr:s;i,nairlr.i nle as her Chief oi Stafi. Frior: io my einploymcnt in tf e i)i r','it.it:j'.rl Government, I was a meml--er of the para-lega1 staff of Artrora C,erilles in 1999 when sire was then the Representr.Ltive of the )rtd iJislr"ici. 01' Zam'rsoanga clcl Sur. Ii[52 salaries a.s a Secretary ii, functi<-ritin3-, ,1s pl]1-ii- 1ega1 staff of Rep. hurora Ceri1les, however, were drawn fi'oi'ri thi: Depar+.ment of Environment ancl Naturai R.e sources iDDlif':) ''uht'.1') incumhent Provincia] Governol: Antr-:lio H. Cr:riiies was then thc llt:crr'l.ar'',' of the DtrNR. Subsequently, i was r.rppointecl by Aurora Ccl'ilies, -"'.l1r{,' ",v;ls then the Representative of the ),tct [)istrict, as her Legisiativi: Stai'i Assistant Iil on December 1, 1999. I resigned fror:r my last pcsiticn ii: i.Lt: Provincial Gor rnment on Januaiy l, 2AA9; 2. i, '.iyrone D. Singgo, was first employed'in t'he Provjtrciai Government of Zanr,boanga dci Sur on July 2,2AO 1 as Executirre rtssistarrt . , of thc Provinciai Governor. I worked" under ituel G. Molina, the Chie{ rf i 1 Staff of then Governor Aurora Cerilles. On January 1,2AAg,l reltl:rcc,ll-.\ i him as Chief of Staff. I resigneci on June 30, 2010 but stiil serve ihern iLi \''i an unofficial capacity until December 2011, I completely terminatcil in\r i' services and cut-off any contact u,'i[h the cortple in January 2A12 v,,'hert 'J',. /i co-worker Mustapha P. Piang was a.mbushed; i]- il 3. We may bc served r,vith iegai processes, orCers atrd irotic{rs .11 \i the following addresses: Ruel G. Molina Poblacion, Kumaiaran€{ Zambcanga del Sur Page 1 of 18 J oint Com p taint-Aff idavit Ruel G. Molina llt Tyrone D. Singgo l i I ,tl ,, ^., rl',' i,i' ill I -'. '-ii," l! i" --.i".; .|.i; 1y .-1\ \t ,1 \i :\.
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Iv
Republic of theCity of Manila
Philippines).) SS
J O INT C O MPLi.IiN,I-AFFIDAVI
/-Wtr, RU,,lL G. MOLINA and T','RCNB D. SINGGO, bof of legal ag;e,
Filipinos, and -'esidents of Kumalarang, Zamboanga de1 Sur and Pagacliart
City, respectively, after being duly sworn to in accordance rvith la\",',
hereby depose and say: That-
THE PRIVATtr COMPLAINANTS
1. I, i?uei G. Molina, used to work in the Provincial Covertrrneril. of
Zarnboanga rle1 Sur. I was first appointed ers Dxecutive Assistiiiti. ii bi'
then Governor Aurora tr. Cerjiles on July 2, 2OAl wherr she serrrcri ittr'llrst term of ollice as Pro.zincial Govr:rnor. tr rvas assig:rcd i;:i tlr: ijillc':: ci'
the Provincial Governor. Thereaftcr, on Ffebruati' 1, 200'1, slte ilr:s;i,nairlr.i
nle as her Chief oi Stafi. Frior: io my einploymcnt in tf e i)i r','it.it:j'.rl
Government, I was a meml--er of the para-lega1 staff of Artrora C,erilles in
1999 when sire was then the Representr.Ltive of the )rtd iJislr"ici. 01'
Zam'rsoanga clcl Sur. Ii[52 salaries a.s a Secretary ii, functi<-ritin3-, ,1s pl]1-ii-
1ega1 staff of Rep. hurora Ceri1les, however, were drawn fi'oi'ri thi:
Depar+.ment of Environment ancl Naturai R.e sources iDDlif':) ''uht'.1')
incumhent Provincia] Governol: Antr-:lio H. Cr:riiies was then thc llt:crr'l.ar'','
of the DtrNR. Subsequently, i was r.rppointecl by Aurora Ccl'ilies, -"'.l1r{,' ",v;ls
then the Representative of the ),tct [)istrict, as her Legisiativi: Stai'iAssistant Iil on December 1, 1999. I resigned fror:r my last pcsiticn ii: i.Lt:
Provincial Gor rnment on Januaiy l, 2AA9;
2. i, '.iyrone D. Singgo, was first employed'in t'he ProvjtrciaiGovernment of Zanr,boanga dci Sur on July 2,2AO 1 as Executirre rtssistarrt . ,of thc Provinciai Governor. I worked" under ituel G. Molina, the Chie{ rf i
1
Staff of then Governor Aurora Cerilles. On January 1,2AAg,l reltl:rcc,ll-.\ i
him as Chief of Staff. I resigneci on June 30, 2010 but stiil serve ihern iLi \''i
an unofficial capacity until December 2011, I completely terminatcil in\r i'services and cut-off any contact u,'i[h the cortple in January 2A12 v,,'hert 'J',. /i
co-worker Mustapha P. Piang was a.mbushed; i]-il
3. We may bc served r,vith iegai processes, orCers atrd irotic{rs .11 \i
the following addresses:
Ruel G. MolinaPoblacion, Kumaiaran€{Zambcanga del Sur
Page 1 of 18
J oint Com p taint-Aff idavitRuel G. Molina llt Tyrone D. Singgo
liI
,tl ,, ^.,
rl','i,i'illI -'.
'-ii,"l!i"
--.i".;.|.i;
1y
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Tyrone D. SinggoPurok Manga, Sto. Nino DistrictPagadian City
THE RESPONDEN'IS
4. Antonio H. Cerilles is the incumbent Provinciaj. Governor of
Zamboanga del Sur. He used to be the Secretary of the Department of
Environment and Natural Resouces (DtrNR) and Representative of the 2^d
District of Zarnboanga del Sur;
5" Aurora tr. Cerilles was the Provincia-l Governor of Zamboanga
dei Sur during thB period 2001 to 2t,110, and is now the Representative of
the province's 2,a District. The Ceriiles couple exchange positions after
serving the maximum three terms of office;
6. For purposes of service of legal processes, "Antonio H. Cerilles
and Aurora E. Cerilles may be served with legal processes, orders andnotices, at their officia-l resid.ence in Sumadat, Dumalinao, Zarnbaanga del
Sur, however, they actually reside at Canuto Enerio Street, Sto. Nino,
Pagadian City;
ANTtrCtrDENT FACTS
7. Both of us were trusted staff and confidants of spouses AntonioH. Cerilles and Aurora E. Cerilles (hereinafter referred to as "Ceri11es
couple") both of whom have held and are still holding powerful positions inthe provincial and national governlnents;
8. As trusted staff and confidants, we were directed to performvarious tasks for the Cerilles couple, including personal ci1es, and oftenworked beyond regular working hou,'s and days. We wqre even required toreport to their residence in Pagadiarr City, and were on their beck and call2417. Sensitive and confidential matters were discussed with us by theCerilles couple ranging from the pol itical, business to personal ones, andwhen circumsrances warranted, we were the few ones assigned personallyby the Cerilles coupie to act decisively on any of these matters. We werethen perceived by the public as authoritative and powerful staff of theCerilles coupie. Our ascendancy extended over the rank and file in theProvincial Government as well as in their household workforce;
9 - But we have reached the point in our lives that we could nolonger, in conscience, foilow the orders of the Cerilles couple. We couldnot allow ourselves to be forever used as instruments and implementers oftheir corrupt and criminal acts, not to mention their penchani to inflictphysical harm upon their politlcal and personal enemies even to the pointof committing murder;
Page 2 of 18
Joint Conrplai nt-A,ff idavitRuel G. Molina & Tyrone D. Singgo
1r i ./.,
Itti \t\i \)wrIr !ilt I4l i_vl I*11
I1t iilIit /tt\i
10. In tlie latter part of 2011, we received information that out'
names were ii :luded in a "hit list" of the Provincia-l Special Operations
Group (PSOG), notorious for the extr4judicial kiliings of political and
personal enemies of the Cerilles couple. The PSOG, with headquartersinside the provincial capitoi complex, is headed by Board Member ErnestoMond.arte, a rabidly loyal Cer:illes foilower. The first four names in the
1 1. At first, we entertained doubts on the veracity of the "hit 1ist"
and considered it as empty threats and a psy-war tactic to pievent or
hinder us in our daily routine. But subsequent events made us reaiize
that the information on the threats to our lives is reliable, serious a.nd
bound to happen:
a) On November 18, 2O11, Raul Ganub, third man in the "hit list",was gunned down in Barintawak, Pagadian City rnhiie cirivinghis public utility val. The gunman was one of his passeilgers
and a member of the PiiOG. I-Iis assailant has never br:en
arrested;
b) On January 28, 2OL2, a close friend of ours, Mustapha P.
Piang, a former community organizer of the Cerilies couple andthe fourth man in the "hit list", was ambushed along Dao roadin Pagadian City. Fortunately, he suruived the attempt againsthis life. He was able to identify his assailants as members oithe PSOG. Piang was advised by tris family and relatir,'es not topursue any 1ega1 action against the perpetrators since theybelieved that it would only be an exercise in futiiity, given iheimmense power and influence of the Cerilles couple, as whathappened to the Ganub kiliing;
c) Surveiliance teams riding in tandem'on motorcycles, withcutplate numbers, are often seen near our iesidences, askingpeopie nearby for our whereabouts. We have also observed thatwe are also being foiiou,ed or tailed by these teams. Initierliy,the surveiliance teams wet e members of the PSOG but are norvaugmented by other armed groups riding in four-wheel vehicles
' without license plates;
12. We consider the foregcing events and circumstances asprecursors of ;erious attempts against our 1ives. We strongiy believe, asformer truste.: staff and conficlan',s of the Cerilles couple, that oul:knowledge of the corrupt and criminal acts of the Cerilles couple during
Page 3 of L8
Joint Complaint-AffidavitRuel G. Molina & Tyrone D. Singgo
\I
lII
j
I
'$-
our employment under them is connected to these events ano
circumstances;
13. Thus, before the Cerille:s couple succeed in permanently
silencing us, \,,: have decid.ed to expose their corrupt and criminal acts
against the people of Zamboanga dei Sur and Pagadian City whom thev
have sworn to serve;
CORRUFTI & CRIMINAL PRACTICES
. 14. As trusted staff and confidants of the Cerilles coupie, we wert3
active participants and first hand witnesses to the highly anomaious,irregular, corrupt and criminal practices of the couple in the provinciai
government. Due to their overwhelming dominance over us and theirsubtle empioyment of pressure and threats on usi we could not Co
otherwise but follow all their orders and instructions to the letter;
Prouincial Funds and Equipntent Spent
And Used For Priuate Pu'rPoses
15. Ail through-out the three consecutive terms (2001-2010) ofthen Governor and now Representalive Aurora Cerilles, provinciai fundswere freely spent and heavy equipmrrnt of the provincial governrnent vo'ere
used for the construction or renovation of buildings and establishmentsowned by the ferilles couple. Office supplies and equipment, as weii as
grocery supplies and kitchen utensils, for their personai and householduse were also paici by the Provincia-l Government;
Modus Operandi
16. Both Governor Antonio Cerilles and then Governor AuroraCerilles personally gave specific instruction to us to withdraw the needed
construction materials, office supplies and equipment, and grocery
supplies, on a "va1e" arrangement, from favored sirppliers, namely; GoldenDaughter Enterprises, AJ Enterprises, Lucky Savers and Crishamie. The,
same instruction was given to us for the needed. hear,y anc-l lighr:\ \a\
equipment from the Provincial Engineer's OlTice. The suppliers and the \Provincial trngineer had earlier been instructed by the Cerilles couple toact favorably and promptiy to all our requests;
17.' When construction materrials or office supplies were needed, abill of materials was given to us by the construction foreman. We thenissued a ovale" slip for the needeil materials to be presented to thesupplier. A government truck was used to haul the materials from thestore to the intended private es,.ablishment of the Cerilles couple^
Page 4 of 18
J oint Cornplaint-AffidavitRuel G. Molina & Tyrone D. Singgo
Thereafter, the documents to supi:ort the payment of the withdraw-n
materials were prepared, such as Purchase Request for a "ghost" deiivery
or fictitious project, Abstract of Canvas, Purchase Order, Receiving ar-rd
Inspection Report, etc. A11 the supporting documents of the disbursement
vouchers werc falsified. Upon pal'ment of the materials, the Cerilles
couple still demanded for a 3Oo/" kickback from the supplier. It was for
this reason that the prices of the materials were jacked-up b5r the
suppliers to which the Cerilles couple allowed;
18. When heavy or light equipment Was required in the project
privately owned by the Ceriiles couple, we asked the provincial engineer to
assign the needed heavy or light equipment to the project site. The heavy
or:light equipment 'uvas utilized without payment of any rental. The fuel of
the equipment was paid by the Provincial Government using faisified
documents;
19. When we need cash for some urgent malter or activity, the
Cerilles coupie woulci instruct us to get the amount from any of the
favored. suppliers. The supplier was paid, with interest, by again falsifyingthe procurement papers of a "ghost" delivery or fictitious project;
Specific Aclis
20. Among the materialsEnterpri.ses and delivered to theresidence of the Cerilles couplewere the folior' ;ng:
we withd.rew from the Golden Daughierprivate and business establishments andand paid by the Provincial Govel'nirrent
Hotel Alinduhaw, Paqcldian Citlt
Following the specific instruction of the Cerilles coupie, we
withdrew from the Golden Daughter Elrterprises variorisconstruction materials for the renovation of Hotel Alindahavrwhich is owned by the couple. The hotei is located along Rizal / \
Avenue, Pagadian City. Most of these construction rnaterials i j
are cement, deformed bars, nails, floor tiies and G.I. sheets.- -\ ial-c cellrellL, LICIUIIIICL_L Uii] S, lliC_lts, ll(J(Jt .L1ICS d-ILLl \-r.1. $rt\-LLr.;-\\ I
Below afe some of the said materials withdrawn frorn the\ \l.IIt]IUW tll C liUIIlC Ul LI-[t, Ui:LlLl I-tli:tLCIlalls \ryllll\.rrawrr 11 urar Lrru\
,t,t . \Golden Daughter trnterprises and delivered. to the Hotei \ ll l'-.\11 i \Alindahaw in 2006: \ti \
\1A-*,'-+ -_-l D^^^1.^/ h'- I UTrust Receipt
No.
Date Descriplion Amount Received by:
BOOO 2l24l06 Deformedbars, cement& paint
P 81,200.00 A11an Jamili
Page 5 of 18
J oint Complaint-Affidavit'Ruel G. Molina & Tyrone D. Singgo
a)
7995 3l3l06 Steel bars &cement
130,300.00 Alian Jamiii
2514 3l24l06 G.I. sheets,cement, steel
bars, nails
107,578.50 Vanessa villarra i
I
ll
I
2515 s l24l06 Cement, steelbar, ho1lowblocks, etc
62,205.OO Vaness Villarta
25L6 3l24l06 Flloor tiles &cement
29,290.O0 Vanessa Viliarta
8672 4losl06 Cement, etc 90,100.00 Allan Jamll
7984 2 l28l06 Cement 290,000.00
c
Allan Jamll
2513 3l23l06 Cement, steelbars, hollowblocks, etc
66,673.O0 Vanessa Villarta
3015 6l07l06 Steel bars,cement,pl1.wood,
nails, etc.
87,467.OO Nelson lrscarlo
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l.l r
<7 IL/t l.,4\l I
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2999 6l13l06 Cement 58,000.00 1 Vancssa vrlla-rta
16663 6173/06 Cement,deformedbars
75,000.00 Nelson Hsca11o ,-ffi itt Ill tlliltllt/t,i
77325 BIL l06 Cement 87,000.00 A1lan Jamrlr
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3642 8l3tl06 Deformedbars, cernent
77,800.00 Arlan Jamili
16660 eltrl06 Cement,deformedbars, G.I.sheets, etc.
131,160.00 Nelson Escario
copies of the afore-stated "Trust Receipts' covering tire
materials withdrawn and deiivered are attached' hereto and
mad.e an integral part hereof as Annex "A" to."N";
b) The ceriiles couple even ciirected. us to Pa], the amount of
P2,000.00 for the telephone connection of the Hotei Alirrdahar'r,'.
Page 6 of 18
Joint ComPlaint-AffidavitRuel G. Molina & TYrone D. Singgo
We got the amount frorn the Goiden Daughter Enterprises as
instructed, payable with ir:terest in the amount of P3,600.00,
as shown in the attached Trust Receipt No. 3897 {Annex "o")
and made an integral part hereof. The amount'l'as received by
Allan Molde as indicated ii:, the trust receipt;
Philippir;:,. Parq-Medtcal and Technical scttool /PPTS)
c) Upo,r instruction to us by the Cerilles couple, various office
supplies and equipment and plastic chairs were withdrawn on
different dates in 2OOT from the Golden Daughter Enterprises
and deiivered to the Philippine Para-Medical and Technical
School (PPTS). We know for a fact that PPTS is a school actually
owned by the cerilles couple. It is located in their privately
owned land known as Enerio cornpound, Sto. Nino, Pagadian
city (The middle name of then Governor "A,r.ot, cerilles is"Enerio"). The foilowing are some of the materials withdrawn
from the Golden Daughter Enterprises and delivered to PPTS:
Page / of 18
Joint Cornplaint-AffidavitRuel G. Molina & Tyrone D. Singgo
Trust ReceiptNo.
Date Description Amount Received by:
3756 sl28l07 Floor wax P 840.00 William Macapobre
4293 6/te /07 Carbonpaper &othersupplies
18,082.00 Leah Del Singgo
4751 7 ll la7 Lunchpacks,spoon & fork
16,600.00 William Macapobre
18535 712107 White board& extensionwire
1,380.00 Leah Del Singgo
4784 7 /5147 Ballpen &RER forms
895.00 Leah Dei Singgo
18534 7l2l07 Airfreshener,coffeeothersupplies
L0,767.50 Leah Del Singgo
4799 7 le /47 Stand fan,computerinks, &other r:ffi.ce
Joint Compi.rint-AffidavitRuel G. Molina & Tyrone D. Singgo
6069 fil30la7 Piasticchairs w Idesk an:r
69,860.00
5111 L2lsloT Steel ca.binet 14,200.00 Marilyn Catalino
5139 72l70l07 Alcohol &other officesupplies
3,558.00 Junie Singgo
Copies of the afore-stated. 'Trt.rst Receipts' covering the
materials withdrawn ancl d.elivered' are attached hereto and
mad.e al integral part hereof as Annex "FD to "JJ";
Fi.shpond located in Htogo, Zamboanga ciel Sur
d) Upon specific instructions of the Ceriiies couple to us, variot-is
construction materials, such as cement, plyrvood, G.1. sheels
and nails, were withdrawn fi'om the Golden Daug[terEnterprises on September 24, ?.OO7 and delivererl io t"heir'
privately owned fishpon'-r located in Barangay Balongbaiong, .,
Pitogo, Zamboanga del :jur. These materiais were usecl to ,i ^cor:,struct their resthousc, fishpond. gates, and hatche:-y in tirc iV \said fishpond. The deljvery is c.overed by Trust Receipt No- ]F4054 dated SepternLrer 24, 2OO7 in the total amount of #P127,583.00, a copy of which is attached hereto as Al1ncx "KL'' S i
anrl mad.e an integral part hereof. Due to the unavailabilit-v of a '-t' !
government truck, a private truck was hired and the cleliven' il i
charge of P 6,000.00, as indicated in the.trust receipt, 'i'as \ ,,,'
advanced. by Golden Daughter Enterprises which charged the \'/
Provincial Government the amount of P9,800.00, or a whoppirf / 1it63'/0 interest!; I I
it:L\ il \
cerittes Residence. paaadian citu \ i I ['.1\il I \
e) As ordered by the Cerilles couple, we withdrew from the Go1de" til_/Daughter trnterprises certain items and delivered the same to \l
. their residence in Pagadian City. Some of these items are the
following:
Pag't 9 of 18
Joi nt ComL laint-AffidavitRuel G. Molina & TYrone D. Singgo
Trust ReceiptNo.
Date Descript.ion Amount Received by:
18594 sle /07 Rice, redwine
P 72,300.O0 House helper I
I
i
I
3803 lLli2l07 Powerwasher
12,600.00 Driver- GerardoAranas
3939 t7l7sl07 Videoke set,waterdispenser
90,807.00 A1lan Jamili
38 15 11l2Bl07 Kitchenutensils
93,500.O0* Imeida Verdida
*Similar to t?rc Deliuery Charge mentioned in paragraph "d" (lboue, GoldettDaugL*er Enterprises aduanced- the amourrt of P 55,O0O.OO (actual cost ofthe items) to the kitchen utensil supplier. The Prouincial Gouernmer* tlrcnpaid Golden Daughter Ertterpises P 93,5OO.00, tthich includeai th.e "castof moneg", againfor a uthopping 7O9o interesi!
Copies of the afore-stated "Trust Receipts" covering thematerials withdrawn and delivered are attached hereto al-id
made an integral part hereof as Annex "LL" to "OO';
Even the grocery, including personal hygiene itenrs, ol liirCerilles household were paid by the Provinciai Go'.'erninent- A"
lavored supplier would be asked to deliver the groccry irems Lc
the Cerilies resjdence in Pagadian City. A clisbursementvoucher, together with the supporting documents of a ghost
d"elivery, was then prepared to pay lhe delivered grocery itr:ins;
Cerilles Warehause. Labangan, Zamboanaa d-el Sur
Again, per standing ins;iruction of the Cerilles couple, we I
withdrew from the Goiden Daughter Enterprises varicus a-[har4ware materials-^";;';;;.r;J ;;. ;; i" ;;t;;r*""'.qcorflpound in Laban gan, Zamboanga dei Sur. These materiais'\were used for the renovation of the warehouse which theyearlier purchased, Below are some of the materials delivered:
Page 10 of 18
J oint Complaint-AffidavitRuel G. Molina & Tyrone D. Singgo
Copies of the afore-st2ted. "Trust Receipts' covering the
materials withdrawn and d"elivered are attached heret-o and
mad.e an integral part heri:of as Annex "PP' to "TT';
Campaign materials inthe 2OO7 Elections
h) Even the personal campaign materials and oftice suppiies of the
party headquarters of the cerilles couple were paid by the.Provincial Government. These materials include tarpaulin,lStreamers, Sweat shirts, pack lunch containers, Computer inks, \
eners/ drinks, coffee, minerai wa.ter, etc. The following are
some of the materials taken from the Golden DaughterEnterprises and used in the 2OO7 campaign:
Page i1 of 18
Joint Complaint-AffidavitRuel G. Molina l3t Tyrone D. Singgo
ll^,it\gi,41 I
trii/V
tl-U)o:r
\/ I )-..\l / 't\,/U
Trust ReceiptNo.
Date Description Amount Receiveri by:
18286 4-le l07 Tarpuline,streamers,computer
P 212,905.00 A1lan Jamili
inks, s'weatshirths
1B238 4l2L/07 Bond paper,cartolina.
59,880.00
t7874 4l2sl07 Long sleevesshirts
28,000.00I
I
17886 4l2sl07 Streamers,mineralwater
39,300.00
t7897 4l27l07 Ballpens,pencil,envelopes,etc
98,634.00
17806 4l30/07 Sweatshirts, packlunchcontainers,spoons andforks, etc.
L54,240.O@
178OB 4l31l07 Sweatshirts, etc.
359,133.00
4207 sl4l07 Energrdrinks,minera-lwater
24,484.O0 Imelda Verdida
18607 s /4 /o7 Computerinks, styrocups, etc.
36,522.OO William Macapobre
I
3900 10l23l07 Coffee 44,842.85
,,1
I
i'!i
Copies of the afore.stated "Trust Receipts' covering thematerials withdrawn and delivered are attached her,eto: andrmade an integral part hereof as Annex "UU' to '{DDD'; r' i :
i'
)NTDOCTJMENTS. I,
27. We were tasked by the Cerilies couple to cause the pr"eparationof the necessary documents to justify the payments o_fl the mattriaiswithdrawn from the Golden Daughler trnterprises, and destroy or br.Lrn
Page i2 of 18
J oint Compl,rint-Aff idavitRuel G. Molina & Tyrone D. Singgo
the corresponding deiivery/trust receipts once the materials were paiC bythe Provincial Government. In compliance with their order, we conferredwith the Provincial Budget Officer, Roger Montealto for the payment of thedelivered materials. We ca11ed him the "Magician" for his task. He was theperson directed by the Ceriiles couple to prepare the necessary documentsfor the delivered materials. Thus, as stated earlier, fictitious projects were
fabricated to serve as bases for the d.ocuments, and that the fatsifiedd"ocuments (i.e. requisition, purchase order, canvas, disburseilentvoucher, check, etc.) were, most often, prepared simultaneously in c.rne
day. Per prior agreement with the Cerilles couple, the falsified"supportingl documents were prepared by the Gold"en DaughterEnterprises;
22. The materials delivered 1o the private residence anci personalbusiness establishments and buildir:gs of the Cerilles couple were chargedto certain on-going projects, mostly to the Amusement,and Events Center(AtrC) in the provincial capitol compound. Among our inner circie, we
called the AEC center the "graveyard of shit" where most "ghost" deliverieswere charged. Incidentaily, the initials of then Governor Aurora Cerilles is"AEC";
23. Upon payment of the materials, as directed by the Cerillescouple, we would ask from the Golden Daughter trnterprises the 3A"/"
"SOP" or kickback based on the amount o[ the check. We personallyreceived fi:om the supplier's representative the "SOP" which was usualiyplaced inside a sealed envelope and gave the same to either of the Ceriliescouple but most of the time to Governor Aurora Cerilles;
24. In view of the limited funds of the Provincial Government, theaccount of the Golden Daughter trnterprises and a few other favouredsuppliers was always prioritized for payment per instruction of the Cerillescouple. Governor Aurora Cerilles decides which supplier to be paid andfor how much. Attached, as Annex "EEE', "FFF'.and "GGG", are some ofthe lists given by Governor Aurora Cr:rilles to the Provincial Treasurer;
i
25. As earlier stated, after the materials indicated in the "T;:ustReceipt" were paid, these receipts were destroyed or burned as ordered bythe Cerilles couple. Fortunateiy, we overlooked to destroy a few of thesetrust receipts which are now being used as documentary evidence of thecouple's corrupt and criminal practices. We are, however, searching forother documents for future filing of other criminal complaints;
Page 13 of L8
J oint Complaint-AffidavitRuel G. Molina & Tyrone D. Singgo
26. We were present when tiie Cerilles couple told Jacqueline C"
Delos Reyes, the proprietor of the Golden Daughter Enterprises, abouttheir desire to withdraw materials from her store on a "vale" arrangementand that we were authorized to withdraw the materials, a:ld that theProvincial Go,r'ernment would pay for the materials. She requested,though, that the prices be "adjusted" or jacked-up to compensate for thecost of money considering that the processing of the payment in thecapitol takes a iong period of time;
ILLEGAL "SUE?RES' NUMBERS GAME
l; Tyrone D. Singgo, was prrvy to the operation of the illegai "SUETRtrS"numbers game, and further state: THAT-
27. Sometime in the middle part of 2009, then Governor AuroraCerilles asked me to approach the operator of the "SUETRtrS" numbersgarne and to negotiate and demand "protection mone/ and monthlypayola for the Cerilles couple. I declined citing my heary rvorkload as herChief of Staff. Another trusted staff, Imelda "Neneng" Verdida and Riclq,Libre were instead given the task. The negotiation with the .SUtrTRtrS'
operator resulted in having the said operator hand to the Cerilles couplethe amount of P10.0M and monthl-1r payola of P3.0M. However, in lessthan a month, the Cerilles couple had the "SUETRES" operator raideC forfailing to give them a larger share o1'the operations which they ciemandedafter receiving the aforementioned amount of P10.0M;
28. The Cerilles couple asked a certain Liza Aranding, theproprietor of another favored supplier "Lucky Savers" to operate the"SUETRES" game on a 50%o-50ozt profit-sharing basis with them.Aranding and Libre went around the province conveying the instruction cfthe Cerilles couple to all the municipal mayors, who are affiliated with theNationalist People's Coalition (NPC), to allow the operation of "SUtrTRtrS"in their respective municipalities;
29. However, due to the ineptness of Lrza Aranding in operating the"SUETRES" which resulted in low profits, the Cerilles, couple persoirallytook over the operations in the last week of July 2010. Under the directg"^.- _.. ---\control of the Cerilles couple, the operations were being managed by \
provinciai government-paid employees Allan Abuyog and Ruel Quirabo.Abuyog is an ExecutiVe Assistant of Governor Antonio Cerilles and over-a,liin charge of the provincial livelihood prograrn, while Quirabo is alivelihood'coordinator assigned in Sta. Lucia District, Pagadian City;
30. All the municipal liveiihood coordinators of the ProvincialGovernment were made as "SUETRtrS' coordinators in their respectiveareas. Remittances of collections \,r'rrre actually made in the residence of
Page 14 of 18
Joint Com pla int-Aff idavitRuel G. Molina & Tyrone D. Singgo
iuntf I-Rttfl.#l*#llt itttit
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the cerilles couple in Pagadian city, particularly in the basement of their
house;
31. However in october 2011, then Governor Aurora cerilles took over
the operations of the "SUETRES" when she discovered that Governor Antonio
Cerilles had a 22-year old mistress who was a runner-up in the Miss
;;"-rb;";* del sur beauty pageant in 2008, and used the .5gETRES"
collections to buy a SUV vehicle (Montero) for his young mistress' She also
found out that Governor Antonio cerilles also used "SUETRES" collections to
pay her college tuition fees, monthly allowance of not less than P20'000'00 and
for the rent of her furnished apartment in Iligan city;
32. I personally witnessed the rage of then Governor Aurora cerilles
when she discovered her husband's dalliance with a former beauty contestant'
she was fuming mad. I have never seen her so very enraged before' on the
other hand., I have never seen Governor Antonio Cerilles so very tame and
paniclry before. uncharacteristically d.ocile, he obeyed whatever his wife
ordered. him to do. A complete opposite to his image as a feared political
warlord in the province. Shortly after the discovefY, the house of the 22-year
old girl in Guipots, zarnboanga d.el sur was strafed by unidentified gunmen'
FortunatelY, nobodY was injured;
33. When then Governor Aurora cerilles took over the 'SUETRES"
operations in october 2o11, with nary a whimper from her husband Antonio'
she assigned another person, a certain Cabarubias, to manage its day-to-day
operations up to the present time. The operations were transferred to a house
oi a political leader in Anonang, Dumalinao, Zag,'boanga del Sur;
g4. The Cerilles couple is using "SUETRES" collections to maintain a so-
called .,reward fund" for PSoG "hif' activities. A PSOG member or "asset" who
executed a "hit project" was given a reward money drawn from this "reward
fund";
CRIMINAL AND ADMINISTRATIVE CASES
35. We are exeicuting this Joint Affidavit-complaint for the purpose of
filing PLUNDER, MALVERSATION and FALSIFICATION cases' and
administrative cases against Governor Antonio H. cerilles and former Governor
Aurora E. Cerilles (now Representative, 2"d District of Zamboanga del Sur), and
all persons who in one way or another might havePconspired', confabulated and
confederated in the commission of the foregoing crimes and offenses and in
support of our application in the Witness Protection, Security and Benefit
Program, and for all other legal intents and purposes'