Yu, Smile Christienne

Marquez, Josemaria Ignacio

Pabrua, Anna Karenina
Tangonan Julius Geoffreys

Republic of the Philippines

OFFICE OF THE OMBUDSMAN
Quezon City

Julius Geoffrey Tangonan, in his

personal capacity as a taxpayer
Complainant, Crim. Case No. _________

- versus -
For: Violation of RA 7080 (Plunder)
Senator Bong Revilla, et al,
Cambe as Chief of Staff of Sen.
Bong Revilla, Janet Lim Napoles,
Lim, De Asis, of JLN Corp.
Relampagos, Alet Nunez, Paule,
Bare of the Department of Budget
and Management

Respondents.
x------------------------------------------x

INFORMATION

The undersigned Ombudsman Prosecutor hereby accuses Senator Bong

Revilla, Napoles, Relampagos, Alet Nunez, Paule, and Bare, Cambe, as
Chief of Staff of BONG REVILLA, and Lim and De Asis as Directors of
Kaupdanan Para sa Mangunguma Foundation, Inc., of the crime of Plunder,
defined and penalized under R.A. No. 7080, as amended by Sec. 12 of R.A.
No. 7659, committed as follows:

1. On January 1, 2016, BONG REVILLA issued a memorandum (Annex

"A") requesting from the Department of Budget and Management that
funds from his Priority Development Assistance Fund or PDAF
amounting to P199,966,000.00 be allocated for “contracts to purchase
fertilizers” with Kaupdanan Para sa Mangunguma Foundation, Inc or
KPMFI a Non-Governmental Organization controlled by Janet Lim
Napoles under her Umbrella holdings organization JLN Corporation,
to be given to poor farmers to assist in farming. (Annex "C");
Yu, Smile Christienne
Marquez, Josemaria Ignacio
Pabrua, Anna Karenina
Tangonan Julius Geoffreys

2. Such request for funds from the Priority Development Assistance

Fund or PDAF to Kaupdanan Para sa Mangunguma Foundation, Inc,
was approved by the Department of Budgement and Management
through Janet Lim Napoles contacts namely Relampagos, Allet
Nunez, Paule, and Bare.

3. That Pursuant to their “contract to purchase fertilizers, BONG

REVILLA, issued 4 checks from his Priority Development Assistance
Fund, paying to Kaupdanan Para sa Mangunguma Foundation, Inc.
said 4 checks were issued on; a) February 1, 2016 for P49,999,000.00
Million. b) March 1, 2016 for P49,999,000.00 Million. c) April 1,
2016 for P49,999,000.00 Million. and d) May 1, for P49,999,000.00
Million pesos, and combining these with a total amount of
P199,966,000.00 Million Pesos way beyond the P50,000,000.00
threshold required crime of Plunder under Section 2 of R.A. 7080.

4. BONG REVILLA has custody of the said funds and was a signatory
of the checks for the release of the same funds, This is proved by the
checks themselves, which shows that BONG REVILLA payor (Annex
"B");

5. Said amount was not used for the purchase of fertilizers but actually
benefited all REVILLA, NAPOLES, RELAMPAGOS, ALET
NUNEZ, PAULE, and BARE, CAMBE, as Chief of Staff of BONG
REVILLA, and LIM and DE ASIS as Directors of Kaupdanan Para sa
Mangunguma Foundation, Inc through:

a) The commencement via "business propositions" with the

senator regarding his allocated PDAF; b) The creation and
operation of JLN-controlled NGOs to serve as "conduits" for
"ghost" PDAF-funded projects; c) The use of spurious receipts
and liquidation documents to make it appear that the projects
were implemented by her NGOs; d) The falsification and
machinations used in securing funds from the various
implementing agencies (IAs) and in liquidating disbursements;
e) The remittance of Sen. Revilla's PDAF for misappropriation;
and f) The remittance of RELAMPAGOS, ALET NUNEZ,
PAULE, and BARE, CAMBE, as Chief of Staff of BONG
REVILLA, and LIM and DE ASIS, of their commissions, by
JANET LIM NAPOLES, for their assistance in the this process
Yu, Smile Christienne
Marquez, Josemaria Ignacio
Pabrua, Anna Karenina
Tangonan Julius Geoffreys

to misappropriate the senator’s PDAF; g) the remittance of

Senator BONG REVILLA’s commission of at least
P99,983,000.00 from this scheme of his misappropriating the
senator’s PDAF.

CONTRARY TO LAW.

Manila, October 14, 2017.

JOANNE VELEZ
Ombudsman Prosecutor

WITNESSES

1. Juan Tamad 2. Maria Makiling

Yu, Smile Christienne
Marquez, Josemaria Ignacio
Pabrua, Anna Karenina
Tangonan Julius Geoffreys

CERTIFICATION

This is to certify that as shown by the records the undersigned, an

authorized officer, that there is a reasonable ground to believe that a crime
has been committed and that the accused is probably guilty thereof; that the
accused was informed of the complaint and of the evidence submitted
against her and was given an opportunity to submit controverting evidence.

JOANNE VELEZ
Ombudsman Prosecutor

SUBSCRIBED AND SWORN to before me, this 15th of October 2017 at

Manila. I certify that I have personally examined the affiants and that I am
satisfied that they voluntarily executed and understood the contents of their
Complaint Affidavit

Doc. No. ________

Page No. _______
Book No. _______
Series of 2017.