REPUBLIC OF THE PHILIPPINES)

CITY OF NAGA ) S.S.

COMPLAINT-AFFIDAVIT

I, Pedro Marasigan, a Filipino and a resident of Bagumbayan

Sur, Naga City, hereby aver the following facts:

That I am employed at the Barangay Hall, Bagumbayan Sur,

Naga City as Barangay Councilman;

That on August 2, 2019, Barangay Captain Wil Tanggo made it

appear that the Barangay Council of Bagumbayan Sur met in session
and passed a Barangay Ordinance appropriating P30,000.00 for a
canal drainage project;

That pursuant to said purported ordinance, Barangay Captain

Tanggo, together with Barangay Treasurer Karla Sola, prepared a
labor payroll for the period August 12 - 21, 2019 indicating therein
that certain individuals, namely, Tirso Cruz and Dante Cortez, have
worked and finished the canal drainage work;

That said barangay officials Tanggo and Sola withdrew and

disbursed from the barangay funds the amount of P30,000.00
supposedly for the canal drainage project;

That the Barangay Council of Bagumbayan Sur had not

convened in session nor passed the aforesaid ordinance on August 2,
2019 for the purpose of appropriating P30,000;

That no canal drainage project was undertaken by the

barangay in August, 2019;

That I am charging Barangay Captain Wil Tanggo and

Treasurer Karla Sola 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).

PEDRO MARASIGAN
Complainant-Affiant

1
 Subscribed and sworn to before me this 18 th day of September,
2019, at Naga City, Philippines.

ATTY. MICHELE ROSE DIAZ

Public Prosecutor

REPUBLIC OF THE PHILIPPINES)

CITY OF NAGA ) S.S.

CERTIFICATE OF NON-FORUM SHOPPING AND VERIFICATION

I, Pedro Marasigan, Filipino, of legal age, married and a

resident of Bagumbayan Sur, Naga City, after having duly sworn to in
accordance with law, do hereby depose and state:

1. That I am the Petitioner in the above-entitled case;

2. That I have caused the preparation and filing of the foregoing

Petition and I have read all the allegations therein which are
true and correct based on my personal knowledge and
authentic documents;

3. That I further certify that there is no pending action or

proceeding involving the same issues in the Supreme Court,
Court of Appeals, or any other tribunal or agency. If I should
thereafter learn that the same or similar action is pending, I
shall undertake to inform the Honorable Court of this fact within
five (5) days therefrom.

PEDRO MARASIGAN
Complainant-Affiant

Subscribed and sworn to before me this 18 th day of September,

2019, at Naga City, Philippines.

ATTY. MICHELE ROSE DIAZ

Public Prosecutor