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

COMPLAINT-AFFIDAVIT

I, MANUEL P. MEJORADA, of legal age, Filipino, married, and a resident of 19-11 La

Belle St., Pavia, Iloilo, after having been sworn in accordance with law, do hereby depose

and state:

1. This is a criminal and administrative complaint against CITY MAYOR JED

PATRICK E. MABILOG of Iloilo City for the 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 which are currently on file

with this Honorable Office;

2. 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 for the years 2007-2010;

b. He was elected as City Councilor for the term 2004-2007;

c. As a duly elected public official during those years, he was required, and did

file, Statements of Assets, Liabilities and Net Worth for the periods covered;

3. Respondent may be served with subpoenas, summonses and other orders of this

Honorable Office at his temporary office at the 3rd Floor, Robinsons Place, Ledesma

St., Iloilo City, or at the New Iloilo City Hall once the Iloilo City government shall

have transferred to the new edifice;

4. The criminal and administrative offenses were committed by respondent as follows:

UNEXPLAINED WEALTH

5. Respondent reported in his SALN for the year ending December 31, 2010 the

following pertinent financial information with respect to his assets, liabilities and net

worth:

a. Declarant’s Annual Gross Income: P564,743.00;

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

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

d. Investments, other personal properties and liabilities: P27,760,000.00;

i. No liabilities were reported in this SALN;

e. Based on the above information, respondent’s Net Worth was valued at

P71,106,600.30;

f. A print out of the digital copy of respondent’s SALN for the year ending

December 31, 2010 furnished the undersigned by the SALN custodian in the

Office of the Ombudsman-Visayas is attached as Annex “A”;

6. In his SALN for the year ending December 31, 2007 (printed copy from digital

image furnished by the OMB-V custodian is attached as Annex “B”), respondent Jed

Patrick E. Mabilog, who was then City Vice Mayor of Iloilo City, reported the

following pertinent information about his assets, liabilities and net worth:

a. Total real properties: P44,910,376.00;

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

c. Total liabilities: P22,712,168.00;

d. NET WORTH: P44,454,432.30;

7. Comparing the information pertaining to respondent Mabilog’s net worth for the

years 2007 and 2010 as summarized above, there was a sharp increase --- a giant

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:

“Section 8. Prima facie evidence of and dismissal due to unexplained wealth. 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 name of other persons, an amount of property and/or money manifestly out of proportion to his salary and to his other lawful income, that fact shall be a ground for dismissal or removal. Properties in the name of the spouse and unmarried children of such public official may be taken into consideration, when their acquisition through legitimate means cannot be satisfactorily shown. Bank

deposits in the name of or manifestly excessive expenditures incurred by the public official, his spouse or any of their dependents including but not limited to activities in any club or association or any ostentatious display of wealth including frequent travel abroad of a non-official character by any public official when such activities entail expenses evidently out of proportion to legitimate income, shall likewise be taken into consideration in the enforcement of this section. The circumstances hereinabove mentioned shall constitute valid ground for the administrative suspension of the public official concerned for an indefinite period until the investigation of the unexplained wealth is completed.”

a. The skyrocket-fashion increase in respondent’s net worth is definitely

manifestly out of proportion to his salary as City 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

P26,652,168.30;

a) The amount 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 of

his gross annual family income for three years, he 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 Internal 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 taxes are deducted from this gross family

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

of P3,200,000.00, more or less, will be taken away from his total

income;

d) 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 yearly

income by approximately P2,400,000.00;

e) With these conservative estimates of deductions for taxes and

living expenses, respondent will have only P2,800,000.00, more

or less as being available for additional investments and property

acquisitions;

f) Assuming this to be the level of his net income for the years 2008,

2009 and 2010, respondent could only acquire properties in the

vicinity of P9,000,000-10,000,000;

g) Where did he get P16,000,000.00 on top of the available money

for investments?

h) Such increase in his net worth 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 UNEXPLAINED WEALTH.

DISHONESTY

1. In disclosing the required information about his assets, liabilities and net worth in

compliance with Section 7 of RA 3019 and Section 1, RULE VII of the

Implementing Rules and Regulations (IRR) of RA 6713, respondent deliberately

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

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

a. In his 2010 SALN, respondent listed 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 in 2007;

i. This information 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 acquisition cost to a lower amount, respondent made

it appear that his real properties and vehicles owned during the year

2010 was only P43,346,600.30;

b. Respondent also listed a Lexus luxury 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’s 2007 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;

iii. The aforementioned amount for the acquisition cost of the Lexus car

is grossly understated, because the price range of this luxury vehicle

is between P2,000,000.oo to P4,000,000.00, depending on the model;

iv. Again, the motive for this understatement of the acquisition cost is to

hide 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 2008 and 2010;

2. Respondent understated the acquisition cost of the 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 in

Lapaz, 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

2004 (a copy is hereto attached as Annex “C”), 2005 (a copy is

attached as Annex “D”), 2006 (a copy is attached as Annex “E”) and

the year 2007;

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

Iloilo City 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 years and hide the fact that it is one of

his recent acquisitions;

1. The above act constitutes dishonesty;

iv. Even if indeed this piece of property 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 jewelries and cash in bank for

the year 2010 which, in his 2007, was reported to be P10,000,000.00;

i. This failure to report/disclose his jewelries/cash in bank, an item that

consistently appeared in his previous years’ SALNs in the amount of

P3,300,000.00, is a deliberate act to hide the true worth of his wealth,

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

and other legitimate income;

ii. This is yet another act of dishonesty;

f. The above-cited misdeclarations and understatements of values resulted in

hiding the true net worth of respondent, which could represent another

P20,000,000.00 that should have been added to his 2010 SALN for the

portion on net worth;

PERJURY

1. The statements under the preceding heading “DISHONESTY” also form the factual

and legal basis to hold respondent liable for PERJURY, as the SALNs were filed in

accordance with law and were sworn to before a competent administering officer;

GROSS MISCONDUCT AND OTHER

VIOLATIONS OF R.A. 3019 AND R.A. 6713

2. In addition to UNEXPLAINED WEALTH, respondent is also liable for violating the

mandate for simple living among public officials and avoid ostentatious display of

wealth under Section 4 Paragraph (h) of R.A. 6713;

a. In his various SALNs up until the latest filed for the year 2010, respondent

has acquired numerous vehicles --- luxury vehicles --- in close proximity to

each other and by the latest count, had a total of seven (7) cars/SUVs, as

follows:

Make/Model Year acquired Acquisition cost

Ford Everest 2004 P 1,400,000.00

Toyota Innova 2006 700,000.00

Toyota Camry 2007 2,246,224.00

Isuzu Altierra 2007 1,300,000.00

Dodge Durango 2008 600,000.00

Lexus Not stated 1,500,000.00

Toyota Revo Not stated 400,000.00

b. That, in any language, is an ostentatious display of wealth and grandiose

living;

c. The Lexus, Dodge Durango, Toyota Camry, Isuzu Altierra and Ford Everest

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

car owner;

d. Having all four of them, and buying these vehicles at the rate of almost one

every year since 2007, is lavish spending, rightfully belonging under the

lifestyle of the rich, and a sharp departure from the Norm of Conduct for

Public Officials and Employees, particularly Section 4, Paragraph (h), of

Republic Act No. 6713 on “Simple Living”;

e. Under Section 8, Republic Act No. 3019, mandates that ostentatious display

of wealth “shall likewise be taken into consideration in the enforcement of

this section”, and would, by itself, also constitute grave misconduct;

3. The circumstances by which respondent amassed so much wealth during his

incumbency as City Councilor, Vice Mayor and Mayor of Iloilo City are mysterious

by any standards;

4. Respondent’s legitimate income in the form of salary as a public official and income

of his wife and business, do not match with the pace by which his wealth grew;

5. Section 8, RA 3019 is clear on this point: such circumstances are prima facie

evidence of unexplained wealth as he amassed assets manifestly out of proportion to

his legitimate income;

6. The documentary evidence also prove the falsification, dishonesty and perjury;

7. Clearly, respondent transgressed RA 3019, RA 6713 and other relevant laws on

falsification, dishonesty and perjury, and a criminal and administrative investigation

by the Office of the Ombudsman is just and proper;

8. That I am executing this complaint affidavit for the purpose of attesting to the

truthfulness of the foregoing statements and file this criminal and administrative

complaint against the respondent;

9. Further, affiant sayeth naught.

IN WITNESS HEREOF, I have hereunto set my hand this ______ day of February, 2012, at

Iloilo City, Philippines.

MANUEL P. MEJORADAComplainant-Affiant

SUBSCRIBED AND SWORN to before me this ________________ in Iloilo City,

Philippines. I hereby certify that I have personally examined the affiant and I am fully

satisfied that he voluntarily executed and understood his complaint-affidavit.

__________________________