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Republic of the Philippines

orFrcE oF THE OMBUD$mAN OI$AYAS)
Department of Agriculture RO-7 Compound, Ctuadalupe, 0600 Cebu City
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MAI\IUEL P. MEJORADA,
Complainant, -versus-

0MB-V-C-12-0077-B. oMB-V-A-12-0091-B

JED PATRICK E. MABILOG, City Mayor, ATTY. JOSE JT]NIO G. JACELA, Chairman, Bids & Awards Committee, OTHER BAC MNMBERS, All of the Iloilo City Govemment, 3'd Floor Robinsons Place, Iloilo City F.F. CRUZ & COMPANY,INC. (CRrM. CASE ONLY) FREYSSINf,T FILIPINAS, INC., JOINT YENTURA Both: Private Respondents, Brgy. Lapuz, Lapaz, Iloilo City,
Respondents.

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MOTION TO PLACE PUBLTG RESPONDENTS UHDER PREVEI{TIVE SUSPENSION
COMES NOW, Complainant, by himself, and unto this Honorable Office respectfirlly avers that:

l. On May 18,2012, public

respondent Jed Patrick E. Mabilog filed his counter-

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affrdavit to the above-captioned complaint, a copy of which was received by undersigned complainant on May 19, 2012; a. Within a period of l0 days, or on May 29,2012, complainant filed his Reply-Affidavit to the same before &is Honorable Office, copy furnished all the respondents by registered mail; On May 4,2012, public respondent Jose Junio G. Jacela, for himself and on behalf of the Bids and Awards Committee (BAC) members, filed his counteraffidavit to the above-captioned complaint after which complainant filed his Reply-Affidavit dated lvlay 17,2012 before this Honorable Office, copy firnished all the respondents by registered mail; Until this date, none of the public respondents have filed their RejoinderAffrdavits which the Rules of Procedure of this Honorable Office affords them to

E.

refute or contavene issues raised in complainant's Reply-Affidavit, and the 10day period for this purpose has lapsed;
4. Public respondents having waived their right to file Rejoinder-Affidavits

within

the prescribed 10-day period, the issues raised in this complaint are deemed to have been joined, and this Honorable Office can henceforth proceed to evaluate the evidence on record; 5. This case involves issues of (a) dishonesty, grave misconduct, neglect in the performance of duty, (b) the charges would warrant dismissal from the service, and (c) the respondents' continued stay in office would prejudice the case filed
against them; 6. The evidence on record establishes strong evidence, or even incontrovertible

evidence, that the offenses for which the public respondents are charged have indeed been committed;

PRAYBR
WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Office to issue an Order placing public respondents JED PATRICK E. MABILOG, JOSE JLINIO G. JACELA and members of the BIDS AND AWARDS COMMITTEE, namely: KARL QUIMSING, JESS SIO, JOY ANN TOLEDO and AGUSTIN SANGRADO& JR. under PREYENTTVE SUSPENSION in accordance with Section 24 of Republic Act No.6770.
Other reliefs just and proper are also prayed.

RESPECTFULLY SUBMITTED. June 15, 2Al2,Iloilo City for Cebu City, Philippines.

Copy furnished:

Jed Patrick E. Mabilog

Crty Mayor,Iloilo City Hall De la Rama St., Iloilo City RegisfiyNumber: Date and Place:

Jose Junio G. Jacela and

BAC members City Legal Officer,Iloilo City Hall De la Rama St., Iloilo City Registry Number:
Date and Place:

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