Ombudsman ordered CamNor dismissed Gov et al, to submit a Counter-Affidavit on Anti-graft and Administrative charges filed by VACC

Ombudsman ordered Tallado et al

CAMARINES NORTE, BICOL, PH (May 2, 2018) – The Office of the Ombudsman has ordered  Edgardo Tallado (Dismissed Governor), Pedro Jonah G. Pimentel (Vice Governor now Governor) , Sanggunian Panlalawigan members – Gerardo G. Quinones, Rodolfo V. Gache, Renee Herrera-Depante, Joseph Stanley G. Alegre, Artemio B. Serdon Jr., Muriel M. Pandi, Erwin L. Lausin, Reynoir V. Quibral, Joaquin “Jay” Emmanuel G. Pimentel, Ramon E. Baning and Provincial Planning and Development Coordinator (PPDC) Elena B. Austria to submit six (6) copies of their Counter-Affidavits and their witnesses in connection with the Affidavit-Complaint filed by Norberto B. Villamin of the Volunteers Against Crime and Corruption – Camarines Norte Chapter.

The Ombudsman said, the charges is now entitled OMB-L-C-18-0104 in violation of RA 3019 Section 3 (a) & (e) and OMB-L-A-18-0122 for  Gross Neglect of Duty and Serious Dishonesty, and now under preliminary investigation and administrative adjudication by the office of the Preliminary Investigation, Administrative Adjudication and Prosecution Bureau -C headed by Director Margie G. Fernandez-Calpatura.

The Ombudsman also  said that failure of the respondents to comply with the Order within the period of ten (10) days from receipt shall be deemed a waiver on their part to file or submit any Counter-Affidavit or  controverting evidence and the  case shall be considered submitted for resolution without further notice.

The Order dated  April 17, 2018 also  directed Edgardo Tallado, et al to submit their Comment on the motion/prayer/request for their preventive suspension as embodied in to the  complaint.

See attached copy of the Ombudsman Order:

OMB Order 2

The VACC complaint was emanated from the  railroaded processed of the proposed loan transaction of the Provincial Government of Camarines Norte, amounting to P60 million pesos with the Municipal Development Fund Office (MDFO) of the Department of Finance (DOF) for the proposed Construction of Wharf, River Control and Holding Area.

Read the Full Content of the Affidavit-Complaint filed by Norberto B. Villamin VACC Coordinator for  Camarines Norte:

 

CRIMINAL AND ADMINISTRATIVE COMPLAINT

I, NORBERTO B. VILLAMIN, Filipino, of legal age, with residence and postal address at Brgy. Malasugui, Labo, Camarines Norte, hereby accuses with the OFFICE OF THE OMBUDSMAN: EDGARDO A. TALLADO, incumbent Governor of Camarines Norte, PEDRO JONAH G. PIMENTEL, incumbent Vice Governor of Camarines Norte, and incumbent Board Members GERARDO G. QUINOŇES, RODOLFO V. GACHE, RENEE HERRERA-DEPANTE, JOSEPH STANLEY G. ALEGRE, ARTEMIO B. SERDON JR., MURIEL M. PANDI, ERWIN L. LAUSIN, REYNOIR V. QUIBRAL, Ex-Officio members JOAQUIN “Jay” EMMANUEL GPIMENTEL, PCL, and RAMON E. BANING, LNB, and ELENA B. AUSTRIA, Provincial Planning and Development Coordinator (PPDC) and Provincial Development Council Executive Committee Secretary, all of the Provincial Government of Camarines Norte, of legal ages, married, Filipinos, and with Office address at the Provincial Capitol Building, Daet, Camarines Norte, for Violations Of Section 3, Paragraphs (a) and (e) of RA 3019 (Anti-Graft and Corrupt Practices Act), GRAVE MISCONDUCT, SERIOUS DISHONESTY and GROSS NEGLECT OF DUTY committed as follows:

STATEMENT OF FACTS

  1. On November 10, 2017 respondent Governor Tallado wrote a letter to the Sangguniang Panlalawigan of Camarines Norte thru respondent Vice Gov. Jonah G. Pimentel as the Presiding Officer of the Sangguniang Panlalawigan regarding his request for the passage of a resolutionAffirming the interest of the Provincial Government of Camarines Norte to Apply, Negotiate and Borrow Funds from the Municipal Development Fund Office (MDFO) of the Department of Finance (DOF) for the implementation of proposed Construction of Wharf, River Control and Holding Areain the amount of Fifty Million Pesos (P50,000,000.00). Accordingly, these proposed projects are included in the Provincial Development and Physical Framework Plan (PDPFP) for 2012-2013 and 2018 Annual Investment Program (AIP) of the Provincial Government of Camarines Norte”. (A photocopy of said November 10, 2017 Letter is hereto attached as Annex “A”).
  1. On November 17, 2017 respondent Governor Tallado again wrote two (2) letters to the Sangguniang Panlalawigan of Camarines Norte, the first pertaining to a request for “appropriate action for the cost adjustment of the proposed Establishment of WHARF at Bagasbas, Daet, Camarines Norte, from Fifty Million (P50,000,000.00) to Sixty Million Pesos (P60,000,000.00), due accordingly to the inclusion of ACCESS ROAD and other components of the project. (A photocopy of the first letter is attached as Annex “B”);
  1. In the second letter also dated November 17, 2017 (Annex “C”), respondent Governor Tallado transmitted to the Sangguniang Panlalawigan for appropriate action a copy of Provincial Development Council (PDC) Executive Committee Resolution No. 01-2017, entitled – “A Resolution Approving the inclusion in the Calendar Year 2017 3rd Subsidiary Annual Investment Program (AIP) of the Province of Camarines Norte the proposed Construction of Wharf, River Control and Holding Area in the amount of P60 Million” (copy of PDC Execom Resolution No. 01-2017 is marked as Annex “D”);
  1. Respondent Vice Governor Jonah Pimentel approved the inclusion of respondent Tallado’s requests in the agenda for the 63rd Regular Session of the Sangguniang Panlalawigan scheduled on November 20, 2017;
  1. During the November 20, 2017 regular session, the requests of respondent Tallado were referred to the Committee of Finance & Appropriation and Ways & Means Committee. But during the recess of the same session, the Finance & Appropriation and Ways & Means Committees unprecedentedly convened jointly precisely to take up the said requests;
  1. During the joint Committee meeting, respondent Vice Governor Pimentel, who is NOT a member of either Committee, ACTIVELY PARTICIPATED in the deliberations. The Joint Committees initially agreed to consolidate respondent Tallado’s two requests for Cost Adjustment of the proposed establishment of Wharf at Bagasbas, Daet, Camarines Norte from P50M to P60M and adoption of the PDC ExeCom Resolution No. 01-2017 approving the inclusion in the Calendar Year 2017 3rd Subsidiary Annual Investment Program of the Province of Camarines Norte the proposed Construction of Wharf, River Control and Holding Area in the amount of P60 Million, as these items are related to one another.

6.1. Respondent Vice Governor Pimentel informed the joint committee members that while the AIP reflects that only P50MM is allotted to the Wharf project, the PDC Executive Committee has approved a resolution to increase it to P60MM to cover the ACCESS ROAD and other component projects. However, it still has to be adopted by the Provincial Development Council (PDC) itself as they cannot be implemented without the approval of the PDC. Respondent Vice Governor Pimentel also intimated that what is actually being requested by respondent Governor Tallado is to ADOPT the PRO-FORMA RESOLUTION being required by the Municipal Development Fund Office (MDFO) of the Department of Finance. Board Member Godfrey Parale reacted that the problem is that the resolution was not presented during the last session and the text thereof was not read by the members, while Board Member Arthur Michael Canlas retorted that the resolution is only for the affirmation of interest to negotiate and apply for a loan, but without giving authority to the Governor.

6.2. Respondent Vice Governor Pimentel explained that during the last session which involved a P500MM allocation for Convention Center, they only approved the AFFIRMATION of intention to borrow, and the authority shall come after the submission of the feasibility study. The use the pro-forma resolution is accordingly needed in order that the project could be implemented soon for the benefit of tourism industry in the province. He further stressed that there is no requirement of submission of feasibility study insofar as the Wharf is concerned. Hence, the PDC Executive Committee has approved a Resolution to increase the amount allotted for the Wharf project, but it should go through the adoption of the PDC as the project cannot be implemented without the approval of the PDC. With such persuasion by respondent Vice Governor Pimentel, the Joint Committee recommended the approval and the passage of the corresponding resolution, but made it subject to the condition that it has to be approved by the PDC prior to the implementation of the project.

  1. Thereafter, the session resumed on the same day November 20, 2017, and the ORAL Committee Report No. 40-2017 was adopted and was approved by the respondents constituting MAJORITY of the members of the Sangguniang Panlalawigan Resolution No.477-2017 entitled: “Resolution Affirming the interest of Provincial Government of Camarines Norte to Apply, Negotiate and Borrow Funds from the Municipal Development Fund Office (MDFO) of the Department of Finance (DOF) for the implementation of Construction of Wharf, River Control and Holding Area, Access Road and other components of the project in the amount of Sixty Million Pesos (P60,000,000.00) (the Committee Report and Resolution No. 477-2017 are marked as Annex “E” and Annex “F”, respectively);

CAUSES OF ACTION

  1. From the foregoing facts and circumstances, several IRREGULARITIES and ANOMALOUS acts and omissions were committed by the respondent, as follows:
  1. a) Careful perusal of the Letter of respondent Tallado dated November 10, 2017 (Annex “A”) would show that what was initially requested was for the passage of a resolution AFFIRMING the INTEREST of the Provincial Government of Camarines Norte to APPLY, NEGOTIATE and BORROW FUNDS from the Municipal Development Fund Office (MPDFO) of the Department of Finance (DOF), for the implementation of the proposed project” as stated therein, which is a WHARF, RIVER CONTROL and HOLDING AREA for P50MM, which projects are accordingly “included in the Provincial Development and Physical Framework Plan (PDPFP) for 2012-2013 and 2018 Annual Investment Program (AIP) of the Provincial Government of Camarines Norte”.

But examination of the Annual Investment Program (AIP) (first page is marked as Annex “G”, while page E-25 is marked as Annex “H”), what is listed in AIP Reference Code No. 8000-300-3.7 is “Construction of WHARF, Bagasbas, Daet, CN” only, and the amount allocated is already P70MM. Hence, the letter of respondent Tallado is INACCURATE, ERRONEOUS and FALSE as regards the project and the allocation, but it unduly EXPANDED what has been previously approved by the Provincial Development Council (PDC), for reasons only known to him;

b) It also appears that in the AIP Reference Code No. 8000-300-3.7, what is approved by the PDC is the “Construction of WHARF, Bagasbas, Daet, CN” only.

But in respondent Tallado’s letter of 10 November 2017, he was requesting the SP for the passage of a Resolution affirming the interest of the Province of Camarines Norte to apply, negotiate and borrow funds from MPDFO for the implementation of the WHARF, RIVER CONTROL and HOLDING AREA in Bagasbas, Daet, CN.

Then in respondent Tallado’s letter dated 17 November 2017, he was requesting for the cost adjustment of the same Wharf project from P50MM to P60MM due to the inclusion of ACCESS ROAD.

Lastly, in his second letter also dated November 17, 2017, respondent Governor Tallado transmitted to the Sangguniang Panlalawigan for appropriate action a copy of Provincial Development Council (PDC) Executive Committee Resolution No. 01-2017, entitled – “A Resolution Approving the inclusion in the Calendar Year 2017 3rd Subsidiary Annual Investment Program (AIP) of the Province of Camarines Norte the proposed Construction of  WHARF, RIVER CONTROL and HOLDING AREA in the amount of P60 Million”, without mentioning about the ACCESS ROAD.

Then the SP passed and approved Resolution No.477-2017Resolution Affirming the interest of Provincial Government of Camarines Norte to Apply, Negotiate and Borrow Funds from the Municipal Development Fund Office (MDFO) of the Department of Finance (DOF) for the implementation of Construction of Wharf, River Control and Holding Area, Access Road and other components of the project in the amount of Sixty Million Pesos (P60,000,000.00), which included already all of the FOUR (4) projects taken from 4 different documents, but are all INCONSISTENT with the AIP.

This is anomalous because what is approved in the 2017 AIP is the construction only of Wharf in Bagasbas. River Control, Holding Area and Access Road are NOT COMPONENTS of Wharf. They are SEPARATE AND DISTINCT PROJECTS, and should have been treated in DIFFERENT ACCOUNTS, and should have been proposed and APPROVED by the PDC itself in a meeting duly called for the purpose;

  1. c) Respondent Tallado was also requesting for the passage of a resolution AFFIRMING the INTEREST of the Provincial Government of Camarines Norte TO APPLY, NEGOTIATE and BORROW FUNDS from the Municipal Development Fund Office (MDFO) xxx”.

(1) But in the approved Resolution No. 477-2017 dated November 20, 2017 (Annex “F”), while the same carries the same title, the resolution further resolved as follows;

”RESOLVED FURTHER to:

  1. AUTHORIZE AND EMPOWER the incumbent local chief executive, HON. GOVERNOR EDGARDO A. TALLADO, and his successor, for and in behalf of the Provincial Government of Camarines Norte to:
  2. APPLY, NEGOTIATE and ENTER INTO a LOAN AGREEMENT with the MDFO and with partner agency, when necessary, and EXECUTE DEEDS and to do all acts necessary and proper under the premises for the effective and efficient implementation of the Project;
  3. ENTER INTO AGREEMENT with qualified PRIVATE INDIVIDUALS OR CORPORATION, after bidding, to EXECUTE the Project, and

xxx                         xxx                             xxx

These are already a separate and distinct and no longer germane to the mere AFFIRMING the INTEREST to apply, negotiate and borrow funds from the MDFO. The authority to ENTER INTO A LOAN AGREEMENT is an expanded authority, and will definitely need a SEPARATE session, deliberation, consideration and legislation. The LOAN AGREEMENT specially the TERMS AND CONDITIONS THEREOF, together with the FEASIBILITY STUDY, ARCHITECTURAL and DETAILED ENGINEERING DESIGN and PROGRAM OF WORK (POW) should first be submitted for the scrutiny, review and approval of the Sangguniang Panlalawigan members, before such authority to enter any agreement could be given.

(2) The resolution also unduly authorized respondent Tallado to ENTER INTO an AGREEMENT with private individuals or corporation to EXECUTE the projects. This is also not covered by respondent Tallado’s request. And before any such agreement could be entered into, the same Feasibility Study, Architectural and Detailed Engineering Design And Program of Work (POW) as well as the AGREEMENT itself should first be submitted in order for the SP members to evaluate whether the private individual who would execute the project is qualified to undertake the project in accordance with the Program of Work.

(3) While the Resolution mentions about a bidding, the BIDDING PROCESS should have been conducted and satisfied first BEFORE any agreement for the execution thereof could be entered into;

(4) The supposed condition imposed in the SP resolution that “PDC Executive Committee Resolution No. 01-201, should be approved and ratified by the Provincial Development Council in a meeting”, is already water under the bridge. This is a condition precedent and should come first before the SP approves the Resolution, absence of which is already “putting a cart before the horse” and would render the resolution as PREMATURE;

(5) In paragraph (f) of the Resolution also provides that:

“f.  Authorize the MDFO to DEDUCT from the LGU’s Internal Revenue Allotment (“IRA”) the amount due to MDFO in connection with the Project under the following cases: (i) default in the payment of principal amortization including interests and penalties; or (ii) any unliquidated financial obligations. The right of MDFO to deduct on the LGU’s IRA shall be without prejudice to any other available under Philippine law;   

This is already a LOAN PROVISION for the SECURITY of the lending institution in the event the LGU fails to pay the loan on time, which is not proper in a mere AFFIRMING the INTEREST of the Provincial Government of Camarines Norte TO APPLY, NEGOTIATE and BORROW FUNDS. This resolution is a mere INTENTION to apply for a loan, and not yet an authority to incur a loan;

(6) The Title of Resolution No. 477-2017 is actually DECEPTIVE as it is very much DIFFERENT from the body of the resolution itself. As already stated, the request of respondent Tallado and the title of said Resolution only expresses the INTENTION of the LGU to BORROW funds from the MDFO. But the Resolution already fraudulently granted respondent Tallado authority to enter into a loan agreement and execution of the project.

(7) The assurance by respondent Vice Governor that it was a pro-forma Resolution being required by the MDFO is suspect. If ever, that is designed just to facilitate the approval of loan and release of the loan proceeds as well as the assurance by the lending institution of collecting the loan, in the assumption that the LGU is already decided to push through with borrowing from the MDFO. But that is not yet the case of the herein respondents, as there are still legal prerequisites before the LGU would ever proceed with loan, like the feasibility study to determine the viability of the project in terms of ROI, etc. It should be remembered that this is a loan and not a grant, hence, the amount of income that could be generated from its operation is very much material to the LGU;

(8) The Provincial Development Council (PDC) Executive Committee Resolution No. 01-2017, entitled – “A Resolution Approving the inclusion in the Calendar Year 2017 3rd Subsidiary Annual Investment Program (AIP) of the Province of Camarines Norte the proposed Construction of Wharf, River Control and Holding Area in the amount of P60 Million” (Annex “D”), did not cure whatever defects created by the respondents’ deliberate  act and omission. Section 111, Paragraph (b), sub. Par. (2), (3) and (4) of the Local Government Code of 1991 (R.A. 7160), provides:

“SECTION 111. Executive Committee. – (a) Each local development council shall create an executive committee to represent it and act in its behalf when it is not in session. The composition of the executive committee shall be as follows:

xxx                            xxx                        xxx

 (b) The executive committee shall exercise the following powers and functions: 

xxx                            xxx                        xxx

             (2) Act on matters requiring immediate attention or action by the council;

            (3) Formulate policies, plans, and programs based on the general principles laid                   down by the council; and

            (4) Act on other matters that may be authorized by the council”.

In passing and approving PDC Executive Committee Resolution No. 01-2017, the PDC Executive Committee has overstepped its function, by EXPANDING the construction of WHARF only, to include other projects. The most prudent thing to do is just identify such additional projects assigning separate account thereto, submit them to the Provincial Development Council for approval, and thereafter to the Sangguniang Panlalawigan.

There is no immediate attention or action being required of the PDC during that time because the AIP had already been approved earlier, and the additional projects and fund allocation could just be taken up by the council itself had a meeting been just been called by respondent Tallado. It was only November and he had more of time to call for the PDC Meeting, but he opted not and instead just called PDC ExeCOM. The policies, plans and programs seemed to have been formulated already by the Council long time ago, hence, there is actually no need for the ExeCom to convene and act in behalf of the PDC.

(9) The act of the respondents Vice Governor Pimentel and other members of the SP in conducting a Committee meeting DURING A RECESS is unprecedented. Committee meeting should have been conducted on a separate date, and not just during the RECESS of the regular session of the SP. This is to give the members of the Committee enough and ample time to carefully study the item, deliberate thereon, and come up with its well-studied and independent disposition on the matter. From the minutes of that Joint Committee meeting on November 20, 2017, it shows that the meeting started at 1:40 PM, and ended at 3:40 PM, or a span of only 2 hours was allotted to them, with other items also taken up;

(10) the ACTIVE PARTICIPATION of respondent Vice Governor Pimentel during the joint Committee meeting in November 20, 2017, is also improper. He is NOT A MEMBER of any of the Committees, but his mere presence and the manner he PERSUADED the SP Members on what to do with the requests of respondent Tallado, tramples on the supposed independence of the individual members of the SP;

THE CHARGES:

 

  1. As a result herein respondents clearly committed the following acts and omissions, viz.:

 

  1. A) Of GOVERNOR EDGARDO A. TALLADO

 

  • by giving erroneous and untruthful data and information as regards the Wharf project and the amount already allotted thereto of P70MM, by including other projects and making it appear that the allocation is only P50MM, is tantamount to SERIOUS DISHONESTY, which is the concealment or distortion of truth, which shows lack of integrity or a disposition to defraud, cheat, deceive or betray and intent to violate the truth. (CSC Resolution No. 06-0538, April 4, 2006);

 

  • By inducing the Sangguniang Panlalawigan to approve that questionable and equally irregular, anomalous, half-baked, premature and deceptive Resolution No. 477-2017 (Annex “F”) based on those erroneous information, he also violated Section 3 (a) of RA 3019, which is defined as “Persuading, inducing or influencing another public officer to perform an act constituting a violation of rules and regulations duly promulgated by competent authority or an offense in connection with the official duties of the latter, or allowing himself to be persuaded, induced, or influenced to commit such violation or offense”.

 

  1. B) Of VICE GOVERNOR PEDRO JONAH G. PIMENTEL –

 

  • By allowing the Joint Committee to conduct their Committee Meeting during the RECESS of the Regular Meeting of the Sangguniang Panlalawigan, which resulted in the passage and approval of that equally half-baked, irregular, anomalous, premature and deceptive Resolution No. 477-2017 (Annex “F”), respondent Vice Governor Pimentel committed GROSS NEGLECT OF DUTY, which is defined as “the omission or refusal, without sufficient cause, to perform an act or duty, which is the officer’s legal obligation to perform (MORENA, Henry P., CSC Resolution No. 00-10-86, May 3, 2000);

 

  • In meddling with and persuading the members of the Joint Committee of Finance & Appropriation and Ways & Means (of which he is not a member) to come up with a Verbal Committee Report recommending the passage and which in fact resulted in the approval of that half-baked, irregular, anomalous, premature and deceptive Resolution No. 477-2017, respondent Vice Governor Pimentel committed GRAVE MISCONDUCT, which is defined as “transgression of some established and definite rule of action, more particularly, unlawful behavior or gross negligence”. It is “wrongful, improper or unlawful conduct motivated by a premeditated, obstinate or intentional purpose, which is characterized with corruption”.

 

  • By allowing himself to be the spokesperson of respondent Tallado during their Joint Committee meeting of the respondent SP Members to persuade them to pass and approve that half-baked, irregular, anomalous, premature and deceptive Resolution No. 477-2017 (Annex “F”), he again guilty of GRAVE MISCOMNDUCT, as already defined above;

 

  1. C) Of the Sangguniang Panlalawigan Members GERARDO G. QUINOŇES, RODOLFO V. GACHE, RENEE HERRERA-DEPANTE, JOSEPH STANLEY G. ALEGRE, ARTEMIO B. SERDON JR., MURIEL M. PANDI, ERWIN L. LAUSIN, REYNOIR V. QUIBRAL, JOAQUIN “Jay” EMMANUEL GPIMENTEL and RAMON E. BANING –

 

  • By VOTING for the passage and approval of that half-baked, irregular, anomalous, premature and deceptive Resolution No. 477-2017 (Annex “F”), without verifying the ERRONEOUS DATA being supplied by respondent Governor Tallado from the AIP itself, and attended by RAILROADING THEIR JOINT COMMITTEE MEETING held during the Recess of the regular session of the SP, and BLINDLY ALLOWING THEMSELVES TO BE PERSUADED by respondent Vice Governor Pimentel rather that acting on respondent Tallado’s requests based in their own conviction and independent evaluation of the matter, and by they clearly committed GROSS NEGLECT OF DUTY and GRAVE MISCONDUCT, as already defined above;

 

  • D) Of PPDC ELENA B. AUSTRIA

 

  • As the Provincial Planning and Development Coordinator (PPDC) and Secretary of the Provincial Development Council (PDC), she, among others, “shall be responsible for providing technical support, documentation of proceedings, preparation of reports and such other assistance as may be required in the discharge of its functions”. But in allowing the passage of that inaccurate, erroneous and Provincial Development Council (PDC) Executive Committee Resolution No. 01-2017 (Annex “D”) which resulted also in the approval of that half-baked, irregular, anomalous, premature and deceptive Resolution No. 477-2017 (Annex “F”), she GROSSLY NEGLECTED her duties and functions, as already defined above.

WORSE, by allowing the passage and approval of that half-baked, irregular, anomalous, premature and deceptive Resolution No. 477-2017, all the herein respondents clearly CONSPIRED, COLLABORATED AND CONFEDERATED by their individual participation, but geared towards a common design, to MODIFY the project that was duly approved by the Provincial Development Council without first complying with the prescribed rules, and prematurely authorizing respondent Governor Tallado to enter into a Loan Agreement already with the Municipal Development Fund Office and Construction Agreement with private person or corporation thru that supposed PRO-FORMA RESOLUTION, but actually DECEPTIVE on its title, and would surely be disadvantageous on the part of the LGU of Camarines Norte. Hence, herein respondents should all be indicted for violating Section 3(e) of RA 3019 (Anti-Graft and Corrupt Practices Act), which provides:

(e) Causing any undue injury to any party, including the Government, or giving any private party any unwarranted benefits, advantage or preference in the discharge of his official, administrative or judicial functions through manifest partiality, evident bad faith or gross inexcusable negligence. xxx” 

          WHEREFORE, it is respectfully prayed that upon the filing hereof;

  1. The respondents be immediately placed under PREVENTIVE SUSPENSION, they being charged of grave offenses wherein the evidence of guilt is strong being all documentary, and their continued stay in their powerful and influential offices surely poses a threat to the integrity of the records, and might intimidate possible witnesses;
  2. The respondents be immediately INVESTIGATED, both criminally and administratively for Violations of Section 3, Paragraphs (a) and (e) of RA 3019 (Anti-Graft and Corrupt Practices Act); GRAVE MISCONDUCT; SERIOUS DISHONESTY and GROSS NEGLECT OF DUTY;
  3. That after finding them administratively liable, that they be meted the STIFFEST PENALTIES imposed by law;
  4. That after finding probable cause against them, that APPROPRIATE CHARGES/INFORMATION BE FILED against them with the proper forum.

Other relief just and equitable are likewise prayed for.

Daet, Camarines Norte, January 26, 2018

                                                NORBERTO B. VILLAMIN

   Complainant

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