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Republic of the Philippines )City of Iloilo ) S.S.

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:

This is a criminal and administuative complaint against cITy MAyoR JED

PATRICK E. MABILOG of Iloilo Crty forthe following offenses:

a. Unexplained wealth under Section 8, Republic Act No. 3019;

b. Dishonesty;

c. Perjury; and

d. 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

curently on file withthis Honorable Office;

Respondent was elected to the position of City Mayor of Iloilo City and assumed

office on June 30,2010;

a. He was also the city vice Mayor of Iloilo city forthe years 2007-za1,3;

b. He was elected as Clty Councilor for the tern 2004-2007;

c. As a duly elegted public official d*i"g those years, he was required, and did

file, Statements of Assets, Liabilities and Net Worth (SALN) in compliance

with Republic Act No. 6713 for the periods covered;

Respondent may be served with subpoenas, suilrmonses and other orders of this

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;

The criminal and adminishative offenses were committed by respondent as follows:

1.

2.

3.

4.

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. Declarant's Annual Gross Income: P564,743.40;

b. Annual Gross Family Income: P8,400,000.00

c. Real properties and vehicles: P43,346,600.30;

d. Investnents, other personal properties and liabilities: P27,7 60,000.00;

i. No liabilities were reported in this SALN;

e. Based onthe above information, respondent'sNet Worth was valued at

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

Office of the Ombudsman-Visayas is attached as Annex "{";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 (B"), respondent Jed

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. Total real properties: P44,91.0,376.00;

b. Total personal and other properties (including vehicles): P22,256,224.00;

c. Total liabilities: P22,7 12,1 68.00;

d. NET WORTH: P44,454,432.30;

Comparing the information pertaining to respondent Mabilog's net worth forthe

years 2007 and 2010 as summarized above, there was a sharp increase -- 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 otherpersons, an amount of property and/or money manifestly out of proportion tohis salary and to his other lawful income, that fact shall be a ground fordismissal or removal. Properties in the name of the spousie and unmarriedchildren of such public official may be taken into consideration, when theiracquisition through legitimate means cannot be satisfactorily shown. Bankdeposits in the ftlme of or manifestly excessive expenditures incurred by the

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public official, his spouse or any of their dependents including but not limitedto activities in any club or association or any ostentatioui display of wealthincluding frequent travel abroad of a non-offrcial character by any publicofficial when such activities entail expenses evidently out of proportion tolegitimate income, shall likewise be taken into consideration in theenforcement of this section. The circumstances hereinabove mentioned shallconstitute valid ground forthe adrniniptrative suspension ofthe public officialconcemed for an indefinite period until the investigation ofthe unexplainedwealth is completed."

b. The skyrocket-fashion increase in respondent's net worth is definitely

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 ofhis gross annual {amily income forthree years, hp would have

raised only P25,200,000.00 to go on a buying spree of more

properties and acquire more wealth;

a. But that is not possible, as he would be prosecuted by the

Bureau of Intemal Revenue for tax evasion;

b. Neither could he keep himself and his family starving just

for the sake of amassing wealth;

c) If personal income tar<es are deducted from this gross family

income (assuming it to be 40 percent of the totar), then an amount

of P3,200,000.00, more or less, will be taken u*uy from his total

income;

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;

With these conseryative estimates of deductions for taxes and

living expenses, respondent will have only p2,800,000.00, more

d)

e)

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

vicinity of P9,000,000- 1 0,000,000;

Where did he get P16,000,000.00 on top of ttie available money

for investments?

Such increase in his net worrh is MANIFESTLY OUT OF

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 incompliance with section 7 of RA 3019 and section I, RULE vII of the .

Implementing Rules and Regulations (IRR) of RA |Tl3,respondent deliberately

made false entries about the acquisition costs of several pieces of property, bothreal

and personal, to deflate and hide the'true magnitude of his unexplained wealth:

a. ln his 2010 SALN, respondent tisted a residential property situated in Canada

and reported the amount of P14,500,000.00 as its'acquisition cost at the time

of its purchase n2007;

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. By changing the acquisitiontost to a lower amoun! respondent made

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. This Lexus luxury vehicle did not appear in respondent's2007 SALN,

hence, it was most likely purchased at some point.between 2008 and

2010;

ii. Respondent declared the acquisition cost for the Lexus vehicle at

P1,500,000.00;

e)

h)

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 tohide the true magnitude of his fast-growing wealth;

c. In the same 2010 SALN, respondent listed a Dodge Durango vehicle and

reported the amount of P600,000.00 as the acquisition cost;

i- Respondent, in gross contravention of the law, also did not indicate

the year it was acquired;

1. This'vehicle was not included in his 2007.SALN, hence, it can

be assumed it was purchased between 200g and 2010;

2- Respondent undetstated the acquisition cost ofthe vehicle,

because the market price of this vehicle/model is at minimum

of P2,000,000.00;

ii. Respondent obviously wanted to disguise the true value of his assets

in understating the real acquisition cost of the Dodge Durango;

d. Respondent reported in his 2010 SALN a residential property situated inLapaz,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 (a copy is attached as Annex *8,,) and

the year 2007;

ii. It is unlikely that respondent had acquired the property inLapaz,

Iloilo Clty in 2000 as indicated in his SALN for 2010;

iii. 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 ofhis recent acquisitions;

1. The above act constitutes dishonesty;

iv. Even if indeed this piece ofiroperty had been in his name since 2000,

then respondent is liable for failure to disclose material information,

which also constitutes dishonesty;

e. Respondent did not disclose the value of his jewelrips and cash in bank forthe 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 thatconsistently appeared in his previous years, sALirIs in the amount ofP3,300,000.00, is a deliberate act to hide the true worth of his wealth,

which has already shot up manifesfly out of proportion to his salary

and other legitimate income;

ii. This is yet another act of dishonesty;

The above-cited misdeclarations and understatements of values resulted indeflating, decreasing and hiding the tue net worth of respondent, whichcould represent another P20,000,000.00 that should have been added to his

2010 SALN for the portion on net worth;

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 justthree years;

PERJURY

9. The statements under the preceding heading "DISHoNESTY,, also form the factualand legal basis to hold respondent liable for PERIURY, as the SALNs were filed inaccordance with law and were swom to before a competent administering officer;

10' In addition to UNEXPLAINED WEALTH, respondent is also liable for violating themandate for simple living among public officials and avoid ostentatious display ofwealth under Section 4Paragaph (h) of R.A.6713;

a. In his various SALNs up until the latest filed for the year.20l0, respondent

has acquired numerous vehicles --- hxury vehicles --- in close proximity toeach other and by the latest count, had a total of seven (7) cars/SUVs, as

follows:

Make/IVIodel

-

Year acouired Acquisition eost

Ford Everest 2004 P 1,400,000.00

Toyota Innova 2006 700,000.00

Toyota Camry 2AO7 2,246224.00

('b.

Isuzu Altierra 2AO7 .1,300,000.00

Dodge flurango 2008 600,000.00

Lexus Not stated 1,500,000.00'

Toyota Revo Not stated 400,000.00

That, in any languagq is an ostentatious display of wealth and grandiose

firirgt

The Lexus, Dodge Durango, Toyota camry, Isuzu Altierra and Ford Everest

are upscale vehicles that evenjust one of them would give the owner status as

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 forPublic officials and Employees, particularly section 4, paragraph (h), ofRepublic Act No. 6713 on"simple Living,,;

under Section 8, Republic Act No. 3019, mandates that ostentatious displayof wealth "shall likewise be taken into consideration inthe enforcement ofthis sectiod', and would by itse$ also constitute gftwe misconduc[

11. The circumstances by which respondent amassed so much wealth during hisincumbency as City Councilor, Vice Mayor and IVIayor of Iloilo Crty are mysteriousby any standmds;

12. Respondent's legitimate income in the form of salary as a public official and incomeof 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 facieevidence of unexplained wealth as he amassed assets manifesfly out ofproportion tohis 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 investigationbythe Office ofthe Ombudsman is just andproper;

16- That 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.

c.

IN WITNESS HEREOF, I have hereunto set my hand this /O!1, day of February ,ZO1Z, atIloilo City, Philippines.

k"F!h,IVIANLJEL p. trdldneoeComplainant-Affi\J

SLIBSCRIBED AI.ID SWORN to before me this @ fu(d,OoW in Iloilo City,Philippines. I he,reby certify that I have personally .r,u-io"d the affiant and I atII fullysatisfigdthat he vohmtarily executed and understood his complaint-affidavit.

GnAFT INVESTEAT|0N AND PRo t