Republic of the Philippines

Office of the Ombudsman

Ombudsman Bldg., Agham Road, Diliman, Quezon City

BERTENI TOTO CATALUA

CAUSING, president of Alab ng
Mamamahayag (ALAM) and
Hukuman ng Mamamayan
Movement, Inc. (HMMI)
Complainant,

- versus -

OMB C-C No. _______________

For:

PERJURY,
FALSIFICATION,
Violation of Sections 87

& in relation to Section 11 of Republic Act

No. 6713

EDWARD S. HAGEDORN,
Puerto Princesa, Palawan
Respondent.
x---------------------------------------x
Republic of the Philippines
)
City of Manila
)SC

Supplemental Complaint-Affidavit
I, BERTENI TOTO CATALUA CAUSING, of legal age,
president of Hukuman ng Mamamayan Movement, Inc. (HMMI)
and president of Alab ng Mamamahayag (ALAM), Filipino, whose
postal address is Unit 1, No. 2368 Leon Guinto St., Malate,
Manila, after having been sworn to in accordance with law, do
hereby depose and state:

1. I have filed the above-captioned complaint against Edward Solon

Hagedorn at the Office of the Ombudsman on October 23, 2013;
2. Because of additional documentary evidences that I have
discovered in relation to Hagedorns six (6) business interests that
he failed to declare in his Statements of Assets, Liabibities and
Net Worth (SALNs for brevity), and because of the fact that it was
only now he learned of the residence address of the respondent,
and further because he committed thirty-three (33) more
counts of the crime of violation of Section 7(a) and Section 7(b) in
relation to Section 11 of Republic Act 6713, I am filing this
Supplemental Amended Complaint, I file this Supplemental
Complaint;
3. From the corporation papers where the name of the respondent
appears as a stockholder, he listed his residence address as No. 1
Marcelo Compound, San Pedro, Puerto Princesa;
4. The six business corporations where Hagedorn is one of the
incorporators and stockholders, include the one that runs a
hundred-million-pesos-yearly-selling Jollibee franchise in
Puerto Princesa City;
5. These businesses that have not been declared in his Statements
of Assets, Liabilities, and Networth (SALNs) are the following:
a) Palawan Jolly Foods Corporation, with principal office address
at Rizal Avenue, Puerto Princesa City, Palawan, was issued a
Certificate of Filing of Amended Articles of Incorporation by the
Security and Exchange Commission (SEC for brevity) on August
27, 2010, but it appeared that it existed since December 17,
1998 as proved by an Acknowledgement notarized by Atty.
Roberto A. Delos Reyes. This corporation that owns the franchise
of Jollibee in Puerto Princesa had not been declared by Hagedorn
in his SALNs for the years 2004, 2005, 2006, 2007, 2008, 2009,
2010, 2011 and 2012 (Nine counts).

All the documents relating to Palawan Jolly Foods Corporation

are attached hereto as ANNEX QQQ series.
b) Puerto Princesa Broadcasting Corporation, with principal office
address at Centro De Benito Yaliva, 178 Rizal Avenue, Puerto
Princesa City, Palawan, was issued a Certificate of Filing of
Amended Artciles of Incorporation by the SEC on January 14,
2009, but it appeared that it existed since June 17, 2008 as
proved by a Directors Certificate which was notarized by Atty.
Leonido B. Arriola. This corporation had not been declared by
Hagedorn in his SALNs for the years 2008, 2009, 2010, 2011 and
2012 (Five counts).
All the documents relating to Puerto Princesa Broadcasting
Corporation are attached hereto as ANNEX RRR series.
c) Puerto Prince Bee Foods Corporation, with principal office
address at National Highway, Barangay San Manuel, Puerto
Princesa City, Palawan, was issued a Certificate of Incorporation
by the SEC on January 26, 2012. This coporation had not been
declared by Hagedorn in his SALN for 2012 which he submitted
to the Office of the Deputy Ombudsman for Luzon on April 30,
2013 (One count).
All the documents relating to Puerto Prince Bee
Corporation are attached hereto as ANNEX SSS series.

Foods

d) Green Forest Blue Waters Corporation, with principal office

address at 2384 Kanumayan Pensione Penthouse-A, Malate,
Manila, was issued a Certificate of Incorporation by the SEC on
January 8, 2008. This corporation had not been declared by
Hagedorn in his SALNs for the years 2008, 2009, 2010, 2011 and
2012 (Five counts).
All the documents relating to Green Forest Blue Waters
Corporation are attached hereto as ANNEX TTT series.

e) Radiant Homes Land Development RHLD Inc., with principal

office address at 178 Rizal Avenue, Puerto Princesa City,
Palawan, was issued by the SEC a Certificate of Incorporation on
October 23 2009 and a Certificate of Filing of Amended Articles of
Incorporation renaming it to Radiant Forest Homes Development
RFHD Inc. on October 18, 2011. This corporation had not been
declared by Hagedorn in his SALNs for the years 2009, 2010,
2011 and 2012 (Four counts).
All the documents relating to RHLD and RFHD are attached
hereto as ANNEX UUU series.
f) Hagedorn Travel & Tours Inc., with principal office address at
National Hiway, San Pedro, Puerto Princesa City, Palawan, was
issued a Certificate of Incorporation by the SEC on May 29, 2000.
This company had not been declared by Hagedorn in his SALNs
for the years 2004, 2005, 2006, 2007, 2008, 2009, 2010, 2011
and 2012 (Nine counts).
ll the documents relating Hagedorn Travel & Tours Inc., are
attached hereto as ANNEX VVV series.
6. The aforementioned documentary evidence form an integral part
of the Complaint.-Affidavit earlier filed.
7. In addition to the charges of three kinds of criminal offenses, I
am also filing the charge of amending the complaint, I am filing
against Hagedorn a criminal offense of violation of Section 7(a)
and Section 7(b) in relation to Section 11 of Republic Act No.
6713, for a total of thirty-three (33) counts for all the
corporations listed above and for all the years that he issued
Mayors Permit to these business establishments.
8. It is noted that despite being the mayor of the City of Puerto
Princesa, he issued permits and licenses to all his businesses,
despite the fact that it is undisputable that he has had financial
and material interests in all these corporations.

9. The respondent knows that as the mayor he knew that every

issuance of license and mayors permit is not a simple ministerial
matter but one that requires judgment.
10.
The respondent deliberately ignored the fact that the
businesses he approved for his corproations have had
competitors in the City.
11.
For being so interested in the businesses, the respondent
placed himself in material and financial conflict with his office.
12.
Because he approved the business permits of these
corporations where he is a major stockholder, the respondent
violated Section 7(a) and Section 7(b) of RA 6713, to wit:
Section 7. Prohibited Acts and Transactions. In addition to acts and
omissions of public officials and employees now prescribed in the
Constitution and existing laws, the following shall constitute prohibited acts
and transactions of any public official and employee and are hereby declared
to be unlawful:
(a) Financial and material interest. Public officials and
employees shall not, directly or indirectly,have any financial or material
interest in any transaction requiring the approval of their office.
(b) Outside employment and other activities related thereto. Public
officials and employees during their incumbency shall not:
(1) Own, control, manage or accept employment as officer,
employee, consultant, counsel, broker, agent, trustee or nominee in any
private enterprise regulated, supervised or licensed by their
office unless expressly allowed by law;
(2) Engage in the private practice of their profession unless authorized
by the Constitution or law, provided, that such practice will not conflict or
tend to conflict with their official functions; or

13.
Under Section 11 of the same Act, any public officer
committing the acts stated in Section 7 shall be punished with
an imprisonment of not exceeding five (5) years, or a fine not
exceeding five thousand pesos (P5,000), or both, and, in the
discretion of the court of competent jurisdiction, disqualification
to hold public office.
14.
Thus, it is very clear that by maintaining these corporations
running businesses in Puerto Princesa City, the respondent
committed also the crimes of violating Section 7(a) and Section
7(b) of RA No. 6713 for thirty-three counts.
15.
To serve the public good, the Office of the Ombudsman must
not let this pass unpunished.
16.
In this trying time when the citizens are bombarded with
munomental corruption acts in relation to the Priority
Development Assistance Fund (PDAF), Malampaya Funds and
other discretionary funds, which amount to tens of billions of
pesos that only went to the pockets, it is revolting to conscience
for Mr. Hagedorn to go scot-free and laughing all the way to the
bank.
IN WITNESS WHEREOF, I sign this Supplemental Amended
Complaint this 25 October 2013 in the City of Manila.

BERTENI TOTO CATALUA CAUSING

Affiant
Drivers No. NO2-94-24154, issued by LTO
SUBSCRIBED AND SWORN TO BEFORE ME this 25
October 2013 in the City of Manila, affiant manifested his
sufficient proof of identity written under his name.
Doc. No.: ___;
Page No.: ___;

Book No.: ___;

Series of 2013.