14 September 2014
09 September 2014
Republic of the Philippines
TANGGULANG DEMOKRASYA, INC., represented by EVELYN L. KILAYKO and TERESITA D. BALTAZAR.
PRESIDENT BENIGO SIMEON C. AQUINO III.
Case No. _________
FOR: Culpable Violation of Section 25(5), Article VI of the 1987 Constitution, Bribery, Graft and Corruption, and Other High Crimes
x ----------------------------------------------------------- x
COMPLAINT TO IMPEACH
We, Evelyn L. Kilayko, Filipino, of legal age, married, and Teresita D. Baltazar, Filipino, of legal age, married, after being duly sworn in accordance with law, jointly depose and state that:
1. Complainant Tanggulang Demokrasya, Inc. (“TanDem”) is a non-stock and non-profit corporation formed, organized and existing under the laws of the Republic of the Philippines, with SEC Registration No. CN201205942, created for the primary purpose of defending democracy, comprised of citizens of the Philippines as members, and with principal office at c/o Rm. 303, State Condominium 1, Salcedo Street, Legaspi Village, 1229 Makati City, Philippines. TanDem is represented herein by its Chairman, Evelyn L. Kilayko, jointly with its President, Teresita D. Baltazar.
2. Respondent Benigno Simeon C. Aquino III is the incumbent President of the Republic of the Philippines (“President Aquino”) who assumed office on 30 June 2010. He was proclaimed elected by Congress after the first automated elections for president held on 04 May 2010. He may be served with summons and other legal processes at the Office of the President, Malacanang Palace, Manila, Philippines.
3. TanDem has authorized the filing of this Complaint to Impeach President Benigno Simeon C. Aquino III, for culpable violation of Section 25(5), Article VI of the 1987 Constitution, bribery, graft and corruption, and other high crimes, pursuant to Section 2, Article XI of the 1987 Constitution. A copy of the Secretary’s Certificate dated __ July 2014, authorizing the filing of the complaint and delegating corporate authority to the undersigned, is attached as Annex “A”.
4. The substantive constitutional provision for the impeachment of the president, pursuant to which this Complaint is filed, provides as follows:
“The President, the Vice-President, the Members of the Supreme Court, the Members of the Constitutional Commissions, and the Ombudsman may be removed from office, on impeachment for, and conviction of, culpable violation of the Constitution, treason, bribery, graft and corruption, other high crimes, or betrayal of public trust.” 1987 Constitution, Article XI Accountability of Public Officers, Section 2.
I. President Aquino culpably violated the constitutional prohibition against the transfer of appropriations, by approving and implementing the Disbursement Acceleration Program (DAP) because: (1) the funds transferred were not savings; (2) the funds were transferred to items not covered by existing appropriations; and (3) the transfers were prohibited cross-border transfers. Section 25(5), Article VI, 1987 Constitution. Araullo, et al, v. Aquino, et al, G.R. No. 209287, 01 July 2014.
5. The constitutional prohibition against the transfer of appropriations provides as follows:
“No law shall be passed authorizing any transfer of appropriations; however, the President, the President of the Senate, the Speaker of the House of Representatives, the Chief Justice of the Supreme Court, and the heads of Constitutional Commissions may, by law, be authorized to augment any item in the general appropriations law for their respective offices from savings in other items of their respective appropriations.” 1987 Constitution, Article VI Legislative Department, Section 25(5).
6. Thus, as a general rule, the Constitution prohibits the transfer of appropriations made under the general appropriations law.
7. As an exception to the general rule, the Constitution allows the law to authorize the transfer of appropriations, provided that the funds transferred are “savings generated from the appropriations”, the “purpose of the transfer is to augment an item in the general appropriations law”, and the transfer is within the respective offices of the President including the entire executive branch, the Senate, the House of Representatives, the Supreme Court and the constitutional commissions.
8. During the period from October 2011 through September 2013, President Aquino personally and directly approved, authorized, directed and ordered the establishment and implementation of a Disbursement Acceleration Program (DAP) that pooled public funds from various appropriations, and applied the funds to uses other than those for which such funds were appropriated by law.
9. For this purpose, President Aquino personally and directly approved the following executive memoranda:
(a) Memorandum for the President dated October 12, 2011 (FY 2011 Proposed Disbursement Acceleration Program (Projects and Sources of Funds);
(b) Memorandum for the President dated December 12, 2011 (Omnibus Authority to Consolidate Savings/Unutilized Balances and its Realignment);
(c) Memorandum for the President dated June 25, 2012 (Omnibus Authority to Consolidate Savings/Unutilized Balances and their Realignment);
(d) Memorandum for the President dated September 4, 2012 (Release of funds for other priority projects and expenditures of the Government);
(e) Memorandum for the President dated December 19, 2012 (Proposed Priority Projects and Expenditures of the Government);
(f) Memorandum for the President dated May 20, 2013 (Omnibus Authority to Consolidate Savings/Unutilized Balances and their Realignment to Fund the Quarterly Disbursement Acceleration Program); and
(g) Memorandum for the President dated September 25, 2013 (Funding for the Task Force Pablo Rehabilitation Plan).
10. Meanwhile on 18 July 2012, Secretary Florencio B. Abad of the Department of Budget and Management, acting in his capacity as alter ego of President Aquino, issued National Budget Circular No. 541 directing the “Withdrawal of Agencies’ Unobligated Allotments as of June 30, 2012.”
11. “Taken together, all the issuances showed how the DAP was to be implemented and funded, that is — (1) by declaring “savings” coming from the various departments and agencies derived from pooling unobligated allotments and withdrawing unreleased appropriations; (2) releasing unprogrammed funds; and (3) applying the “savings” and unprogrammed funds to augment existing PAPs or to support other priority PAPs.”
12. As fate sealed it, “(on) September 25, 2013, Sen. Jinggoy Ejercito Estrada delivered a privilege speech in the Senate of the Philippines to reveal that some Senators, including himself, had been allotted an additional P50 Million each as “incentive” for voting in favor of the impeachment of Chief Justice Renato C. Corona.”
13. “Responding to Sen. Estrada’s revelation, Secretary Florencio Abad of the DBM issued a public statement entitled Abad: Releases to Senators Part of Spending Acceleration Program, explaining that the funds released to the Senators had been part of the DAP, a program designed by the DBM to ramp up spending to accelerate economic expansion.”
14. “The revelation of Sen. Estrada and the reactions of Sec. Abad and the DBM brought the DAP to the consciousness of the Nation for the first time, and made (pork barrel) controversy inevitable.”
15. Thereafter, “(nine) petitions assailing the constitutionality of the DAP and the issuances relating to the DAP were filed (with the Supreme Court) within days of each other…”
16. On 01 July 2014, the Supreme Court in the case of Araullo v. Aquino ruled that the DAP violated the constitutional prohibition against the transfer of appropriations, as follows:
(a) “There were no savings from which funds could be sourced for the DAP”; “savings could be generated only upon the purpose of the appropriation being fulfilled, or upon the need for the appropriation being no longer existent”; unreleased appropriations were NOT savings because such appropriations had not even reached the agency concerned vis-à-vis the programs, activities and projects for which Congress allocated them; unobligated allotments were NOT savings, unless the purpose of the appropriation was already fulfilled, or the need for the appropriation was no longer existent;
(b) The funds “pooled under the DAP were allocated to PAPs (programs, activities, projects) that were not covered by any appropriations in the pertinent GAAs;” in other words, the transfers of funds were NOT for the purpose of augmenting any existing item in the general appropriations law;
(c) Substantial funds pooled under the DAP from offices under executive branch, were transferred to the House of Representatives, the Commission on Audit and the Commission on Elections; in other words, the transfers of funds were NOT confined within the office of the President.
17. Accordingly, the Supreme Court in Araullo v. Aquino declared as unconstitutional the essential provisions of the DAP established and implemented by President Aquino, as follows:
“WHEREFORE, the Court PARTIALLY GRANTS the petitions for certiorari and prohibition; and DECLARES the following acts and practices under the Disbursement Acceleration Program, National Budget Circular No. 541 and related executive issuances UNCONSTITUTIONAL for being in violation of Section 25(5), Article VI of the 1987 Constitution and the doctrine of separation of powers, namely:
“(a) The withdrawal of unobligated allotments from the implementing agencies, and the declaration of the withdrawn unobligated allotments and unreleased appropriations as savings prior to the end of the fiscal year and without complying with the statutory definition of savings contained in the General Appropriations Acts;
“(b) The cross-border transfers of the savings of the Executive to augment the appropriations of other offices outside the Executive; and
“(c) The funding of projects, activities and programs that were not covered by any appropriation in the General Appropriations Act.
“The Court further DECLARES VOID the use of unprogrammed funds despite the absence of a certification by the National Treasurer that the revenue collections exceeded the revenue targets for non-compliance with the conditions provided in the relevant General Appropriations Acts.
18. Under the premises, it is manifest that President Aquino culpably violated the constitutional prohibition against the transfer of appropriations, by approving and implementing the Disbursement Acceleration Program (DAP) because: (1) the funds transferred were not savings; (2) the funds were transferred to items not covered by existing appropriations; and (3) the transfers were prohibited cross-border transfers.
19. President Aquino may NOT invoke the “doctrine of operative fact” to exculpate himself from liability, because the doctrine which provides for the prospective effect of a declaration of unconstitutionality, is premised on equity and fair play. The doctrine is applied ONLY if the retroactive nullification of the effects of the unconstitutional act will result in inequity and injustice. Thus, the doctrine does NOT protect those who committed the unconstitutional act. Rather, the doctrine protects ONLY those who in good faith relied on the unconstitutional act.
20. President Aquino may NOT invoke Section 39, Book VI of the Administrative Code of 1987 to justify the DAP because:
(a) The cited provision is only about the execution by the President of the budget approved by Congress; the said provision does not authorize the President to approve a budget separate from that of Congress;
(b) The cited provision speaks only of “savings” to cover “deficits”; as held in Araullo, DAP did not use savings, nor did DAP cover deficits; DAP instead transferred unreleased appropriations and unobligated allotments, to programs, activities and projects not covered by any appropriation enacted by Congress;
(c) The cited provision authorizing the President to transfer savings to cover deficits should be construed in a manner consistent with Section 25(5), Article VI, 1987 Constitution that prohibits “cross-border” transfers, because in the hierarchy of laws, the Constitution prevails over statutes such as the Administrative Code of 1987; otherwise, if the cited provision were strained and construed to purport to authorize “cross-border” transfers, then the said provision would be unconstitutional.
21. Apart from the constitutional prohibition against the transfer of appropriations, the statutory laws also impose criminal liability for the illegal use of public funds, as follows:
“Illegal use of public funds or property. - Any public officer who shall apply any public fund or property under his administration to any public use other than for which such fund or property were appropriated by law or ordinance shall suffer the penalty of prision correccional in its minimum period or a fine ranging from one-half to the total of the sum misapplied, if by reason of such misapplication, any damages or embarrassment shall have resulted to the public service. In either case, the offender shall also suffer the penalty of temporary special disqualification.
“If no damage or embarrassment to the public service has resulted, the penalty shall be a fine from 5 to 50 per cent of the sum misapplied.” Revised Penal Code, Act No. 3815, Article 220, 08 December 1930.
22. Notably, felonies under the Revised Penal Code are committed either with deliberate intent or with voluntary negligence. Criminal intent is automatically presumed from the mere commission of the criminal act. It is for the accused to rebut the presumption of criminal intent. The motive or reason behind the commission of the criminal act is not by itself an element of the crime.
23. Thus, by applying public funds under his administration to other public uses different from those provided by law, President Aquino is presumed to have the criminal intent to cause injury to the intended beneficiaries of the appropriations made by Congress.
II. President Aquino, using “pork barrel” funds sourced from DAP and PDAF, bribed and corrupted one hundred eighty-eight (188) Congressmen and nineteen (19) Senators, to secure the impeachment and conviction of Chief Justice Renato C. Corona. Privilege Speech of Senator Jinggoy Estrada on 25 September 2013. Privilege Speech of Senator Bong Revilla on 20 January 2014.
24. On 12 December 2011, a caucus of the majority bloc of Congressmen allied with President Aquino was called at the House of Representatives. A draft complaint containing eight (8) articles for the impeachment of Chief Justice Renato C. Corona of the Supreme Court, was presented during the caucus.
25. The caucus ended with one hundred eighty-eight (188) out of the two hundred eighty-five (285) Congressmen, signing the impeachment complaint against the Chief Justice. As only one-third of the entire membership of the House of Representatives, or 95 votes, was required for impeachment, the Chief Justice was impeached right there and then.
26. On 13 December 2011, or immediately on the following day, Congress transmitted the Articles of Impeachment to the Senate for trial. On 16 January 2012, the Senate commenced the trial of the impeachment complaint.
27. On 29 May 2012, with only two-thirds majority or sixteen (16) votes required to convict, the Senate impeachment court by a vote of twenty (20) against three (3), found Chief Justice Corona guilty of the Second Article involving the failure to disclose certain properties in his Statement of Assets and Liabilities and Net Worth.
28. Meanwhile, Congressman Tobias Tiangco of Navotas City, left the majority bloc in protest of the “railroading” of the Corona impeachment. He said that during the majority caucus at the House last December 12, Speaker Feliciano Belmonte Jr. gave lawmakers only two choices: sign or not sign the resolution impeaching the Chief Justice. The Speaker did not give the Congressmen the chance to question the resolution and read and assess the pieces of evidence against the Chief Justice. No questions were entertained.
29. Congressman Tiangco also bared the intimidation and undue influence exerted by President Aquino, acting through his alter ego Secretary Florencio B. Abad of the Department of Budget and Management, to impound or otherwise withhold the release of allotments under the Priority Development Assistance Fund (PDAF) intended to fund projects identified by congressmen. This was because of his refusal to support the impeachment of the Chief Justice.
30. On the other hand, Senator Joseph Victor Ejercito disclosed that when he was still a Congressman of San Juan, the government of President Aquino released to him P10 million pesos of public funds, as his reward for supporting the impeachment of the Chief Justice. The funds were sourced from the Disbursement Acceleration Program (DAP) of President Aquino.
31. If each one of the one hundred eighty-eight (188) Congressmen received P10 millions pesos of pork barrel funds, that would be equivalent to P1.88 billion pesos disbursed through the DAP of President Aquino.
32. On 25 September 2013, more than a year after the conviction of the Chief Justice, Sen. Jinggoy Estrada delivered a privilege speech revealing that nineteen (19) out of the twenty (20) senators who voted for the conviction of Corona, were promised and did in fact receive financial “incentives” in the amount of at least 50 million pesos each of public funds, by and from President Aquino who facilitated the “pork barrel” releases through his alter ego Secretary Florencio B. Abad of the Department of Budget and Management.
33. On 20 January 2014, likewise in a privilege speech, Sen. Bong Revilla further revealed that President Aquino invited and met him at the latter’s official residence at Bahay Pangarap in the Malacanang Complex, to personally and directly ask for the conviction of the Chief Justice, while the trial was still pending. President Aquino was with Secretary Abad of the DBM and Secretary Mar Roxas of the Department of Interior and Local Government during the meeting.
34. Meanwhile, in response to calls by the general public for the disclosure of information about the new and little known DAP of President Aquino, Secretary Abad released to mass media the additional pork barrel fund releases to Senator-Judges. The disclosure included releases made during the period from August 2012 through January 2013, given to the nineteen (19) Senators who voted to convict Corona, as follows:
Name of Senator-Judge
Amount of Pork Barrel Funds
Source of Pork Barrel Funds
Period of Release
1. Angara, Edgardo
2. Cayetano, Alan Peter
3. Cayetano, Pia
4. Drilon, Franklin
5. Enrile, Juan Ponce
6. Escudero, Francis
7. Estrada, Jinggoy
8. Guingona, Teofisto III
9. Honasan, Gregorio
10. Lapid, Lito
11. Legarda, Loren
12. Osmeña, Serge
13. Pangilinan, Francis
14. Pimentel, Aquilino III
15. Recto, Ralph
16. Revilla, Ramon Jr.
17. Sotto, Vicente III
18. Trillanes, Antonio IV
19. Villar, Manuel
*DAP: Disbursement Acceleration Program of President Aquino.
35. Under the premises, it is evident that President Aquino, using “pork barrel” funds sourced from DAP and PDAF, bribed and corrupted one hundred eighty-eight (188) Congressmen and nineteen (19) Senators, to secure the impeachment and conviction of Chief Justice Renato C. Corona.
Wherefore, we respectfully pray:
(a) That a Member of the House of Representatives endorse this Complaint, and that thereafter, the House of Representatives initiate impeachment proceedings against President Benigno Simeon C. Aquino III, for culpable violation of Section 25(5), Article VI of the 1987 Constitution, bribery, graft and corruption, and other high crimes, in accordance with the provisions of Section 3, Article XI on Accountability of Public Officers of the 1987 Constitution; and
(b) That after impeachment by the House of Representatives and trial by the Senate, President Aquino be convicted of the foregoing charges, removed from office and disqualified to hold any office under the Republic of the Philippines.
Evelyn L. Kilayko
Teresita D. Baltazar
TIN: 110-714-417 TIN: 106-938-235
We, Evelyn L. Kilayko, and Teresita D. Baltazar, Filipinos, of legal age, married, residents of Metro Manila, Philippines, under oath, depose and say:
1. That we are the Chairman and President respectively of party complainant Tanggulang Demokrasya (TanDem), Inc.;
2. That as Chairman and President respectively of party complainant, we have been authorized jointly to cause the filing and prosecution of a complaint for impeachment against President Benigno Simeon C. Aquino III based on the applicable provisions of the 1987 Constitution, and pursuant to said authority we caused the preparation of the present complaint; Secretary’s Certificate dated 23 July 2014, Annex “A”;
3. That as Chairman and President respectively of party plaintiff, we have read the contents thereof and the allegations therein are of our own personal knowledge or based on authentic records.
Evelyn L. Kilayko Teresita D. Baltazar
SUBSCRIBED AND SWORN to before me at MAKATI CITY on JUL 23, 2014, affiants exhibiting their TIN as follows:
Evelyn L. Kilayko TIN: 110-714-417
Teresita D. Baltazar TIN: 106-938-235
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 Araullo, et al, v. Aquino, et al, G.R. No. 209287, 01 July 2014, pages 55-56.
 Id, pages 36-43.
 Id, pages 43-47.
 Id, page 47.
 Id, page 6.
 Id, page 7.
 Id, page 8.
 G.R. No. 209287, 01 July 2014, pages 90-91.
 Id, page 57.
 Id, page 59. Under the GAAs for 2011, 2012 and 2013, “(savings) refer to portions or balances of any programmed appropriation in this Act free from any obligation or encumbrance which are: (i) still available after the completion or final discontinuance or abandonment of the work, activity or purpose for which the appropriation is authorized; (ii) from appropriations balances arising from unpaid compensation and related costs pertaining to vacant positions and leaves of absence without pay; and (iii) from appropriations balances realized from the implementation of measures resulting in improved systems and efficiencies and thus enabled agencies to meet and deliver the required or planned targets, programs and services approved in this Act at a lesser cost.”
 Id, page 60.
 Id, page 69.
 Id, pages 73-75.
 G.R. No. 209287, 01 July 2014, pages 90-91.
 “An unconstitutional act confers no rights, imposes no duties, and affords no protection. An unconstitutional act is inoperative as if it has not been passed at all. The exception to this rule is the doctrine of operative fact. Under this doctrine, the law or administrative issuance is recognized as unconstitutional but the effects of the unconstitutional law or administrative issuance, prior to its declaration of nullity, may be left undisturbed as a matter of equity and fair play.” Araullo, et al, v. Aquino, et al, G.R. No. 209287, 01 July 2014, J. Carpio, Separate Opinion, page 25.
 Araullo, et al, v. Aquino, et al, G.R. No. 209287, 01 July 2014, J. Brion, Separate Opinion, page 55.
 Supra Araullo, J. Carpio, page 25.
 Supra Araullo, J. Brion, page 56.
 Administrative Code of 1987, Book VI National Government Budgeting, Chapter 5 Budget Execution, Section 39. “Authority to Use Savings in Appropriations to Cover Deficits. - Except as otherwise provided in the General Appropriations Act, any savings in the regular appropriations authorized in the General Appropriations Act for programs and projects of any department, office or agency, may, with the approval of the President, be used to cover a deficit in any other item of the regular appropriations: provided, that the creation of new positions or increase of salaries shall not be allowed to be funded from budgetary savings except when specifically authorized by law: provided, further, that whenever authorized positions are transferred from one program or project to another within the same department, office or agency, the corresponding amounts appropriated for personal services are also deemed transferred, without, however increasing the total outlay for personal services of the department, office or agency concerned.”
 Araullo, et al, v. Aquino, et al, G.R. No. 209287, 01 July 2014.
 Id, Page 57.
 Id, Page 63.
 Civil Code of the Philippines, Art. 7. “Laws are repealed only by subsequent ones, and their violation or non-observance shall not be excused by disuse, or custom or practice to the contrary.
“When the courts declared a law to be inconsistent with the Constitution, the former shall be void and the latter shall govern.
“Administrative or executive acts, orders and regulations shall be valid only when they are not contrary to the laws or the Constitution.”
 Revised Penal Code, Art. 3. “Definitions. - Acts and omissions punishable by law are felonies (delitos).
“Felonies are committed not only be means of deceit (dolo) but also by means of fault (culpa).
“There is deceit when the act is performed with deliberate intent and there is fault when the wrongful act results from imprudence, negligence, lack of foresight, or lack of skill.”
Fundamentals of Criminal Law Review, Antonio L. Gregorio, 1983 Sixth Edition, page 13.
 Id, page 14.
 Id, page 15.
 Disbursement Acceleration Program (DAP) is a form of Presidential “pork barrel”. The essential provisions of the DAP were declared unconstitutional by the Supreme Court in Araullo, et al, v. Aquino, et al, G.R. No. 209287, 01 July 2014.
 Priority Development Assistance Fund (PDAF) is a form of Congressional “pork barrel”. The PDAF was declared unconstitutional by the Supreme Court in Belgica, et al, v. Ochoa, et al, G.R. No. 208566, 19 November 2013.
 See PNoy admits meeting other senators aside from Revilla: re Corona, GMA News, 21 January 2014, <http://www.gmanetwork.com/news/story/344827/news/nation/pnoy-admits-meeting-other-senators-aside-from-revilla-re-corona>
Republic of the Philippines )
MAKATI CITY, Metro Manila ) ss
I, Elena San Agustin, Filipino, of legal age, married, resident of Metro Manila, Philippines, being the Corporate Secretary of Tanggulang Demokrasya (TanDem), Inc., a non-stock and non-profit corporation formed, organized and existing under the laws of the Republic of the Philippines, with Securities and Exchange Commission Reg. No. CN201205942, created for the primary purpose of defending democracy, with principal office at c/o Rm. 303, State Condominium 1, Salcedo Street, Legaspi Village, 1229 Makati City, Philippines, hereby certify that on 05 July 2014, at the meeting of the Board of Trustees held at the GEA Community Hall, San Juan, Metro Manila, Philippines, the following resolution was duly and properly approved, upon compliance with the notice and quorum requirements, which resolution remains in full force and effect, not having been amended nor repealed as of this date:
Resolution No. NA, Series of 2014
“Resolved, that Tanggulang Demokrasya (TanDem), Inc. be authorized to institute and prosecute an impeachment complaint against President Benigno Simeon C. Aquino in accordance with the applicable provisions of the Philippine Constitution; to exercise or perform any act, power, duty, right, or obligation whatsoever that the Corporation now has, or may hereafter acquire the legal right or power, in connection with the foregoing.
“Resolved, that the Chairman of the Corporation, Evelyn L. Kilayko, and the President, Teresita D. Baltazar, be authorized jointly, to institute and prosecute legal proceedings, verify pleadings or motions, issue a certification of non-forum shopping, execute and sign documents, and perform any and all other acts necessary or convenient to implement the foregoing, under such terms and conditions as he/she may deem reasonable under the premises.
“Resolved, that the Chairman and the President of the Corporation, be vested jointly with full power and authority to appoint a substitute to perform any of the acts said officers are by this resolution authorized to perform, with the right to revoke such appointment or substitute at pleasure, with full power of substitution or revocation, hereby ratifying and confirming all that said officers, or their substitute or substitutes, shall lawfully do or cause to be done by virtue of this resolution and the rights and powers herein granted.
“Resolved, that all rights, powers and authority of said officers to exercise any and all rights and powers herein granted shall commence and be in full force and effect on this day and such rights, powers and authority shall remain in full force and effect thereafter until expressly or impliedly revoked by the Board, but the cessation of the authority herein granted shall not affect any act therefore done in exercise hereof.
“Resolved, that the present resolutions shall take effect immediately, and that any and all previous resolutions inconsistent with the foregoing be, as they are hereby, revoked and canceled.”
Elena San Agustin
SUBSCRIBED AND SWORN to before me at MAKATI CITY on JUL 23, 2014, affiant exhibiting her TIN: 126-705-730.
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