February 28, 2011

Hon. NEIL C. TUPAS, JR.Chairman Committee on Justice

Dear Chairman Tupas:

COMPLIANCE

Greetings to the Chairman and members of the Honorable Committtee on Justice.

The undersigned Complainant and Endorser, in compliance with and pursuant to Rule III Section 5 of the Rules of Procedure on Impeachment of the 15 th Congress, respectfully submit the affidavits of complainants and their witnesses including the attached documentary evidence, and a list of the witnesses and document we have or will be submitting to or presenting before this Honorable Committee in support of complainants' Impeachment Complaint against Ombudsman Merceditas Gutierrez and in rejoinder to any answer or defense of the respondent Ombudsman:

1) Documents in relation to the General Allegations:

a) Sworn Statement of Mr. Renato Reyes Jr. as to the Impeachment Complaint and the grounds thereto. Mr. Reyes will testify as a witness on the same, as well as the other complainants.

2) Documents-evidence in relation to the Fertilizer Fund scam

a) KMP et al. Complaint with Annexes A to A-5, B, Annex C, D, E prefaced by the Sworn Statements of Mr. Danilo Ramos and Atty. Jobert Pajilga

b) Sandiganbayan Certification that no complaint has been filed by the Ombudsman against Jocelyn “Jocjoc” Bolante and Luis “Cito” Lorenzo

c) Senate Report (Blue Ribbon Committee) on the Fertilizer Scam

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d) Senate Report 254 e) Senate Report 54 f) Sworn Statement of former Solgen Francisco Chavez with his Complaint for

Plunder together with its attached evidentiary documents.

Attached to his sworn statement:

a. Amended Complaint-Affidavit dated May 26, 2004 for plunder against Pres. Arroyo et al in relation to P 728M GMA Fund Scamb. Manifestation dated 31 May 2004 identifying Bolante as John Doe mentioned in the complaintc. Complaint-Affidavit dated June 8, 2004 - Second Plunder charge against GMA et al in relation to the 1,102,391,000 GMA Fund scam in addition to the 728M d. Complaint-Affidavit dated 25 June 2004 – Plunder charge against GMA et al in relation to “Oplan Mercury” involving NFA, DA, PAGCOR and DOHe. Complaint-Affidavit dated 20 July 2004 - Plunder charge against GMA et al for misuse of OWWA Fundsf. and f-1. Motion to Recuse and Follow-up letter to Ombudsman Marcelo to inhibit from investigating/hearing the caseg. Letter to Ombudsman for Luzon dated 27 August 2004 asking for update on the plunder chargesh. Letter from Ombudsman for Luzon dated 02 September 2004 informing Atty.

Chavez that Marcelo inhibited himself from investigating/hearing the plunder cases

i. Letter dated 02 December 2004 asking for an update on the plunder chargesJ. to J-2, letter from Ombudsman with 2 pages attachment regarding the office’s action plans on the plunder chargesk. Letter dated 29 November 2005 to follow up on the action planl. 12 December 2005 letter from the Ombudsman informing Atty. Chavez that the plunder complaints were returned to the Central Office as Marcelo resigned m. Letter dated 21 December 2005 with Atty. Chavez informing the Ombudsman that it made him wait for nothingn. Letter dated 03 February 2006 to Sen. Magsaysayo. Reply letter of Sen. Magsaysay dated 08 February 2006p. Senate Committee Report No. 54 dated 01 March 2006

p-1. Transmittal letter of Senate Committee Report No. 54 to the Ombudsmanq. COA Report on the audit of the 728 M GMA Fundsr. Motion to require Respondents to Submit Counter-Affidavits. Filed Investigation Office report dated 20 June 2006 recommending the filing of criminal and administrative cases against Jocjoc et al

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t. Consolidated Report of FIO dated 20 July 2006 recommending the filing of criminal and administrative charges against the local officials of Butuan City and private individuals involved in the 728 GMA Fund scam

Witnesses for the Fertilizer Scam :i) Mr. Danilo Ramos, KMP Secretary General with his sworn statementii) Former Solgen Francisco Chavez with his sworn statementiii) Atty. Jobert Pahilga with his sworn statement iv) Other witnesses such as the farmers who did not receive the supposed fertilizer with their sworn statements; witnesses from the Commission on Audit who will testify on the irregularities in the Fertilizer Fund scam; Senate Committee Secretary to attest to holding of Committee hearings on the fertilizer scam and the fact that the Senate has transmitted its report to the Ombudsman together with their respective documents.

3) Documents in relation to the Euro Generals

a) Sworn Statement of Complainant Ferdinand Gaite, Secretary General of COURAGE, on the case of the Euro Generalsb) Senate Transcript of Stenographic Notes (TSN) containing admissions of Gen. Eliseo de la Paz as to his failure to declare that he was carrying more than US $ 10,000 cash out of the country and other related issuesc) Senate Report No. 229 (11/13/2008) and its annexes and attachments d) Central Bank Circular on the need to declare the carrying of currency in excess of US$ 10,000.00e) PNP-CIDG Report and PNP DIDM report and memorandum and other documents relevant to its investigation of the Euro-Generals scandal f) Certification from the Sandiganbayan dated February 28, 2011 that no criminal/civil case has been filed against Police Director Eliseo D. Dela Pazg) Certification from the Bureau of Customs about the non declaration of carrying out of the country dollars in excess of US$10,000h) News reports on the euro generals

Witnesses: 1. Ferdinand Gaite with his sworn statement2. Other witnesses such as Customs Collector Teresita Roque and other witnesses from the Bureau of Customs and the Central Bank with their respective sworn statements; witness from the Senate on the Senate inquiry

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and the transmittal to the Ombudsman of the Report with his sworn statement; other witnesses who will testify on the findings of the PNP and COA with their respective sworn statements

4) Documents in relation to the Information Technology Foundation of the Philippines (ITFP) or the Mega Pacific eSolutions, Inc. case

a) Sworn Statement of Mr. Gus Lagman and its annexes b) Supreme Court Resolutions/Decisions in relation to the (GR No. 159139) dated 1/13/2006, 6/13/2006, /5/3/2006 c) Ombudsman Resolution in the cases of Kilos Bayan vs. Benjamin Abalos et al and Pimentel vs. Benjamin Abalos et al.d) Ombudsman Supplemental Resolution in the cases of Kilos Bayan vs. Benjamin Abalos et al and Pimentel vs. Benjamin Abalos et al. e) Other witness and documents

Witnesses:

1. Mr. Gus Lagman with his sworn statement2. Other witnesses

We have also attached in the Impeachment Complaint documentary evidence in support of the said impeachment complaint. We reserve the right to submit additional witnesses, affidavits and documentary evidence in response or as a rejoinder to the answer or defense of respondent Ombudsman and in relation to any requirement of the Articles of Impeachment that may be issued by the House of Representatives.

Thank you

MR. RENATO REYES REP. TEDDY CASINO (Bayan Muna)Complainant Endorser

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