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hepublic of the PhiliPPines )

) S.S.City of IloiloX---- ------X

COMPLAINT.AFFII}AYIT

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

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

and state:

This is a criminal and administrative complaint against JEFFREY

CHRISTIAN E. MABILOG of Iloilo city for the following offenses:

r unexplained wealth under section 8, Republic Act No. 3019;

o Dishonesty;

r Perjury; and

. Grave misconduct and such other offlenses covered by

Republic ActNo. 3019 and Republic ActNo' 6713;

These offenses were commified by respondent, who holds the position of

Nurse IV, City Health Office, Iloilo City, in connection with his Statements of

Assets, Liabilities and Net Worth (SALN) for the year 2008, 2009,2010 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'

Golez is attached as Annex o'8";

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;

a) In the Articles of Incorporation, it is shown that respondent Jeffrey

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 ofP62,500.00;

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

complaint;

b) It should be noted that respondent Mabilog is the only incorporator

with paid up capital, giving rise to the presumption that he is the

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2.

a

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c)

d)

sole owner of the corporation and the other incorporators are merelyoodummies";

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 islisted as stockholder, director and Finance Officer (a photocopy ofwhich 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 traininginstitution 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 dulyaccredited 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 TESDA-Iloilo (a photocopy of which is attached as Annex 'oH" of thiscomplaint 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 ofP45,842.71for 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'lServices, 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 lonepaid-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 ofonly P62,500.00, it managed to generate equity for its operationsthrough o'Advances from Stockholders" in the amount ofPt,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 financialinterest and business investment in Victory Educ'l Services, Inc.

was NOT disclosed;

e)

-$N:As)

h)

i)

k)

tF"

D Such concealment of this substantial financial exposure to abusiness is a violation of Republic Act No. 6713, particularlySection 8 thereol as this corporation continues to be active as

shown by the latest filing of the General Information Sheet for theyear 2010;

m) More than an act of concealment, respondent Mabilog is liable forunexplained wealth or ill-gotten wealth;

n) Being a low-level public officer, respondent Mabilog could notpossibly afford to advance or lend the corporation P1,873,674.07which is indicated in its Balance Sheets for the years 2007 and

2008, hence, is presumed ill-gotten or unexplained pursuant toRepublic ActNo. 3019, Section 8;

o) As it is an advance, or loan, to the corporation, that amountnecessarily forms part of his assets, but was not disclosed as

mandated by Republic Act No.6713;p) Republic Act No.l379 raises the presumption that the

asset/investrnent is ill-gotten wealth as well, and should be subjectto confi scation proceedings;

q) In addition to the foregoing, respondent Mabilog should be indictedand prosecuted for dishonesty and perjury and grave misconduct forthese offenses;

r) Administratively, respondent Mabilog should be meted withadministrative suspension for the above offenses because of thestrong evidence against him while the preliminary investigation ison-going;

That I am executing this complaint affidavit for the purpose of attesting to thetruthfulness of the foregoing statements in support of this criminal and administativecomplaint against the respondent;

Further, affiant sayeth naught.

IN WITNESS ImREoF, I have hereunto set my hand this U&day of Augu st,2012, atIloilo City, Philippines.

FlftA(m rD# 1 .biss1|\

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

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satisfied that he voluntarily executed and understood his