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hepublic of the PhiliPPines City of Iloilo

) S.S.

X----

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COMPLAINT.AFFII}AYIT

of 19-11 La I, MANUEL p. MEJORADA, of legal age, Filipino, married, and a resident hereby depose Belle St., Pavia, Iloilo, after having been swom in accordance with law, do
and state:
1.

This is a criminal and administrative complaint against JEFFREY CHRISTIAN E. MABILOG of Iloilo city for the following offenses: unexplained wealth under section 8, Republic Act No. 3019;

2.

Grave misconduct and such other offlenses covered by Republic ActNo. 3019 and Republic ActNo' 6713; of These offenses were commified by respondent, who holds the position of Nurse IV, City Health Office, Iloilo City, in connection with his Statements Assets, Liabilities and Net Worth (SALN) for the year 2008, 2009,2010 and

r o r .

Dishonesty; Perjury; and

20ll,copies of which were furnished by Ms. ThelmaGolez, Department Head, Human Resources Management and Development Office, Iloilo City Government, hereto attached as Annexes'0A", "B", "C" and "D" respectively; 1. A photocopy of the cover letter signed by Ms' Thelma E'
a

o'8"; Golez is attached as Annex Respondent may be served with summonses' orders and issuances by this Honorable Office at his office in the City Health Office, New Iloilo City Hall, De la Rama St., Iloilo CitY 5000; The above-listed offenses were cotnmitted by respondent Jeffiey Christian E' Mabilog by way of his failure to disclose his financial interests and business involvement in a corporation named VICTORY EDUC'L SERVICES, INC', a private corporation duly registered with the Security and Exchange Commission on August 17,2A05 under Company Registry No. CS200528239; In the Articles of Incorporation, it is shown that respondent Jeffrey

4.

a)

Christian E. Mabilog is one of the five incorporators of Victory Educ'l Seryices, Inc., and subscribed to 1,000 shares, or 40 percent of the total shares of stock subscribed, with total paid up amount of
P62,500.00;

a.

A photocopy of the certified true copy of the Articles of Incorporation for Victory Educ'l
Services Inc. is attached as Annex
o'F"

of this

b)

complaint; It should be noted that respondent Mabilog is the only incorporator with paid up capital, giving rise to the presumption that he is the

11

sole owner of the corporation and the other incorporators are merely
oodummies";

c) d)

Respondent Mabilog was elected as Treasurer of the corporation as

shown in Article Tenth of the Articles of Incorporation; In the certified true copy of the General lnformation Sheet (GIS) submitted by Victory Educ'l Services, Inc. to the Securities and Exchange Commission for the year 2010, respondent Mabilog is

e)

:A

-$ N

s)

h)

i)
k)

listed as stockholder, director and Finance Officer (a photocopy of which is attached as Annex "G" of this complaint); a. Please note there is no change in the profile of the stockholders, including the total amount of paid-up capital compared to the time of its incorporation; The corporation operated and managed a call-center training institution called "Panpacific Career and Management Institute" as could be gleaned from the first page of the SEC GIS; The Panpacific Career and Management Institute was duly accredited by the Technical Education and Skills Development Authority (TESDA) to conduct short-term training programs, particularly for finishing courses for call-center agents as indicated in the letter dated November 14,2011 signed by YOLANDA C. PORSCHWITZ, CESO IV, then the Provincial Director of TESDAIloilo (a photocopy of which is attached as Annex 'oH" of this complaint along with its attachments); In its audited financial statements submitted to the Securities and Exchange Commission, it appears that Victory Educ'l Services, Inc. posted a net operating loss of P302,842.17 and a net profit of P45,842.71for the years ending December 31,2007 and 2008, respectively; a. A photocopy of a Certified True Copy of the Audited Financial Statements of Victory Educ'l Services, Inc. is attached as Annex o'I"; In short, Victory Educ'l Services, Inc. was a legitimate business operation, with respondent Mabilog as its Finance Officer and lone paid-up stockholder; An examination of the Balance Sheet of Victory Educ'l Services, Inc. would show that while the corporation had a paid-up capital of only P62,500.00, it managed to generate equity for its operations o'Advances through from Stockholders" in the amount of Pt,873,634.07; With the corporation's profile of its incorporators and stockholders, it is logical that the advances could only have come from one person: respondent Mabilog; Against this backdrop, a careful examination of respondent Mabilog's Statements of Assets, Liabilities and Net Worth (SALN) for the years 2008,20A9,2010 and 2011 shows that this financial interest and business investment in Victory Educ'l Services, Inc. was NOT disclosed;

tF"

Such concealment of this substantial financial exposure to a business is a violation of Republic Act No. 6713, particularly

Section 8 thereol as this corporation continues to be active as shown by the latest filing of the General Information Sheet for the year 2010;

More than an act of concealment, respondent Mabilog is liable for unexplained wealth or ill-gotten wealth; Being a low-level public officer, respondent Mabilog could not possibly afford to advance or lend the corporation P1,873,674.07 which is indicated in its Balance Sheets for the years 2007 and 2008, hence, is presumed ill-gotten or unexplained pursuant to Republic ActNo. 3019, Section 8; As it is an advance, or loan, to the corporation, that amount necessarily forms part of his assets, but was not disclosed as mandated by Republic Act No.6713; Republic Act No.l379 raises the presumption that the asset/investrnent is ill-gotten wealth as well, and should be subject to confi scation proceedings; In addition to the foregoing, respondent Mabilog should be indicted and prosecuted for dishonesty and perjury and grave misconduct for these offenses; Administratively, respondent Mabilog should be meted with administrative suspension for the above offenses because of the strong evidence against him while the preliminary investigation is on-going; 5. That I am executing this complaint affidavit for the purpose of attesting to the truthfulness of the foregoing statements in support of this criminal and administative complaint against the respondent; 6. Further, affiant sayeth naught.

m)

n)

o)

p) q)

r)

IN WITNESS ImREoF, I have hereunto Iloilo City, Philippines.

set my hand this

U&day

of Augu st,2012, at

FlftA(m rD# 1 .biss1|\

dUg 14 zof? in,o,o City, SUBSCRIBED AND SWORN to before me this Philippines. I hereby certifi/ that I have personally examined the affiant and I am firlly satisfied that he voluntarily executed and understood his