Republic of the Philippines

Department of ___________
BOARD OF X ADMINISTRATION
__________., _________City
Metro Manila,Philippines

X Y. Z
Chairperson

DEPARTMENT _________________,
Complainant,

-vs- Case NO. 111

For:

ABC,
Respondent.
x--------------------------------------------------x

VERIFIED ANSWER

I, ABC, of legal age, Filipino, currently residing at __________, after

having been duly sworn to in accordance with law, depose and state, that:

Admissions/Denials/Explanations:

1. Allegations under Par. 1 are admitted.

2. Allegations under the Par. 2 are denied as follows:

4.1 Allegations under Subpars. (a) through (f) are denied for lack of
sufficient knowledge to form a conclusion as to their veracity.

4.2. Allegations under Subpar. (g) are specifically denied as I did not
receive any amount alleged therein in connection with the processing
of the Permit application of Alien nationals. There is no direct
evidence to support such claim aside from the statements of Mr. G
and Mr. H. It is noteworthy that the latter did not reduce their
statements against me into writing to form part of the record of the
case;

4.3. Allegations under Subpar. (h) are specifically denied as I did

not give any instruction to Mr. H regarding the applications of said
Alien Nationals;
 4.4. Allegations under Subpar. (i), is specifically denied as I did not
make any admission that I took part in any of the alleged fraudulent
processing and illegal issuance of permits to suspected Alien
nationals. The admission referred to is actually a misinterpretation
because what I admitted before Mr. J is the fact that I know the
existence of anomalous transactions done in the office.

3. Allegations under Pars. 3, 4, and 5 are admitted.

4. Allegations under Par. 6, are categorically denied as follows:

6.1. I specifically deny allegations under Subpars. (a) Subsubpar.

[iv] and (b), as I did not make any admission before the Mr. J and Ms.
L, in connection with the irregular processing of Mr. P’s Permit
application. As a matter of fact, what I admitted to is my knowledge
that there are anomalous transactions that happen in the Office;

6.2. I deny allegations under Subpar. (c) for lack of sufficient

knowledge to form a conclusion as to their veracity;

6.3. I specifically deny the allegations under subpar. (d), as these

Permit slips/receipts are not under my exclusive custody. These
alleged recycled Permit slips/receipts can also come from
applications which were deemed rejected due to clerical errors.
These rejected application are within the reach of anyone from the
office and can be accessed by any employee within the office.

6.4. I specifically deny the allegations under subpar. (e), as I did

not give any instruction to Mr. M to exchange stations with SG N. It is
noteworthy that it took Mr. M more than a week to report a
suspicious incident not involving me, then report another incident
alleging my involvement through dubious assumptions.

6.4. I partially admit allegations under subpar. (f) but only as to the
fact that I talked to Mr. G regarding some personal matters. I deny all
other allegations under this paragraph for lack of sufficient
knowledge to form a conclusion as to their veracity.

5. Allegations under Pars. 7 denied for lack of sufficient knowledge to

form a conclusion as to their veracity. I do not know these foreign nationals
nor did I have any participation in the illegal processing of their
applications.
 7.1 I was employed at the Office in Tawi-tawi for the period 8
February 2005 – 21 April 2008. For period May 2006 to October
2007, I was occupying the position of Permit Processor. For period
November 2007 – 21 April 2008, I was occupying the position of
Releasing Officer.

7.2 A careful perusal of the application forms (“ANNEX L”) do not

contain a processing date except for one (Application of “GU GU
GU”), dated 18 August ______.

7.3 During said date, as Permit Processor, it is my duty to affix my

signature as processor in all application forms that go through me.
The lack of my signature in the aforementioned forms show that I am
not aware nor did I take part in the processing of said applications.
Thus, these applications which do not contain my signature in any of
their pages, cannot be a basis of my participation in these illegal
practices.

6. Allegations under Pars. 8 and 9 are admitted.

7. Allegations under Par. 10, 11, and 12 are specifically denied as

follows;

9.1 My duty as Releasing Officer is limited to: filing the permits

received from the main office; segregating them according to their
shipping lists; monitoring and follow-up the status of applications;
and make necessary communications both to concerned offices for
coordination and applicants’ Post’s requests.

9.2 I did not participate in the preparation, processing, grant,

issuance and verifications of these anomalous applications since they
are outside the scope of my duties and responsibilities as Releasing
Officer.

8. Allegations under Pars. 13, 14, 15, and 16 are specifically denied as
follows:

10.1 The circumstance which the law provides does not apply to me
considering my duties and responsibilities as Releasing Officer, as
stated, does not involved the grant, issue or verification of any
Permit or travel document.

10.2 Even assuming that said circumstance applies, the alleged

application forms subject of the violation do not bear my signature.
 Thus, there is no direct evidence against me, aside from the sworn
affidavits of the witness and admissions of fixers which are merely
circumstantial.

9. Allegations under Pars. 17, 18, 19, and 20 are admitted.

10. Allegations under Par. 21, 22, 23, 24, and 25 are specifically denied
as follows:

12.1 I did not connive with other personnel, took advantage of my

position to derive any monetary gift, benefit or gain, nor knowingly
violate any law concerning the issuance of approved Permit
applications to unqualified foreign nationals.

12.2 I did not give instruction to anyone for so that the application
forms of foreign nationals be processed. I did not received any gift,
money, or consideration during my tenure as an employee of CO
Tawi-tawi in exchange for the processing and release of any Permit
application.

12.3 I did not knowingly approved Permit applications of foreign

nationals who are unqualified nor entitled for the issuance of a
Permit.

12.4 Moreover, the violation, one of the bases of which are the
application forms of the foreign nationals do not bear my signature
nor do they contain a date which would point to me as a processor or
releasing officer

11. Allegations under Par 26, 27 and 28 are admitted.

12. Allegations under Par. 29, 30, 31, and 32 are specifically denied as
follows:

14.1 I did not facilitate nor have a part in the speedy completion of
transactions done in my office for pecuniary gain, any other advantage or
consideration. The evidence presented against me show no direct relation
between my actions to said violation of the law;

14.2 I did not admit in an interview with Mr. J and Ms. L that I
facilitated these illegal Permit application of foreign nationals for a
consideration;

14.3 I am not aware of any scheme which Mr. G and Mr. H point me
to be a part of nor did I received any amount in connection with it. It is
interesting that these allegations of both Mr. G and Mr. H are not reduced
into writing to be made part of the record;

14.4 I did not knowingly nor willingly violate the law as did not
partake in any scheme to facilitate the speedy processing of Permit in
exchange for an amount, consideration, or pecuniary gain.

13. Allegations under Pars. 33, 34, 35, 36 are admitted.

14. Allegations under Par. 37, 38, and 39 are specifically denied as follow:

16.1 I do not involve myself with anything that is illegal in any

transaction done in the Office. Having been an employee of the
Department for almost 10 years, I am aware of the standards
required of public servants and that I will not jeopardize the pledge I
took before I started my service.

16.2 Throughout my tenure, I have upheld the dignity required of

the service and maintained the image and integrity of the same by
obeying all laws and following the rules and regulations
promulgated by the higher authorities

16.3 The evidence presented against me show no direct relation

between the violations alleged and any act or omission which I did.
The affidavits presented are merely circumstantial, and the CCTV
footage alleged as basis does not even show my image.

16.4 Premises considered, it would be at the height of injustice

should these evidence be considered.

15. (Statement to elect formal hearing or not)

16. I am executing this Affidavit to answer the Formal Charge against me

issued by the Board and that I attest to the truth of the foregoing.

Done this 5th day of January 2009 at _________, Metro Manila, Philippines.

ABCS
Affiant
 SUBSCRIBED AND SWORN TO before me this _____ day of January
2009 in _________ City. I hereby certify that I have personally examined
the affiant and after my queries, I am fully satisfied that she voluntarily
executed and understood her affidavit.

Notary Public