1

Republic of the Philippines

OFFICE OF THE OMBUDSMAN
Quezon City

________________________,
________________________,
________________________,
________________________,
Complainants,
OMB Case No.
- Versus -
For: Violation of the Anti-Graft
and Corrupt Practices Act.
Direct and Indirect Bribery
Under Articles 210 and 211
of the Revised Penal Code
(Criminal Offenses)

Malfeasance, Dishonesty,
Grave Misconduct
(Administrative Offenses)
DEPUTY COMMISSIONER DELILAH
F. DELES,
Deputy Commissioner of the
NATIONAL TELECOMMUNICATIONS
COMMISSION (NTC) and concurrently
The REGIONAL DIRECTOR, NTC,
National Capital Region,
Respondent.
X * * * * * * * * X

COMPLAINT – AFFIDAVIT

WE, _______________________, ______________________,

___________________________, of legal ages, Filipino Citizens and
with office address at ________________________________________,
under oath, depose and state:

PREFATORY STATEMENT

We run to the Ombudsman to complain, expecting it to use all its powersand

resources to unearth the evil whose surface we have barely scratched.There are,
no doubt, many more pieces of evidence that are beyond theaccess of ordinary
citizens or even legislators like herein complainants. Wetrust that this complaint
will be appreciated not only for the substance that italready contains, but the
potential avenues that it opens for investigationand prosecution of those who
would steal from the poor.The time for reckoning is now. Let those who sowed
corruption now reapthe consequences of their actions.

1. We, (names of complainants and respective government positions);

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2. The Respondent, DEPUTY COMMISSIONER DELILAH F.

DELES, is of legal age, Filipino Citizen, is the Deputy Commissioner of the
NATIONAL TELECOMMUNICATIONS COMMISSION (NTC for brevity)
and concurrently the REGIONAL DIRECTOR of the NTC, National Capital
Region, Metro Manila and with office address at BIR Road, Diliman,
Quezon City, Metro Manila;

2. The parties may be served with subpoenas and other legal

processes of this Honorable Office at their above-given respective addresses;

3. Respondent is liable for Corrupt Practices of Public Officers

under pertinent provisions of Republic Act No. 3019 more known as the
Anti-Graft and Corrupt Practices Act.

3.1. Preliminarily, a Public Officer includes elective and appointive

officials and employees, permanent or temporary, whether in the classified
or unclassified or exempt service receiving compensation, even nominal,
from the government (Sec. 2, sub-paragraph [b], R.A. No. 3019).
Respondent, being a Deputy Commissioner of the NTC and concurrently
the Regional Director of the NTC, National Capital Region, Metro Manila,
undoubtedly, squarely falls within the definition of a Public Officer under
said Law.

3.2. Certainly, it is not amiss to state that nature and character of

the functions, duties and powers of the Respondent as Deputy
Commissioner of the NTC or by nature and character of said functions,
duties and powers attached to his Office and / or Government Position, she
has, indubitably, by law, the vested power to intervene in his official
capacity on behalf the Government or the NTC, with any contract,
transaction or dealings with private persons or entities relative to the
application, acquisition and grants of NTC permits, licenses or
concessions;

3.3. That for the span of about six (6) years reckoned from the time
respondent assumed the Position of NTC Deputy Commissioner up to that
point when she occupied the position of NTC, NCR Director concurrently as
NTC Deputy Commissioner, respondent have been receiving cash/money
allowances from one William Tieng in consideration of favours being asked
by William Cheng, which are, the issuance of Broadcasting Licenses from
the NTC with the intervention, complicity and intercession of respondent in
the grants and issuances of the desired NTC permits and / or licenses by
William Tieng, who, conspicuously and prominently, is the Chairman of
SOLAR ENTERTAINMENT, a well-known Private Media Broadcast entity.
The variable substantial amounts representing said allowances ranging
from Two Hundred Thousand Pesos (P200, 000.00) to Three Hundred
Thousand Pesos (P300, 000.00) written and recorded in yellow pad
papers are hereto attached as Annexes “A”, “A-1” “A-___” “A-___” and
“A-____” and are made indispensable parts of this Complaint-Affidavit;
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3.4. Strong and trusty source bear out that said allowances in
variable amounts for checks preparation were prepared by Wilson Tieng’s
Chief Finance Officer, copy of which were given to one Attorney Ramos,
respondent’s alleged ‘bagwoman’ who received said amounts for and in
behalf of respondent albeit the variable amounts were meant for and
intended for respondent who ultimately received the same;

4. That the afore-named William Tieng is likewise the Owner of

DOMSAT PHILIPPINES, a Domestic Satellite Philippine based corporation
and SBN TV 21, a subsidiary of the afore-mentioned SOLAR entertainment
of which William Tieng is also the owner;

4.1. SOLAR ENTERTAINMENT has full block time agreement with

RJ TV-29 with 60-kilowatts transmitter in Antipolo City which is simply
beyond the 25 Kilowatts limit allowable by NTC existing regulations. Said
SOLAR ENTERTAINMENT full block time agreement with RJ TV-29 at 60-
kilowatts transmitter was made possible expedient through the intervention
and complicity of respondent in consideration of variable and substantial
amounts given to, and received by respondent;

4.2. That William Tieng has interest in VTV, also a Private Media
Broadcast entity owned by one Bobong Velez. William Tieng operates said
VTV under Telered Technologies Services Corporation situated in Antipolo
City on his own with the consent and acquiescence of respondent, without
procuring the requisite NTC Permit and/or License in patent and brazen
violation of NTC regulations and pertinent Radio Laws;

4.3. That further, William Tieng has interest in Byers

Communications, Inc., a Holder of NTC PA for TV-22 whose franchise
would expire come year 2020 pursuant to R.A. 8107 which is the Law that
granted Byers franchise to operate broadcasting and television stations
within the National Capital Region and Central Visayas Region. Through
the intervention and complicity of respondent, William Tieng uses said
franchise of Mr. Velez with Atty. Roman as the conduit and trusty sources
have it that last year, 2015, Two Million in cash was given to Congressman
Madrona of Romblon to fast track the renewal of said franchise as Mega
Franchise albeit the total amount promised to Congress was Seven Million
Pesos;

4.4. SBN owned by William Cheng operates UHF TV in Cebu and

Davao with TV Transmitter Power of 30 Kilowatts beyond the allowable 10
Limit Kilowatts in clear violation of pertinent NTC Regulations and Radio
Laws with the intervention and complicity of the respondent in
consideration of substantial variable amounts of money given to, and
received by respondent;

5. That respondent, in utter denigration and debasement of her

Office receives gifts from broadcasters and broadcasting operators, e.g.
pearl bracelet with diamond from a certain Tiffany and a New Vehicle, CRV
given by a favoured TELCO Operator;
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6. For every conventions (National Association of Broadcasters)

abroad on conventions relative to broadcast, respondent was given travel
allowances ranging from US$3,000 to $10,000.00 and from small media
networks, he was given US$500 to $2,000.00 travel allowances. These
amounts are besides her round trip airfare provided by said networks.
Regrettably however, respondent’s attendance in said conventions would
be brief as she would leave the official engagement and go on shopping
spree wherein the items she purchase are brought to Los Angeles,
California, U.S.A. where his husband resides;

7. That the afore - narrated actuations of respondent constitutes

Violation of REPUBLIC ACT No. 3019 more known as the ANTI-GRAFT
AND CORRUPT PRACTICES ACT, to wit:

Section 3. Corrupt practices of public officers. In addition to acts or

omissions of public officers already penalized by existing law, the following shall
constitute corrupt practices of any public officer and are hereby declared to be
unlawful:

(b) Directly or indirectly requesting or receiving any gift, present, share,

percentage, or benefit, for himself or for any other person, in connection
with any contract or transaction between the Government and any other
part, wherein the public officer in his official capacity has to intervene
under the law.

(c) Directly or indirectly requesting or receiving any gift, present or other

pecuniary or material benefit, for himself or for another, from any person
for whom the public officer, in any manner or capacity, has secured or
obtained, or will secure or obtain, any Government permit or license, in
consideration for the help given or to be given, without prejudice to Section
thirteen of this Act.

xxx

(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. This
provision shall apply to officers and employees of offices or government
corporations charged with the grant of licenses or permits or other
concessions.

xxx

(h) Directly or indirectly having financial or pecuniary interest in any

business, contract or transaction in connection with which he intervenes or
takes part in his official capacity, or in which he is prohibited by the
Constitution or by any law from having any interest.

(j) Knowingly approving or granting any license, permit, privilege or

benefit in favor of any person not qualified for or not legally entitled to
such license, permit, privilege or advantage, or of a mere representative or
dummy of one who is not so qualified or entitled.
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8. That respondent, Delilah Deles is criminally liable for Bribery and /

or Indirect Bribery under the Revised Penal Code.

8.1. For purposes of said Crimes, respondent is a Public Officer, defined

under the Revised Penal Code as - any person who, by direct provision of
law, popular election or appointment by competent authority, shall
take part in the performance of public functions in the Government of
the Philippines, or shall perform in said Government, or in any of its
branches public duties as an employee, agent, or subordinate official,
of any rank or class.

8.2. That as may be culled from the preceding narrations, the said
actuations of respondent constitute Direct Bribery since she committed acts
constitutive of a crime or not and whether or not the acts in consideration of
which the bribe was given was accomplished or not, penalized under
Art. 210 of the Revised Penal Code which pertinently provides in part, viz:
– Bribery Art. 210. Direct bribery. – Any public officer who shall agree to
perform an act constituting a crime, in connection with the performance
of his official duties, in consideration of any offer, promise, gift or present
received by such officer, personally or through the mediation of another, x x
x. If the gift was accepted by the officer in consideration of the execution
of an act which does not constitute a crime, and the officer executed
said act, x x x. and if said act shall not have been accomplished, x x x.;

8.3. That the money considerations and favors given to respondent

as narrated in the preceding segments of this Complaint-Affidavit were
given to and received by her by reason of his Office, thus constituted
Indirect Bribery under Art. 211 of the Revised Penal Code which pertinently
provides, viz: Art. 211. Indirect bribery. – The penalties of prision
correctional in its medium and maximum periods, suspension and public
censure shall be imposed upon any public officer who shall accept gifts
offered to him by reason of his office . In indirect bribery, it is not
necessary that the officer should do any particular act or even
promise to do an act, as it is enough that he accepts gifts offered to
him by reason of his office. (GREGORY JAMES POZAR Vs. THE
HONORABLE COURT OF APPEALS, G.R. No. L-62439, October 23,
1984; citing: The Revised Penal Code by Luis P. Reyes, 1975 Ed., p. 332)

9. That taken as whole, respondent’s afore-narrated actuations

comprised an Administrative offense of Grave Misconduct since obtaining
from her acts are the elements of: corruption, clear intent to violate the
law or flagrant disregard of established rule. MONICO K. IMPERIAL,
JR. Vs. GOVERNMENT SERVICE INSURANCE SYSTEM,
G.R. No. 191224, October 4, 2011);

10. That in the same vein,

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of legal age, Filipino andwith office address at Room MB2, House of

Representatives, Batasan, QuezonCity, where subpoena and other processes
may be served upon her. She is theformer President of the Republic of the
Philippines during the period of 2001 toJune 30, 2010 and a public official with
Salary Grade 33. Currently, she is aMember of Congress representing a
district in Pampanga.1.2 MS.
ROSARIO URIARTE
of legal age, Filipino and with officeaddress at No. 27-A Scout Lozano St.
Barangay Paligsahan, Quezon City, wheresubpoena and other processes may
be served upon her. She is the formerGeneral Manager of the Philippine Charity
Sweepstakes Office (“PCSO” forbrevity) during the period January 17, 2003, to
July 30, 2010, and even becameconcurrent chair of the agency from April 19,
2004, to August 29, 2004, at thattime a public official with salary grade above
Salary Grade
27.2. As a preliminary, it must be pointed out that under Section 1 of the PC
SOCharter, the PCSO Board of Directors is composed of only 5 members to be
appointedby the President to wit:
"It shall have, a Board of Directors, hereinafter designated the Board,
composed of five members who shall be appointed, and whose
compensation and term of office shall be fixed, by the President

.3. In relation to this, Section 2 of the same Charter provides that the
GeneralManager of the PCSO is a mere appointee of the Board, thus

Sec. 2. The general manager shall be appointed by the Board of Directors

and he can be removed or suspended only for cause as provided by law.”
4. However, Ms. Uriarte assumed the position of Vice-Chairman, and
evenserved as its concurrent co-chairman, when she was supposed to be a
mere appointeeof the Board and therefore accountable to the said
Board. Her assumption of thisposition together with her admitted
closeness to then President Arroyo is not only aclear violation of the PCSO
charter because she is not even a member of the Board butplaced her in a
powerful position within the PCSO hierarchy as both a vice-chairman ofthe
Board and its General
Manager.4.1 Relevant to this, Ms. Uriarte admitted on national television d
uringthe Senate investigation on 7 July 2011 her personal ties to the
President, sayingthat she is personally “close” to then President Arroyo
and has been working forher in various capacities since she (Arroyo) was
an undersecretary of theDepartment of Trade and Industry in the 1990s.
Perhaps, this may explain theappointment of Ms. Uriarte as PCSO General
Manager, Vice-Chairman, andlater, as the lead implementor of its
intelligence fund. [Attached as Annex “A” is acopy of the news report on
her closeness to then Pres.
Arroyo]5. Such usurpation of powers by both Rep. Arroyo and Ms. Uriarte
is not onlyhighly irregular and illegal. It also granted Arroyo and Uriarte
substantial power andcontrol inside
PCSO.6. On 30 May 2011, Rep. Colmenares exposed in a privilege speech
anumber of irregularities and anomalies inside the PCSO during the
previousadministration. These include PCSO entering into contracts with
the Philippine Gamingand Management Corp.(PGMC) on the rent of
overpriced lotto machines and a 50-yearcontract on thermal paper
production both of which are highly disadvantageous to thePhilippine
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government. He also discussed in that privilege speech the bloated

mediafund not only the reported 40% commission from media advertisers
but also therealignment of media fund to intelligence fund, and the
approval of then PresidentArroyo of the said realignment, without a board
resolution approving the amendment tothe duly approved budget of the
PCSO.7. The PCSO scandal would soon escalate and other anomalies the
reinwere exposed by other sectors of society and the media, thereby urging
the Senate ofthe Philippines to conduct its own investigation.
PRESIDENT ARROYO AND MS. URIARTE VIOLATEDARTICLE 220 OF
THE REVISED PENAL CODE
8. Article 220 of the RPC provides:
“Art. 220. Illegal use of public funds or property. — Any public officer who
shall apply any public fund or property under his administration to any
public use other than for which such fund or property were appropriated by
law or ordinance shall suffer the penalty of prision correccional in its
minimum period or a fine ranging from one-half to the total of the sum
misapplied, if by reason of such misapplication, any

damages or embarrassment shall have resulted to the public service.

In either case, the offender shall also suffer the penalty of temporary
special disqualification.
President Arroyo and Ms. Uriarte are public officers
__________________________ 9. As heretofore alleged, President Arroyo
and Ms. Uriarte are both publicofficers. Arroyo is the former President of
the Republic of the Philippines during theperiod of 2001 to 30 June 2010
with Salary Grade 33, while Uriarte is the formerGeneral Manager of the
PCSO during the period of 2004 up to 30 June 2010 with salarygrade above
Salary Grade 27.
Uriarte requested for and President Arroyo gave her a total of P325
Million for her administration as intelligence/confidential fund,
including the realignment of at least P150 Million of the media fund in
the 2010 PCSO budget to “intelligence
fund”. _____________________________________
10. Under the PCSO Charter,
the PCSO Board approves its budget for thefiscal year containing its
projected expenses and sources of funds.11. In relation
to this, it was uncovered that as PCSO General Manager Ms.Uriarte issued
a total of eight (8) memoranda / letter requesting former President
Arroyothat her office be given intelligence/confidential fund. The copies of
said Memoranda / Letter are hereto attached as ANNEXES “B” to
“I”.11.1 The total amount of intelligence/confidential fund given
to Ms.Uriarte from 2008 to 2010 totaled
P325 Million
. These documents show that theywere all signed and/or approved by
President Arroyo.11.2 Significantly, the Memorandum dated 4 January
2010 issued byUriarte requesting President Arroyo for intelligence fund
suggested to thePresident that “
the General Manager’s Office be given at most, twentypercent (20%)
of the Public Relations Fund or a minimum of 150 MillionPesos, to be
used as intelligence/confidential fund
.” (ANNEX “H”). This latestrequest has the largest amount involved
among the other intelligence/confidentialfund requests since 2008. GMA
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approved the same as shown in her “OK” inrequest letters themselves.11.3

It must be noted that Ms. Uriarte presented no PCSO Boardresolution
allowing the realignment of the PCSO budget or any authority thatwould
allow Ms. Uriarte to request for such
realignment.12. During the Senate investigation
on 7 July 2011, [Attached as annex “J” isa copy news reports on her
testimony] Ms. Uriarte confirmed the accuracy of the

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contents of the above-mentioned documents, when she admitted under
oath before theBlue Ribbon Committee and on national television,
that:12.1 She indeed submitted a Memorandum-request
to President Arroyoon 4 January 2010 for the realignment of the budget for
media or advertisingexpenses from its operations budget to “intelligence”
fund;12.2 She personally submitted at least two Memoranda-
requests to thenPresident Arroyo and discussed the contents with
her.12.3 President Arroyo approved her request for realignment
of fundsfrom the operating expense to the “intelligence” fund, as she
personallywitnessed the signing thereof by President
Arroyo.12.4 She is the project proponent
of the said intelligence fund.12.5 She has custody of the said funds and
was a signatory of thechecks for the release of the same funds, and was
the payee of the said funds.This admission is also proved by the checks
themselves, which shows thatUriarte was both the payee and
signatory/payor of the said check. (Samples ofsuch checks are attached
as ANNEXES “K” and “L”).13. Ms. Uriarte encashed said checks and
disbursed the same.14. The realignment of the P150 Million public relation
or media fund wasintended for appropriating it for intelligence work.
Diverting funds from the operationalexpense, which is subject to regular
auditing, to intelligence fund which is not subject toregular auditing,
clearly exposes the intention of both Arroyo and Uriarte to disbursesaid
funds without the benefit of regular auditing scrutiny, in violation of our
laws.
President Arroyo and Uriarte conspired in using the intelligence fund
for use other than intelligence
work. _____________________________________
15. During the Senate investigation on 7 July 2011, Uriarte also admittedu
nder oath before the Senate Blue Ribbon Committee and on national
television thatbefore President Arroyo approved the realignment of funds,
the latter was already verymuch aware that the “intelligence fund” will not
be used for intelligence work but for: (a)work to “roll out” the Small Town
Lottery (“STL”) all over the country, (b) “reliefoperations” during calamities,
and (c) payment for “blood money” to save OFWsimprisoned abroad. This
is so because according to Uriarte, she personally discussedthe same with
President Arroyo during the times that she asked for the approval of
herletter-requests.16. However, despite such knowledge, President Arroyo
still approved therealignment of
funds.17. The illegal motivation of President Arroyo is clear. Despite know
ledge thatsaid intelligence fund will not be used for intelligence work, she
kept on approving the

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various requests of Ms. Uriarte for the grant and realignment of funds to
this phantomintelligence fund project for
years.18. In view of the foregoing, it is very clear that President
Arroyo and Uriarteconspired in using the intelligence fund for purposes
other than intelligence work. This isso because Uriarte could not have
committed the illegal use of such intelligence fundhad President Arroyo not
approved the realignment of funds despite the latter’sknowledge that the
same will not be used for intelligence work. In this regard,
GLORIAMACAPAGAL-ARROYO
and
ROSARIO URIARTE
should be charged and should beheld liable for violating Article 220 of the
RPC.
PRESIDENT ARROYO AND URIARTE MAY ALSO BE HELD
LIABLEFOR VIOLATION OF ARTICLE 217 (4) OF THE REVISED PENAL
CODE
19. Article 217 (4) of the Revised Penal Code provides that:
“Art. 217. Malversation of public funds or property.— Presumption of
malversation.—Any public officer who, by reason of the duties of his office,
is accountable for public funds or property, shall appropriate the same, or
shall take or misappropriate or shall consent, or through abandonment or
negligence, shall permit any other person to take such public funds or
property, wholly or partially, or shall otherwise be guilty of the
misappropriation or malversation of such funds or property,
shall suffer: …The failure of a public officer to have duly forthcoming any
public funds which he is chargeable, upon demand by any duly
authorized officer, shall be prima facie evidence that he has put such
missing funds or property to personal use.
19.1 Under paragraph 4 of the same Article, if the
amount involvedexceeds P22,000.00, the penalty shall be reclusion
temporal in its maximumperiod to reclusion perpetua (as amended by RA
1060.)20. The questioned funds were malversed and appropriated by both
PresidentArroyo and Ms. Uriarte for themselves as provided under Art.
217. They have failed topresent any accounting of the said funds as
Uriarte merely claimed that her “one andonly copy” of her report
was with President Arryo. The P150 Million fund, disbursed afew months
before the 2010 elections will most likely have been used in the
elections.This is malversation and appropriation for gain and benefit of
President Arroyo. As toUriarte, the fact that she cleaned out almost all the
intelligence funds for the year in thefirst 6 months of 2010, and even
withdrew P2.5 million and P10 million on June 18,2010 only 12 days before
her term ends on June 30 (as shown in the Senate hearing)only shows the
intent to malverse said funds for their benefit.

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24.1 According to Section 1 (d) of RA 7080, ill-gotten wealth means:
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“Section 1. Definition of Terms. – As used in this Act, the term – …d) Ill-
gotten wealth means any asset, property, business enterprise or material
possession of any person within the purview of Section Two (2) hereof, acquired
by him directly or indirectly through dummies, nominees, agents, subordinates
and / or business associates by any combination or series of the following means
or similar
schemes: 1. Through misappropriation, conversion, misuse, or malversation of
public funds or raids on the public
treasury; 2. By the illegal or fraudulent xxx disposition of assets belonging to the
National government or any of its agencies or xxx government-owned or
controlled corporations;
and 3. By taking undue advantage of official position, authority xxx or influence
to unjustly enrich himself or themselves at the expense and to the damage and
prejudice of the Filipino people and the Republic of the Philippines”.
25. The funds, amounting to more than 50 Million pesos, were malversed anda
ppropriated by President Arroyo and Ms. Uriarte for themselves and their
personalgain as provided under Art. 217 of the Revised Penal Code. Both
committed a series ofovert acts, as provided above through (i) conversion or
misuse, (ii) disposition of assetsand (iii) taking undue advantage of official
position. They should be charged, for theiracts, with the crime of plunder under
RA 7080 or the Plunder Law.
OTHER ANOMALIES IN THE PCSO SHOULD BE INVESTIGATED BY
THEOMBUDSMAN
26. PCSO throughout
the years has increased its budget and spending formedia and advertising
expenses during the time of Uriarte. That in 2007 it has incurredan Media or
PR expense in the staggering amounts of P686,900,486 Million; in
2008P529,449,558 Million; and in 2009 P1.5
Billion.27. This inordinate amount of budget allotted and spent for advertising, a
nitem under the Operating Fund of the PCSO budget, was subject of a
Commission onAudit (COA for brevity) review. The COA, in its Annual Audit
Reports AS EARLY AS2005, found recurring problem in the presence of
deficiencies in the advertisingexpenses of PSCO, where disbursement vouchers
differed with the amounts in thesupporting documents, as well as onerous and
unchecked and unmonitored advertisingcontracts and deals. The COA remarked
that:
“PCSO is not engaged in the marketing of consumer products that requires
extensive advertising to increase customer awareness and sales nor is there a
competition factor to contend with. While these advertisements intend to promote
patronage of sweepstakes tickets and lotto games, it is expected of management
to always count the costs in carrying out this objective. The number of
advertisements placed has to

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be carefully planned, evaluated and limited to what is just enough
and necessary.Considering PCSO’s mandate to raise funds for health and
charity programs, instead of spending on advertising expenses, a portion
could have been used more meaningfully for charity. If advertising expenses
are reduced to even only about 50 percent of the current year amount, at
the minimum financial assistance of P10,000 each, at least an additional 35,850
indigents could have directly benefited. These beneficiaries will be the best
medium to promote the revenue generating activities of PCSO because the
public becomes aware that the funds generated are used to provide
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financial/medical assistance to poor and needy patients.Prospective bettors will

be made aware that they do not only have the chance to win but, at the same
time, they are helping provide necessary funds for financial/medical assistance to
indigents.”
(ANNEXES “M” to “M-4” – Paragraph 11.6-11.7, pages 71-72 of the Annual
Audit Report on thePCSO For the year ended December 31, 2008)28. Clearly,
the media fund of PCSO enjoys hefty funding and one that isconstantly
unmonitored and highly untransparent with its accounting, despite
constantreminders from COA. Thus, it would not be outside the mandate of the
HonorableOmbudsman to also conduct an investigation on the foregoing matter,
including theanomalous contracts mentioned above and in Rep. Colmenares’
privilege speech,Arroyo’s highly irregular and illegal act of appointing Uriarte as
General Manager of thePCSO and the subsequent illegal assumption of Uriarte
as Vice-Chairman of the PCSOBoard, and thereafter, file appropriate charges
against Arroyo and Uriarte for anyviolation of the law.

29. We ask the Ombudsman to immediately order the sequestration of alldocu

ments, including the liquidation reports, if any, submitted to then COA
ChairmanReynaldo Villar, pertinent to the PCSO anomalies. We also ask the
Ombudsman toimmediately conduct a lifestyle check on both respondents Arroyo
and Uriarte includingthe monitoring of their assets and bank accounts including
the freezing of their accountsif necessary.30. We are executing this Complaint-
Affidavit to attest to the truth of theforegoing and to charge Arroyo and Uriarte of
the crimes mentioned and discussedabove.
IN WITNESS WHEREOF
, we have hereunto affixed our signatures this 12
th
dayof July 2011 at Quezon City, Philippines.
REP. TEDDY CASIÑO

REP. NERI JAVIER COLMENARES

Bayan Muna Representative Bayan Muna RepresentativeComplainant-Affiant
Complainant Affiant

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SUBSCRIBED AND SWORN TO before me this 12
th
day of July 2011 at QuezonCity, Philippines. I hereby certify that I have personally
examined the affiants and I amsatisfied that they read and understood the
contents of their affidavit and that they havevoluntarily executed the same.
INVESTIGATING PROSECUTOR