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List of documents for second impeachment complaint vs. Ombudsman

List of documents for second impeachment complaint vs. Ombudsman

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Published by Teddy Casino
A list of documents submitted to the House Committee on Justice for the impeachment complaint filed by Bayan, et. al.
A list of documents submitted to the House Committee on Justice for the impeachment complaint filed by Bayan, et. al.

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Published by: Teddy Casino on Mar 02, 2011
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03/02/2011

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February 28, 2011
Hon. NEIL C. TUPAS, JR.ChairmanCommittee on Justice
Dear Chairman Tupas:
COMPLIANCE
Greetings  to the  Chairman and  members of  the  HonorableCommitttee on Justice.The undersigned Complainant and Endorser, in compliance withand pursuant to Rule III Section 5  of the Rules of Procedure  onImpeachment of the 15
th
Congress,  respectfully submit  the affidavitsof  complainants  and  their  witnesses  including  the  attacheddocumentary evidence,  and a list of the witnesses and document wehave or will be submitting to or presenting before this HonorableCommittee  in  support  of  complainants'  Impeachment  Complaintagainst Ombudsman Merceditas Gutierrez and in rejoinder to anyanswer or defense of the respondent Ombudsman:
1) Documents in relation to the General Allegations:
a)
Sworn  Statement  of  Mr.  Renato  Reyes  Jr.  as  to  theImpeachment Complaint and the grounds thereto.   Mr. Reyeswill testify as a witness on the same, as well as the othercomplainants.
2)
Documents-evidence in relation to the Fertilizer Fundscam
a)
KMP et al. Complaint with Annexes A to A-5, B, Annex C, D, Eprefaced by the Sworn Statements of Mr. Danilo Ramos and Atty.Jobert Pajilga
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b)
Sandiganbayan Certification that no complaint has been filed bythe Ombudsman against Jocelyn “Jocjoc” Bolante and Luis “Cito”Lorenzoc) Senate Report (Blue Ribbon Committee) on the Fertilizer Scamd) Senate Report 254e) Senate Report 54
f)
Sworn Statement of  former Solgen  Francisco Chavez with hisComplaint for Plunder together with its attached evidentiarydocuments.Attached to his sworn statement:a. Amended Complaint-Affidavit dated May 26, 2004 for plunderagainst Pres. Arroyo et al in relation to P 728M GMA Fund Scamb. Manifestation dated 31 May 2004  identifying Bolante as JohnDoe mentioned in the complaintc. Complaint-Affidavit dated June 8, 2004  - Second Plundercharge against GMA et al in relation to the 1,102,391,000 GMAFund scam in addition to the 728Md.  Complaint-Affidavit dated 25 June 2004 Plunder chargeagainst GMA et al in relation to “Oplan Mercury” involving NFA,DA, PAGCOR and DOHe.  Complaint-Affidavit dated 20 July 2004 - Plunder chargeagainst GMA et al for misuse of OWWA Fundsf. and f-1.   Motion to Recuse and Follow-up letter to OmbudsmanMarcelo to inhibit from investigating/hearing the caseg.  Letter to Ombudsman for Luzon dated 27 August 2004  askingfor update on the plunder chargesh. Letter from Ombudsman for Luzon dated 02 September 2004informing  Atty.  Chavez  that  Marcelo  inhibited  himself  frominvestigating/hearing the plunder casesi.  Letter dated 02 December 2004 asking for an update on theplunder chargesJ. to J-2, letter from Ombudsman with 2 pages attachmentregarding the office’s action plans on the plunder chargesk.  Letter dated 29 November 2005 to follow up on the actionplanl.  12 December 2005 letter from the Ombudsman informing Atty.Chavez that the plunder complaints were returned to the CentralOffice as Marcelo resignedm.  Letter dated 21 December 2005 with Atty. Chavez informingthe Ombudsman that it made him wait for nothingn.  Letter dated 03 February 2006 to Sen. Magsaysay
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o.  Reply letter of Sen. Magsaysay dated 08 February 2006p. Senate Committee Report No. 54 dated 01 March 2006p-1.  Transmittal letter of Senate Committee Report No. 54 to theOmbudsmanq.  COA Report on the audit of the 728 M GMA Fundsr.  Motion to require Respondents to Submit Counter-Affidavits.   Filed  Investigation  Office  report  dated  20  June  2006recommending the filing of criminal and administrative casesagainst Jocjoc et alt.  Consolidated Report of FIO dated 20 July 2006 recommendingthe filing of criminal and administrative charges against the localofficials of Butuan City and private individuals involved in the 728GMA Fund scamWitnesses for the Fertilizer Scam :
i)
Mr. Danilo Ramos, KMP Secretary General with hissworn statementii) Former  Solgen  Francisco  Chavez  with  his  swornstatementiii) Atty. Jobert Pahilga with his sworn statement
iv)
Other witnesses such as the farmers who did notreceive the supposed fertilizer  with their sworn statements;witnesses from the Commission on Audit  who will testify onthe  irregularities  in  the  Fertilizer  Fund  scam;  SenateCommittee Secretary to attest to holding of Committeehearings on the fertilizer scam and the fact that the Senatehas transmitted its  report to the Ombudsman together withtheir respective documents.
3) Documents in relation to the Euro Generals
a)
Sworn Statement of Complainant Ferdinand Gaite, SecretaryGeneral of COURAGE, on the case of the Euro Generals
b)
Senate Transcript of Stenographic Notes (TSN) containingadmissions of Gen. Eliseo de la Paz as to his failure to declarethat he was carrying more than US $ 10,000 cash out of thecountry and other related issuesc) Senate Report No. 229 (11/13/2008) and its annexes andattachmentsd) Central Bank Circular on the need to declare the carrying of currency in excess of US$ 10,000.00
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