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2ND IMPEACHMENT COMPLAINT



YOUTH ACT NOW et al
vs Aquino
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GROUNDS FOR IMPEACHMENT
I. THE PRESIDENT HAS COMMITTED CULPABLE
VIOLATION OF THE CONSTITUTION

II. THE PRESIDENT HAS BETRAYED PUBLIC
TRUST

III. THE PRESIDENT HAS COMMITTED GRAFT
AND CORRUPTION
YOUTH ACT NOW, et al vs. Aquino, 22 July 2014
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CULPABLE VIOLATION OF THE CONSTITUTION
Paragraphs 7 to 10 explains how DAP came to be
and cites several memoranda approved and
signed by no less than the president himself to
pool public funds without any legal basis.
Paragraph 14: The president used the DAP
mechanism for cross-border transfer to
Commission on Audit (Php143.7 million) and
House of Representatives (Php250 million)
YOUTH ACT NOW, et al vs. Aquino, 22 July 2014
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CULPABLE VIOLATION OF THE CONSTITUTION
Paragraph 34: The president used DAP to transfer
funds from Congress-approved items to projects
not covered by GAA
Paragraph 22: On 14 July 2014, in a nationally-
televised address, the President arrogantly and
brazenly announced his defiance of the Supreme
Court. It was widely viewed as a declaration of war
and gross disrespect of the Supreme Court, the
ultimate arbiter and interpreter of the Constitution.
YOUTH ACT NOW, et al vs. Aquino, 22 July 2014
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BETRAYAL OF PUBLIC TRUST
Paragraphs 45-46: As pointed out by the Supreme
Court in the Decision dated 1 July 2014 , the
doctrine of operative fact "cannot apply to the
authors, proponents and implementors of the
DAP unless there are concrete findings of good
faith in their favor by the proper tribunals
determining their criminal, civil, administrative
and other liabilities." The burden of proving good
faith is on the president and other implementors
of DAP.
YOUTH ACT NOW, et al vs. Aquino, 22 July 2014
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BETRAYAL OF PUBLIC TRUST
Paragraph 48: The President is far from an
innocent bystander here. He approved and
gave authority for NBC No. 541, affixing his
signature and stamp of approval on the said
circular, as well as each of the various
memoranda and related issuances pertaining
thereto (as mentioned in Par 8 and 9).

YOUTH ACT NOW, et al vs. Aquino, 22 July 2014
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GRAFT AND CORRUPTION
Paragraphs 21, 54-56: Sen. Jinggoy Estrada has
previously revealed the Presidents attempt to
bribe members of the Senate of the Philippines
with Fifty Million Pesos (Php50M) in DAP funds in
exchange for voting in favor of Chief Justice
Renato Coronas impeachment.
This act of the President constitutes the crime of
attempted corruption of public officials, as
punished under Article 212, in relation to the
second paragraph of Article 210, of the Revised
Penal Code.
YOUTH ACT NOW, et al vs. Aquino, 22 July 2014
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GRAFT AND CORRUPTION
Paragraphs 59-60: By realigning at least Php144.4B
in funds to at least 116 programs, activities, and
projects under the DAP, the President has committed
no less than 116 counts of technical malversation.
All elements of the crime of technical malversation is
present (the President is a public officer, accountable
for all the funds appropriated under the GAAs, who
applied public funds under his administration to
allegedly public uses which the Supreme Court has
found to be different from the purpose for which they
were originally appropriated by the House of
Representatives).
YOUTH ACT NOW, et al vs. Aquino, 22 July 2014
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THE 2
ND
COMPLAINT IS
SUFFICIENT IN SUBSTANCE
1. There is a recital of facts
2. The recital of facts constitute the
offenses charged
3. The recital of facts determine
the jurisdiction of the committee
YOUTH ACT NOW, et al vs. Aquino, 22 July 2014
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2ND IMPEACHMENT COMPLAINT

YOUTH ACT NOW et al
vs Aquino
__________________________________________________________________________