REPUBLIC OF THE PHILIPPINES)

CITY OF DAVAO ) S.S.

x----------------------------------------------x

AFFIDAVIT of COMPLAINT
(Malversation; Violation of R.A. 3019)

I, SEAN SANTOS, Filipino citizen, of legal age, single, and a resident of

Brgy. Sasa, Davao City, after having been duly sworn in accordance with
law, hereby depose and say:

1. That I am employed at the Sanggunian Panglungsod as Chief of Staff of

City Councilor Lexi Hirangdayang of 1st District of Davao City;

2. That on January 10, 2020, City Councilor ANTON SERA made it appear
that the City Council met in session and passed a city ordinance
appropriating P 80,000,000.00 for a flood wall project in the bank of
canal in agdao market area;

3. That pursuant to said purported ordinance, Councilor ANTON SERA,

together with City Treasure MIKO BESAVILLA, prepared a labor payroll
for the period January 16-25, 2020 indicating therein that certain
individuals, namely, Brader Sam miguel and Eliseo Te, have worked and
finished the canal drainage work;

4. That said barangay officials Tanggal and Ayos withdrew and disbursed
from the City Council funds the amount of P80,000,000.00 supposedly
for the flood wall project:

5. That the City Council had not convened in session nor passed the
aforesaid ordinance on January 8, 2020 for the purpose of
appropriating P80,000,000.00;

6. That no flood wall project was undertaken by the barangay in January,

2020,

7. That I am charging City Councilor ANTON SERA and City Treasurer MIKO
BESAVILLA for the commission of the crimes of Malversation of Public
Funds thru Falsification of Public Documents and the Anti-Graft and
Corrupt Practices Act (RA 3019).
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IN WITNESS WHEREOF, I have hereunto set my hand this 5 th day of

March 2020 at Davao City, Philippines.

SEAN SANTOS (sgd)

Affiant

SUBSCRIBED AND SWORN TO me, in the City of Davao, this 13th day
of December, 2019 by Mr. Aegon Targaryen, with PRC ID No. 696969 valid
until June 10, 2022 bearing his photograph and signature as competent
proof of his identity.

LYNDZELLE RAMONA IRVINA OLACO VIII (sgd)

Prosecutor
DAVAO CITY
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REPUBLIC OF THE PHILIPPINES)

IN THE CITY OF DAVAO ) S.S.
x-----------------------------------------x

VERIFICATION/CERTIFICATION OF NON-FORUM SHOPPING

I, SEAN SANTOS, of legal age, Filipino, single and a resident of Davao

City, after having been sworn to in accordance with law, hereby depose and
say:

1. That I am the Affiant/Complainant in the above-entitled case;

2. That I have caused the preparation of the foregoing Complainant,

have read and understood the same, and attest that all the
statements are true and correct to the best of my personal
knowledge and/or authentic documents;

3. That I hereby certify that (a) the Plaintiff and I have not commenced
any other action involving the same issue in the Supreme Court, the
Court of Appeals or any other tribunal or agency; (b) to the best of
my knowledge, no such action or proceeding which is either pending
or may have been terminated, I must state the status thereof; and (d)
if I should thereafter learn that a similar action or proceeding has
been filed or pending before the Supreme Court, Court of Appeals or
any other tribunal or agency, I undertake to report the same within 5
days therefrom to the court or agency wherein filed.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 15 th

day of January 2020, Davao City, Philippines.

SEAN SANTOS (sgd)

Affiant

SUBSCRIBED AND SWORN to before me this 18th day of March 2020

at Davao City, Philippines, affiant exhibited to me her SSS ID No. 09-

WITNESS MY HAND AND NOTARIAL SEAL on the date and place

above written.

Doc. No. _____;

Page No. _____;
Book No. _____;
Series of 2020
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