Supplemental Affidavit-Rodolfo Edrad JR

Republic of the Philippines DEPARTMENT OF JUSTICE Manila
P ATRIA GLORIA ORTEGA, Complainan i,

- versus-

NPS NO. IV-17-INQ-Il-A-00005

JOEL T. REYES, ET. AL.

Respondents.

x------------·------------------------------------------------------------------------------------x

SUPPLEMENT AL AFFIDA.VIT

I, RODOLFO "BOMARfl EDRAD JR., of legal age, Filipino, married,

with postal address c/o the Witness Protection Program, Department of Justice

Manila, after having been duly sworn to in accordance with law, duly assisted by

my counsels of choice, hereby depose and state:

1) I am one of the respondents in the above-captioned case and presently

under custody of the Witness Protection Program of the Department of Justice.

2) I hereby affirm and confirm the contents of my Sinumpaang Salaysay

dated 06 February 2011 and declare that they are all true and correct based on my

utmost recollection and personal knowledge.

of Supplemental Affidnvit

3.) I still maintain until the day I die that respondent former Governor of Palawan Joel T. Reyes and respondent former Governor of Marinduque Jose Antonio Carrion are the Masterminds in the murder of Dr. Gerry Ortega.

4.) I was a former Close In Security/Bodyguard of respondent Jose Antonio

Carrion, the former Governor of Marinduque, from June 2008 up to May 2010.

5.) I was also a former Close In Security/Bodyguard of respondent Joel T. Reyes, the former Governor of Palawan, from July 2010 until I went in hiding after the murder of Dr. Gerry Ortega.

6.) I was hired by respondent Joel T. Reyes, through respondent Jose Antonio

Carrion, to kill Dr. Gerry Ortega, a broadcastery mediaman from Palawan.

7.) I received money from respondent Joel T. Reyes for payment of hired killers Marlon Recamata and Dennis Aranas and Armando Noel alyas "Salbakota" .

8.) I was in direct communication with respondent Joel T. Reyes (Globe Mobile No. 0917-5312222/Smart No. 0918-9169059) before, during and after the killing of Dr. Gerry Ortega.

9.) It was respondent Joel T. Reyes who personally gave me the money,

pictures and order to kill Dr. Gerry Ortega.

Page 3 of48

of Supplemental Affidnvit

10.) Respondents Joel T. Reyes and Jose Antonio Carrion both deny my

accusations and claim that I have no credibility nor any independent evidence to

back up my allegations ..

11.) In order to prove once and for all, who is telling the truth and who is

lying, I have prepared a simple illustration and diagram which would prove my

accusations, as follows:

CHRONOLOGY OF EVENTS

(Based on the Sinumpaang Salaysay of Rodolfo Edrad, Jr. dated 06 Februanj 2011)

ADMISSIONS

INDEPENDENT!

CORROBORATIVE EVIDENCE

[uly4,2010

a) Rodolfo Edrad, Jr. ("BOl\1ARfI) reported for work as Ii close-in" security of Respondent Joel Reyes at Palawan Center, Makati ..

BASED ,oN THE C,oUNTER- Photo of Bomar with AFFIDAVIT OF [DEL T. Respondent Joel Reyes and REYES DATED 3.1 MARCH his companions while 2011 Bomar was stili a close-in

security of Respondent Joel 1) In paragraph 46.3 of his T .. Reyes. (Annex "A")

Coun ter- Affidavi i,

Respondent Joel Reyes

admitted that Bomar would

accompany him and his BASED ON THE driver to social functions. SJNUMPAANG SALA YSAY

,oF ARTURO REGALAD,o

2) In paragraph 46 .. 4 of his DATED

Counter-Affidavit 9' FEBRUARY 2011

Respondent Joel Reyes

admitted that Bomar would show up occasionally whenever Respondent Joel Reyes was in Manila.

- This would prove thai Respondent Joel Reyes personally knows Bomar.

- This would prove that Bomar

1) In paragraph 17 (5) of his Sinumpaang 5alaysay, Regalado confirmed that Bomar called him and asked him to buy bullets for a .. 38 caliber gun. He stated that "may pinapatrabaho 51 "Boss", isang kumentarista daui."

b) Respondent Joel Reyes arrived at Palawan Center at 2pm on board a Rubicon Wran ler driven b [un

- -.0- .-. ".I ~

of Supplemental Affidavit

was on-call every time Respondent Joel Reyes was in Manila

- This proves that Bumar never posed a security threat to Respondent Joel Reyes and his family.

- The fact that Respondent Joel Reyes is always accompanied by Bumar in his social functions is sufficient to establish his closeness with Bumar.

- Respondent Joel Reyes, as a former Governor, wou Ld never allow Bumar to know his whereabouts if he never considered him as his close-in security.

3) In paragraph 46.3 of his Counter-Affidavit, Respondent Joel Reyes also admitted that he would occasionally give Bumar "balaio" and "pambigasbigas"

- This would prove that Bumar was close to Respondent Joel Reyes, being always in his company whenever he was in Manila.

- This would also prove that Bumar was receiving money from Respondent Joel Reyes from time to time. Bumar's salary as closein security was given to him in the guise of "balato" and "pambigas-bigas"

4) In paragraph 46.5 of his Counter-Affidavit Respondent Joel Reyes admitted that he was at the Palawan Center and met

2) In paragraph 25 (T and S) of his Sinumpaang Salay say, when Regalado was asked "Sa iyong pagkakaalam, sino ang tinutuloy niyang "Boss'T, he answered "Si dating Governor Joel T. Reyes"

3) In paragraph 26 (T and S) of his Sinumpaang Salaysay, when asked "Bakii mo naman nasabi at sa iyong pagkakaalam ay si dating Governor Joel T.

R HB /I

eyes ang ass na

tinutuloy?", Regalado

answered HDahil pareho kaming naging security ni dating Governor Toel T. Reyes sir." (emphasis supplied)

This corroborates the

statement of Bomar that he was a close in security of Respondent JOel RelJes

- This negates the allegation of Respondent Joe; Reyes tat Bomar was never his dose~1. security.

Page 5 of48


Cabalsa. While Bomar and Respondent Joel Reyes were discussing his duties as close-in security of Respondent Joel Reyes, respondent Gov. Carrion arrived on board his Jeep Conunander.

Respondent Gov. Carreon there on July 4, 2010.

- This validates the statement of Bomar that Respondents 1 Del Reyes and Gov. Carrion were at the Palawan Center on July 4,2010.

- This proves that contrary to the claim of Respondent Joel Reyes, Bomaruias in fact with him at Palawan Center on July 4, 2011.

- The fact that Bomar knew the details of the meeting of Respondents Joel Reyes and Gov. Carrion validates the statement of Bomar that he was really with Joel Reyes at Palwan Center.

- This proves that as close-in securitu of Respondent Joel Reyes, Bomar knows his whereabouts since he was always with him.

BASED ON THE AFFIDAVIT OF ANTONIO ALBANO (Annex US" of Respondent Joel Reyes' Counter-Affidavit)

1) Albano admitted that met with Respondents Joel Reyes and Gov. Carrion for lunch at Palawan Center on July 4, 2010.

- This confirms the statement of Bomar that Respondents Joel Reyes Gov. Carrion were at the Palatcan Center on July 4,2011.

BASED ON THE AFFIDAVIT OF NEMESIO CABAL SA (Annex '7" of JTR's CounterAffidavit)

c) Bomar and Respondent Joel Reyes proceeded to a mall in Makati. While at the said mall, Respondent Joel Reyes asked Bomar if Gov. Carrion already informed him of the plan to kill Dr. Ortega. Respondent Joel Reyes even said "Kailangan mawala na kasi saki t na ng ulo pero i-schedule ng December 2010. x x x Kailangan ay hindi ikaw ang magtatrabaho (papatay) kasi masusunog ako dahil nakadiki t ka sa akin kumuha ka na lang ng ibang tatrabaho 0 kung ikaw ang tatrabaho

Page 6 of48


1) Cabalsa confirmed the statement of Bomar that Respondent [oel Reyes had a meeting with Respondent Gov. Carrion at the Palawan Center.

2) Cabalsa also confirmed that Bomar would accompany Respondent Joel Reyes on several occasions.

- These would prove that Bomar was on-call every time Respondent Joel Reyes was in Manila

- These also prove that Bomar never posed a securitu threat to Respondent Joel Reyes and his family.

- The fact that Respondent Joel Reyes is always accompanied by Bomar in his social functions is

sufficient to establish the

closeness of Bomar with

Respondent Joel Reyes.

~L/

. i

kailangan hindi ka na didikit sa akin"

(No. 41[5] of

Sinumpaang Salaysay)

December 2010

a) Bomar & Respondent Joel Reyes went to Podium [Feng Shui's Store]

b) Thereafter, they went to Atty. Clara Espiritu's house (mother-in-law of Respondent Joel Reyes) at No. 1363 Caballero St.

Dasmarinas Makati

c) Bomar and Respondent Joel Reyes went to Resorts World Manila near Villamor and Terminal 3 at around 7 or 8 pm. They were dropped off by the driver Respondent Joel Reyes, [un Cabalsa, at the lobby of Marriot hotel.

d) While at Marriot Hotel, Respondent Joel Reyes discussed again with Bomar the plan to kill Dr. Ortega and handed him P150,OOO.OO and photos of Dr, Ortega.

d) Bomar searched for someone who could do the job. After a while,

Page 7 of 48


BASED ON THE COUNTERAFFIDA VIT OF ,OEL T. REYES DATED 31 MARCH 2011

1) In paragraph 46.8 of his Counter-Affidavit, Respondent Joel Reyes admitted that he was a frequent visitor of Marriot Hotel and well-known to its staff.

- This proves that as close-in security of Respondent Joel Reyes, Bomar knew his whereabouts and this fact is sufficient to establish the closeness of Bomar with Respondent Joel Reyes.

- These would prove that Bomar was really on-call eoerutime Respondent Joel Reyes was in Manila.

-----. -

Page 8 of48


Bomar talked to Salbakotah while he was in Pagbilao and discussed with him the plan to kill Dr. Ortega.

MID-DECEMBER 2010

a) Salbakotah & one (1) companion went to Bomar's house In Pagbilao

b) Bomar gave

Salbakotah money

-P25,OOO.OO for

expenses -P20,OOO.OO each

and 3 photos of Gerry Ortega

BASED ON THE SINUMPAANG SALAYSAY OF ARMANDO NOEL (I'SALBAKOTAH") D:A.ITD 13 FEBRUARY 2011

1) In his Affidavit, Salbakotah confirmed that Bomar discussed with him the plan to kill Dr. Ortega.

This pro-ves that the statement of Bomar--that he discussed the plan of Respondent Joel Reyes to kill Dr. Ortega-tnas substantially corroborated ,by Salhokotah.

BASED ON THE SINUMPAANG SALAYSAY OF ARMANDO NOEL (JISALBAKOTAH") DATED 13 FEBRUARY 2011

1) In pages 3 and 4 of his Affidavit, Salbakotah stated that Bomar gave them P20,OOO each as initial

payment and an

additional amount of

P25,OOO for their expenses inPalawan.

Salbakotah

2)

also

confirmed that Bomar gave him photos of the target, Dr. Gerry Ortega.

This proves that the statement of Bomar that he gave Salbakotah and his companion P65,OOO.OO and photos of Dr. Gerry Ortega to execute the plan of Respondent Joel Reyes to kill Dr. Ortega was substantially corroborated by Salbakotah.

Page 9 of 48


c) Salbakotah and Arandia went to Pier 2 North Harbor, Manila but they were not able to leave because of sudden inspection made by coast guard along with some K9.

BASED ON THE SINUMPAANG SALAYSAY OF ARWIN ARANDIA DATED

28 FEBRUARY 2011

1) In Page 6 of his Affidavit, Arwin Arandia confirmed that Bomar gave them P20,OOO each as initial payment for killing Dr. Ortega.

2) Arandia also confirmed that Bomar gave them photos of the target, Dr. Gerry Ortega

- This proves that the statement of Bomar -- that he gave Salbakotah and Arandia the amount of P65,OOO.OO and photos of Dr. Gem} Ortega to execute the plan of Respondent Joel Reyes to kill Dr. Ortega-was substantially corroborated in material points.

i

December 17,2010

a) Bomar went to Batangas Pier to meet Salbakotah to give him the .357 revolver which was hidden inside the Rebisco Tin Can.

BASED ON PAGE 5 OF THE SINUMPAANG SALAYSAY OF SALBAKOTAH AND PAGE 7 OF THE SINUMPAANG SALAYSAY OF ARANDIA, they both confirmed that they were not able to leave because of the presence of coast guard along with someK9.

BASED ON THE SINUMPAANG SALAYSAY OF ARMANDO NOEL e~SALBAKOTAH") DATED 13 FEBRUARY 2011

1) In paragraph 38 (S) of

his Sinumpaan_g_2alaysay ~

~/

Page 10 of48


b) 5albakotah and Arnadia and boarded a ship going to Coron via EI Nido, then from EI Nido to Puerto Prinsesa.

5albakotah confirmed that he met with Bomar at Batangas Pier, and Bomar gave him the Rebisco Tin Can containing the .357 revolver.

BASED ON IRE SINUMPAANG SAlAYSAY OF ARWIN ARANDM DATED

28 FEBRUARY 2,011

1) On Paragraph 76(5) of his Sinumpaang Salay say, Arandia stated that Bomar sent him a text message that he already gave the money to Salbakotah and the Rebisco Tin Can containing the gun was already inside the ship.

2) Arandia also confirmed that he met 5albakotah inside the ship and he saw the Rebisco tin can.

- This proves that the statement of Bomar -- that he gave Salbakotah the Rebisco Tin Can containing the gun at the Batangas Pier- was substantially corroborated In material points.

BASED ON THE SINUMPAANG SALAYSAY OF ARMANDO NOEL (USALBAKOTAH") DATED 13 FEBRUARY 2011

1) On Paragraph 38(5) of his 5inumpaang 5alaysay, Salbakotah stated that they went to Batnagas Per and boarded a ship goi~

I !

Page 11 of48


to Coron Palawan. He also stated that he used the name "Alex Dela Cruz"

- Rapal Inter-Island Shipping Inc. Passenger Manifest showing that Alex Dela Cruz was a passenger of MjV Ma. Angelica Grace from Batangas to Coron Palawan on December 17,2011. (Annex "Bf')

- This corroborates the statement of Bomar and Salbakotah that Salbakotah and Arandia went to Batangas Pier and boarded a ship going to Coron, Palawan in preparation of the execution of Respondent Joel Reyes' plan to kill dr. Ortega.

BASED ON THE SINUMPAANG SALAYSAY OF ARWlN ARANDLA DATED

28 FEBRUARY 2011

1) On Paragraph 76(S) of his Sinumpaang Salay say, Salbakotah stated that they went to Batangas Per and boarded a ship going to Coron Palawan.

- This corroborates the statement of Bomar and Salbakotah that Salbakotah and Arandia went to Batangas Pier and boarded a ship going to Coron, Palawan in preparation of the execution of Respondent Joel Reyes' plan to kill dr. Ortega.

December 20,2010

a) 5albakotah and his

companion safely

arrived In Puerto

Prinsesa, Palawan and checked In an apartment.

Page 12 of48


BASED ON THE SINUMPAANG SALAYSAY OF ARMANDO NOEL (i'SALBAKOTAHTf) DATED 13 FEBRUARY 2011

1) In paragraph 51 (5) of his 5inumpaang Salaysa};-# Salbakotah confirmed that they arrived at Puerto Prinsesa on December 20, 2010

2) In paragraph 52 (5) of his 5inumpaang 5alaysay, 5albakotah confirmed that they checked in at Bundal Inn.

3) In paragraph 53 (5) of his 5inumpaang 5alaysay, 5albakotah confirmed that they left Bundal Inn the next day and transferred to an apartment.

BASED ON THE SINUMPAANG SALAY SAY OF ARWlN ARAND:lA DATED

28 FEBRUARY 2011

1) On Paragraph 89 (5) of his 5inumpaang 5alaysay, Arandia confimed that they arrived in Puerto Prinsesa on December 20, 2010.

2) On Paragraph 90 (5), Arandia also confirmed that they checked. in at Bundal Inn.

Page 13 of48


a) Bomar called Regalado and asked him to buy bullets for .38 caliber revolver.

the next transferred apartment.

day to

and an

This proves that the statement of Bomar - that Salbakotah and Arandia stayed in an apartment when they arrived in Puerto Prinsesa Palawan to execute the plan of Respondent Joel Reyes to kill Dr. Gem) Ortega- was substantially corroborated In material points.

BASED ON THE SINUMPAANG SALAYSAY OF ARTURO REGALADO DATED

9 FEBRUARY 2011

1) In paragraph 17 (5) of his Affidavit, N onoy Regalado confirmed that Bomar called him and asked him to buy bullets for a .38 caliber gun.

2) In paragraph 28 (5) of his Affidavit, Regalado stated that he was able to buy bullets which Bomar asked him to buy.

3) In paragraph 30 (5) of his Affidavit, Regalado stated that he informed Bomar through text message that he was able to buy the said bullets.

4) In paragraph 30 (5) and 33 (5) of his Affidavit, Regalado stated that upon instructions of Bomar, he gave the bullets to a man whom Bomar sent to him at I

Page 14 0/48


Burgos St., Barangay Princes a, Puerto Prinsesa, Palwan.

This proves that the statement of Bomar - that Bomar called him to buy bullets while he mas in Palawan- was substImrtJlil..J corroborated In material points.

BASED

o

IRE

SINUMPAANG SALltYSilY OF ARWIN ARAl\VIA DATED

28 FEBRUARY 2011

1) In paragraph 107 (S) of his Sinumpaang Salaysay, Arandia stated that Bomar sent him a text message and ordered rum to go to Ignacio Restaurant at Burgos St. to meet a man who will give him the six (6) pieces of bullets.

2) In paragraph 110 (S) of his Sinumpaang Salay say, Arandia stated that he went to Ignacio Restaurant at Burgos St. and a man handed rum a brown envelop containing the six (6) pieces of bullets for .38 caliber gun.

3) In paragraph 111 (5) of his Sinumpaang Salaysay, Arandia stated that Bomar told him that the man who gave him the bullets was named "N onoy Regalado"


statement of Regalado that after he bought the bullets for .38 caliber un tohu: J.lr-±","-,

Page 15 of48


a) Bomar stated that a few days after, Salbakotah told him that they could not do the job. Salbakotah and Arwin went back to Pagbilao.

2) In paragraph 68 (S) of his Sinumpaang Salaysay,

Salbakotah confirmed that I

they informed Bomar that

they could not do the job i

to kill Dr. Ortega.

asked him to buy, Regalado gave the said bullets to Arandia at Ignacio Restaurant.

BASED O~ THE S.lNlmtfPAAr,rG 5!AL4YSdY OF ARlYLA_ ""\no ;S:OEL (F"SALEvtKiOTAH") DAnn 13 FEBRUARY 2011

1) In paragraph 64 (S) of his Sinumpaang Salaysay, Salbakotah stated that after discussing with Arandia, they decided to went back to Manila because both of them could not do the job to kill Dr. Ortega.

- This proves that the statement of Bomar - that he was told that Salbakotah and Arandia could not do the job to kill Dr. Ortega - was substantially corroborated In material points.


28 FEBRUARY 2011

1) In paragraph 120 (S) of his Sinumpaang Salay say, Arandia stated that after discussing with Salbakotah, they decided to went back to Mnaila

Page 16 of48


b) Bomar stated that Salbakotah told him he would recommend someone to fllrish the job.

because they could not do the job to kill Dr. Ortega.

2) In paragraph 132 (S) of his Sinumpaang Salaysay, Arandia stated that on December 30I they told Bomar that they could not kill Dr. Ortega.

- This proves that the statement of Bomar - that he was told that Salbakotah and Arandia could not do the job to kill Dr. Ortega - was substantially corroborated In material points.

BASED ON THE SINUMPAANG SALAYSAY OF ARMANDO NOEL ("'SALBAKOTAH") DATED 13 FEBRUARY 2011

1) In paragraph 71 (5) ofi his Sinumpaang Salaysay, Salbakotah confirmed that

he went to Bomar and he recommended a certain alyas "PUSAII to finish the

job to kill Dr. Ortega.

2) In paragraph 74 (S) of his Sinumpaang Salaysay, Salbakotah stated that he talked to Al yas PUSA" and discussed with him the job to kill Dr. Gerry Ortega.

- This proves that the statement of Bomar - that Salbakotah recommended Alyas "PUSA" to finish the job to kill Dr. Ortega- was substantially corroborated in material points.

Page 170/48


lanuary Sf 2011

BASED ON THE SINUMPAANG SALAYSAY OF ARWIN ARANDlA DATED

28 FEBRUARY 2011

1) In paragraph 141, 142 and 143 (S) of his Sinumpaang Salaysay, Arandia stated that Salbakotah looked for someone to replace them in finishing the job.

- This corroborates the statement of Bomar that Salbakotah recommended "PUSAn to finish the job to kill Dr. Onega.

a) Respondent Joel Reyes sent a text message to Bomar and directed him to report to him at Dasmarinas Village, Makati. At that time, JTR was in Cor on Palawan.

Travel Records and Certification from Bureau of Immigration indicating

that JTR and his daughter Jacquelyn Reyes went 1) In paragraph 46.9 of his abroad on January 10, 2011.

Counter-Affidavit, (Annex "C" and "D",

Respondent Joel Reyes respectively)

admitted that he arrived

inManila from Palawan on - This proves that the January 8,2011 statement of Bomar that Respondent Joel Reyes and his daughter Jacquelyn Reyes went abroad was substantially corroborated in material points.

BASED ON THE COlINTERAFFIDA VIT OF JOEL T. REYES DATED 31 MARCH

b) Bomar and driver Jun Cabalsa went to the airport Terminal 3 to fetch Respondent Joel Reyes who just arrived from Coron Palawan.

c) Bomar stated that Respondent Joel Reyes went to Manila because he was leaving the country to accompany his daughter "J akie Reyes" abroad.

2) In paragraph 46.10 of his Counter-Affidavit, Respondent Joel Reyes admitted that on January 8, 2011, he arrived in Manila

c) After they fetched Respondent Joel Reyes

Page 18 of48


lanuary 15, 2011

from Palawan and that he and her daughter was leaving for Switzerland on January 10, 2011.

from the airport, they went to Atty. Clara Espiritu's house (Respondent Joel Reyes'

mother-in-law) at

Dasmarifias Village, -This would prove that Bomar

Makati. was on-call every time Respondent Joel Reyes was in Manila

d) When they arrived there, Respondent Joel Reyes gave Bomar PlOO/OOO.OO and told him "Kailangan mawala na dahil sakin na ng ulo", and this meant killing Dr. Ortega.

- This proves that as close-in security of Respondent Joel Reyes, Bomar knew the whereabouts of Respondent Joel Reyes as in fact, he always accompanied him every time he was in Manila.

- Respondent Joel Reyes, as a former Governor, 'Would never

allow Bomar know his

whereabouts if he never

considered him as his close-in security.

e} After that, they went

I to Ayala, Alabang to visit the house of Respondent Joel Reyes which was being

constructed, and they even talked to the architect.

If) From Ayala Alabang, they went back to Dasmarinas Village,

where he spent the night.

a) Bomar went to Salbakotah's house and there he met Marlon

Ricamata, a.k.a.

"PUSA" and his

companion Dennis

Aranas and talked about killing Ortega.

b) Bomar promised to give P150,000.00 for the killing of Dr. Gerry Orte a. He also ave

BASED ON THE SINUMPAANG SALAYSAY OF ARMANDO NOEL ("SALBAKOTAH") DATED 13 FEBRUARY 2011

1) In paragraph 75 (S) of his Sinumpaang Salay say, Salbakotah stated that on he introduced Alyas "Pusa" to Bomar.

2) In paragraph 76 (S) of his Sinumpaang Salaysay, Salbakotah that

initial payment of PIO,OOO.OO each for Recamata & Dermis Aranas.

Page 19 of48


after introducing Alyas Pusa to Bomar, Salbakotah and Pusa went to Dennis Aranas.

3) In paragraph 77 (5) of his Sinumpaang Salaysay, Salbakotah stated that they discussed with Dennis Aranas the plan to kill Dr. Gerry Ortega. Dennis Aranas askedhim about the background of Dr. Ortega.

4) In paragraph 78 (5) of his Sinumpaang Salay say, Salbakotah stated that after telling him that he would be paid PIO,OOO.OO as initial payment, Dennis Aranas agreed to perform the job to kill Dr. Ortega.

- This proves that the statement of Bomar - that Salbakotah recommended Alyas "PUSA" to finish the job to kill Dr. Ortega- was substantially corroborated In material points.

- This proves that the statement of Bomar --that he promised to give P150,OOO.OO for the killing of Dr. Gerry Ortega and gave initial payment of P10,ooa.ao each for Recamata & Dennis

Aranas - was substantially

corroborated m material points.

Page 20 of48


2) In paragraph 144 (S) of his Sinumpaang SaIaysay, Arandia stated. that he saw Bomar gave "FUgA" and Dennis Aranas PlOfOOO_OO each.


28 FEBRUARY 2011

1) In paragraph 144 (S) of his Sinumpaang Salaysay, Arandia stated that he went to Salbakotah's house and found out that the two (2) men hired by Salbakotah to replace them to finish the job was named "PUSA" and Dennis Aranas.

- This corroborates the statement of Salbakotah that he talked to "PUSAN and discussed with him the plan to kill Dr. Ortega.

- This proves that the statement of Bomar --that he promised to give P150,OOO.OO for the killing of Dr. Gerry Ortega and gave initial payment of P10,OOO.OO each for Recamata & Dennis


corroborated in material

points.

- This corroborates the statement of Salbakotah that PUSA and Aranas were paid P10,OOO.OO to do the job to kill Dr. Ortega.

Page 21 of48


- This proves that the statement of Bomar --that he promised to give P150,OOO.OO for the killing of Dr. Gerry

Orrega ~?

3) In paragraph 19 (S) of

his Sinumpaang Salaysay, I

Recamata identified

Dennis Aranas as his i

companion in. performing

the job and he was also given PIO,OOO.GO as initial payment.

BASED

ON

THE

SINUMPAANG SALAYSAY OF MARLON RECAMATA DATED

24 TANUARY 2011

1) In paragraph 16 and 17 (S) of his Sinumpaang Salaysay, Recamata stated that Salbakotah hired him to kill Dr. Gerry Ortega.

2) In paragraph 18 (S) of his Sinumpaang Salaysay, Recamata stated that they were promised payment in the amount of PI50,OOO.OO and as initial payment, thy were given PI0,OOO.ao each.

- This corroborates the statement of Bomar that Salbakotah recommended "PUSA" to finish the job to kill Dr. Ortega.

- This corroborates the statement of Salbakotah and Bomar that they talked to "PUSA" and discussed with him the plan to kill Dr. Ortega.

Page 22 (j)f48


c) Bomar told them to leave immediately & go to Nonoy Regalado to get the gun.

payment of PlO,OOO.OO each for Recamata & Dennis


corroborated in material

points.

This corrobora~s the

statement of SalbaJrotah that PUSA and Arenas 1l'ere paid PIG,OOO.OO to do the job to kill Dr. Ortega.

BASED 0 THE SINUMPAAN G SALAYSAY OF ARTURO REGALADO DATED

9 FEBRUARY 21011

1) In paragraph 40 (5) of his Sinumpaang Salaysay, Regalado stated that Bomar called him and asked him to look for a gun.

2) In paragraph 54 (5) of his Sinumpaang Salaysay, Regalado stated that Bomar called him and asked him to look for a gun, particularly a .45 caliber gun.

3) In paragraph 45 to 49(S) of his Sinumpaang Salaysay, Regalado stated that he talked to Eric (Atty. Seraiubias' driver) and found out that Atty. Seratubias was selling his gun.

4) In paragraph 54 (5) of his 5inumpaang Salaysay, Regalado stated that he talked to Val Lecias who in turn, called Atty. Seratubias and asked

c) Bomar sent P20,OOO via Lhuiller to buy .45 caliber gun addressed to certain "Kumpare" of Noynoy Regalado.

Page 23 of48


about the gun he was selling.


statement oj Bomar that he assigned Regalado to get a gun, which will be used for killing Dr. Ortega.

BASED ON THE SINUNIP AANG SALAYSAY OF PERCIVAL LEeIAS DATED

26 TANUARY 2011

1) In paragraph 04 (S) of his Sinumpaang Salay say, Lecias stated that he was asked by Regalado to get the gun from Atty. Seratubias.


statement of Regalado that he talked to Val Lecias who in turn, called Atty. Seratubias and asked about the gun he was selling.

BASED ON THE SINUMPAANG SALAYSAY OF ARTURO REGALADO DATED

9 FEBRUARY 2011

1) In paragraph 58 (5) of his Sinumpaang Salaysay, Regalado stated that Quintin Pasia gave him the money which was used in buying the .45 caliber gun.

2) In paragraph 62 (S) of his Sinumpaang 5alaysay, Regalado stated that the money was sent by Bomar to Quntin Pacia throu h

Page 24 of48


M. Lhuillier Pawnshop.

This proves that the statement of Bomar--that he sent money through M. Lhuillier Paumshop-: was substantially corroborated in material points.

- This proves that the rrwney which Bomar sent was addressed to Quintin Pacia, Bomar's "kumpare".

BASED ON THE SINUMPAANG SALAYSAY OF QUINTIN PACIA DATED

26 TANUARY 2011

1) In paragraph 10 (S) of his Sinumpaang Salaysay, Pacia stated that he was asked by Regalado to withdraw the money (P20,OOO.OO) from M. Lhuillier Pawnshop which was addressed to his name.

2) In paragraph 10 (S) of his Sinumpaang Salaysay, Pacia Pacia stated that after getting the money, he gave it to Regalado at Aborlan.

3) In paragraph 08 (S) of his Sinumpaang Salay say, Pacia Pacia stated that he

personally gave the

money and its

corresponding receipt to Regalado.

This proves that the statement of Bomar--that he sent money through M. Lhuillier Pawnsho--

January IB, 2011

a) Bomar bought three (3) plane tickets from Cebu Pacific at SM Lucena for flight to Palawan on January 19, 2011 for:

-Marlon De Chavez

-Dennis Aranas

-Armando Noel

Page 25 of48


substantially corroborated In material points.

- This proves that the money which Bomar sent 'was addressed to him, bein»

<6

B f uk " omar s umpare.

Documents corroborating Bomar's testimony;

1) Passenger and Bag Manifest of Zest Air

(Annex "E")

2) MH Lhuiller Pawnshop Receipts (Annex "F")

3) Acknowledgment Receipt of Sale of gun. (Annex HA'I of Att).l Seratubia's Affidavit)

- This proves that the statement of Bomar that he sent money to Palawan to be used for buying the .45 caliber . i gun was substantially corroborated, not just by the testimonies of Regalado and Pacia, but also but also by other independent documen tary evidence.

BASED ON THE SINUMPAANG SALAYSAY OF ARMANDO NOEL (HSALBAKOTAH") DATED 13 FEBRUARY 2011

1) In paragraph 84 (5) of his Sinumpaang Salaysay, Salbakotah stated that Bomar bought plane tickets from Cebu Pacific

- This corroborates the statement of Bomar that pursuant to the plan to kill Dr. Ortega, he bouKht ticket~

dffij )C_ )

Page 26 of48


,fanuary 19, 2011

a) Bomar rented a van and accompanied them to NAIA Airport Terminal 3 for their

, flight to Palawan.

r

Cebu Pacific for Marlon Recamaia, Dennis Aranas, and Armando Noel for their flight to Puerto Prinsesa; Palawan.

BASED ON THE SINUMPAANG SALAY SAY OF ARMANDO NOll. (HSALBAKOTAH") DATED 13 FEBRUARY 2011

1) In paragraphs 85 to 90 (S) of his Sinumpaang Salay say, Salbakotah stated they went to Manila using the van rented by Bomar.

BASED ON THE SINUMPAANG SALAYSAY OF MARLON RECAMATA DATED

24 TANUARY 2011

1) In paragraph 21 (S) of his Sinumpaang Salay say, Recamata stated that on January 19, 201 0, they went top Manila for their flight to Puerto Prinsesa. He also stated that that they boarded a Cebu Pacific airplane.

BASED ON THE SINUMPAANG SALAYSAY OF DENNIS ARANAS DATED

22 FEBRUARY 2011

1) In paragraph 21 (S) of his Sinumpaang Salaysay, Aranas stated that on January 19, 2010, he, Bomar, Salbakotah, and Tagar [Recamata] went to

b) Salbakotah called Bomar and informed him that they have

already arrived at

Palawan and they

checked In at Bundal Inn.

lanuary 21,2011

a) Bomar received text message from Respondent Joel Reyes stating that, "Sana paguwi ko ay tapos na ang problema"

Page 270f48


BASED ON THE COUNTERAFFIDA VIT OF 10EL T. REYES DATED 31 MARCH 2011

1) In his Counter-Affidavit, Respondent Joel Reyes admitted that he would occasionally exchange text messages with Bomar.

Manila using the van rented by Bomar.

Passenger I Bag Manifest of' Cebu Pacific indicating that Marlon De Chavez, Denis Aranas and Armando Joel went to Palawan on board Cebu Pacific Airline on January 19, 2011.. (Annex "GIf)

BASED ON THE SINUMPAANG SALAYSAY OF ARlvIANDO NOEL ("'SALBAKOTAH") DATED 13 FEBRUARY 2011

1) In paragraphs 105 (S) of his Sinumpaang Salaysay, Salbakotah stated that he talked to Bomar and he was told to transfer at Bundal Inn for accornodation.

- This proves that the statement of Bomar hired men to go to Palawan to kill Dr.

Ortega was substantially

corroborated In material

points.

This can be verified and validated by the Phone Records of Respondent Joel T. Reyes with Globe No. 09175312222.

lanuary 22,2011

a) Bomar stated that Salbakotah sent him text messages informing him of their movements in Palawan.

lanuary 23, 2011

a) Salbakotah went to Bomar's house m Pagbilao after he got back from Palawan.

Tanuary 24, 2011

BASED ON THE COllNTERAFFIDA VIT OF lOEL T. REYES DATED 31 A1ARCH 2011

a) Exchange of text messages between

a) Bomar and N onoy

b) Bomar and JTR

c) Bomar and

Salbakotah

regarding the execution of the plan to kill Dr. Gerry Ortega.

1) In his Counter-Affidavit, Respondent Joel Reyes admitted that he exchanged text messages with Bomar while he was abroad.

2) In paragraph 46.11 of his b) After Dr. Gerry Counter-affidavit, he admitted Orte a was killed, that Bomar was asking

This was corroborated by

Recamata, Aranas and

Salbakotah in their

respective affidavits. They narrated their movements in Palawan before, during and after the killing of Dr. Gerry Ortega,

BASED ,oN THE SINUMPAANG SAIA¥SAY OF ARMANDO ~·~OEL ("SALBAKOTAH") DATEn 13 FEBRUARY2011

1) In paragraphs 108 to 112 (S) of his Sinumpaang Salaysay, Salbakotah stated that Bomar sent him P4,OOO.OO via M Lhuillier to be used for buying his plane ticket back to Manila. When he arrived, he went to Bomar at his house in Pagbilao.

- This proves that Salbakotah regularly reported to Bomar and informed him of all their movements before, during, and after the killing of Dr. Ortega.

Photo of text message sent by Salbakotah asking if the target was already dead. . (Annex "H")

BASED ON THE SINUMPAANG SALAYSAY OF ARMANDO NOEL ("SALBAKOTAHtr) DATED 13 FEBRUARY 2011

1) In paragraphs 21 and 22(S) of his Sinum aan

Bomar packed up his financial support from him. bag, fetched Salbakotah

and hid at Fresh Air 3) Respondent Joel Reyes also Hotel, Lucena City. admitted that he ordered Bomar to go to his brother who will give him the money Bomar was asking for.

c) Bomar sent text message to Respondent Joel Reyes askng for financial support. In reply, Respondent Joel Reyes told him to go to Resorts World Manila. When they got there, he received a text message from Respondent Joel Reyes and he told him to go to his brother's house at 701 Parola Street, Ayala Alabang, Muntinlupa.

d) Bomar rented a van

and went to

Respondent Mayor

Mario Reyes' house in Ayala Alabang and met him and his wife there. Ma yor Mario Reyes gave P500,OOO.OO.

Page 29 of48


4) Respondent Joel Reyes admitted that he asked his brother to give Bomar money.

- These admissions confirm and validates the statement of Bomar that he was in constant communication with respondent Joel Reyes.

- These admissions confirm the statement of Bomar that he was a close-in security of Respondent Joel Reyes. As close-in security of Respondent Joel Reyes, he knew where his brother, Respondent Mario Reyes lives.

5alaysay, 5albakotah stated that he, Arandia and Bomar went to Fresh Air hotel to hide.

2) In paragraphs 23 to 26

of his 5inumpaang

Salaysay, Salbakotah

stated that on January 24, 2011, they went to Ayala Alabang.

- The statements prove that because of fear for their lives, they went to Fresh Air Hotel and hid there after Dr. Gerry Ortega was killed.

- This corroborates the statement of Bomar that he was asked by Respondent Joel Reyes to go to his brother Respondent Mario Reyes at Ayala Alabang to get the money.

- These admissions also confirm - This corroborates the the statement of Bomar that statement of Bomar that Respondent Joel Reyes ordered the Respondent Joel Reyes killing of Dr. Gerry Ortega. financed the expenses used in the killing of Dr. Gerry Ortega.


28 FEBRUARY 2011

1) In paragraph 154 (5) of his 5inumpaang 5alaysay, Arandia stated that he went with Bomar to Fresh Air Hotel at Lucena City.

2) In paragraph 156 (5) of his 5inumpaang 5alaysay, Arandia stated that they

- These admissions also proves that after ordering Bomar to find people who will kill Dr. Ortega, he gave him money to be used in executing the plan to kill him.

- These admissions confirm the statement of Bomar that being in constant communication with Respondent Joel Reyes, the latter was the one who ordered him to go to Respondent Mario Reyes' house at Ayala Alabang.

- These admissions also confirm the statement of Bomar that upon instruction of Respondent Joel Reyes, Bomar went to Ayala Alaban to meet his brother

Page 30 of48


Mario Reyes.

BASED ON THE COUNTER- - An entry fyom the AFFIDA VIT OF MARlO T. Logbook of the age REYES DATED 31 MARCH indicating that Bomar "\ Tent

2011 to Ayala, Alabang 0 January 24, 20'11.. (Annex

- These admissions also confirm

the statement of Bomar that upon - This corroborates the instruction of Respondent Joel statement of Bomar that Reyes, Bomar went to Ayala Respondent Joel Reyes Alabang to meet his brother financed the expenses used in Mario Reyes. the killing of Dr. Gerry

Ortega.

2) In paragraph 5 of his Counter-Affidavit, Mayor Mario Reyes admitted that Bomar went to his house and he gave him money.

1) In paragraph 5 of his Counter-Affidavit, Mayor Mario Reyes admitted that he received a text message from Respondent Joel Reyes on January 24, 2011 asking him if he could lend him money.

- These admissions confirm the statement of Bomar that he 'was a close-in securitu of Respondent Joel Reyes. As close-in security of Respondent Joel Reyes, Respondent Mario Reyes allowed Bomar to go to his house and even gave him money.

Tanuary 25,2011

a) Bomar and his companions went back to Lucena City.

b) Bomar gave Marlon Ricamata and Salbakotah money in the amount of

went to 701 Parola St., Ayala Alabang.

"I")

- This can be verified by Phone Records of Respondent Joel T. Reyes indicating that he was in constant communication with Bomar.

j

- The statements prove that because of fear for their lives, they went to Fresh Air Hotel and hid there after Dr. Gerry Ortega u as killed.

-This corroborates the statement of Bomar that he was asked by Respondent Joel Reyes to go to his brother Respondent Milrio Reyes at Ayala Alabang to get the

money.

BASED ON THE SINUMPAANG SALAYSAY OF ARMANDO NOEL (JISALBAKOTAH") DATED 13 FEBRUARY 2011

1) In paragraph 139 (5) of his Sinumpaang Salaysay, Salbakotah stated that when they go

Page 31 of48


P20,OOO.OO each.

c) Bomar and his companions checked out from Fresh Air Hotel

d) Bomar and Respondent Joel Reyes exchanged text message. Bomar was asking for Respondent Joel Reyes' help and told him that there are people after him.

Fresh Air Hotel, Lucena City, Bomar gave him and Arandia P20,OOO.OO each.

- This corroborates the statement of Bomar Ilmt Respondent Mario RelJes gave him substantial amount of

money In the P500, 000. 00

- This corroborates "

statement of Bomar tlud:

Respondent Joel RelJes financed the expenses used in the killing of Dr. Gerry Ortega.


28 FEBRUARY 2011

1) In paragraph 162 (5) of ills Sinumpaang Salaysay, Arandia stated that Bomar gave him and Salbakotah P20,OOO.OO each

2) In paragraph 162 (5) of his Sinumpaang Salaysay, Arandia also stated that he saw Bomar gave money in the amount of P65,OOO.OO to Salbakotah's brother, Albert Noel. Bomar instructed him to send the money to Dennis Aranas.

- This corroborates the statement of Bomar that Respondent Mario Reyes gave him substantial amount of money In the amount of P500, 000. 00

Page 320148



statement of Bomar that Respondent Joel Reljes financed the expenses used in the killing of Dr. Gerry Ortega.


statement of Bomar tlmt after receiving the money fhn1f. Respondent Mario Reyes, he gave partial amounts to his companions Arandia and Salbakotah.

BASED ON THE SINUMPAANG SALAYSAY OF DENNIS ARANAS DATED

22 FEBRUARY 2011

1) In paragraph 42 (5) of his 5inumpaang 5alaysay, Aranas stated that he sent a text message to Salbakotah and asked him to send him money.

2) In paragraph 44 (5) of his Sinumpaang Salaysay, Aranas stated that he was sent P 50,000.00 through Smart Padala.


statement of Bomar that Respondent Joel Reyes financed the expenses used in the killing of Dr. Gerry Ortega.


statement of Bomar that after receiving the money from Respondent Mario Reyes, he gave partial amounts to his companions.

e) Bomar and his group parted ways. He went in hiding to Lopez Quezon and stayed there until he voluntarily surrendered on February 5, 2011.

f) While in hiding, Bomar sent a text message to Respondent Joel Reyes saying "Ano pong dapat kong gawin, wanted na po ako. /1 Respondent replied to him using a different number (09189169059) and told him "abogado magaling" .

Page 33 of48


- This corroborates the statement of Arandia that he saw Bomar gave money in the amount of P65,OOO.OO to' Salbakotah's brother, Albert Noel and that Bomar instructed him to send the money to Dennis /vmnae.

12.) The illustration shown above would easily prove that my allegations

against respondent former Palawan Governor Joel T. Reyes and respondent

former Governor Jose Antonio Carrion are not only fully supported and

corroborated by independent evidence but also admitted in some aspects by the

respondents themselves.

13.) Considering the various independent pieces of evidence corroborating my

allegations, certainly, my statements are binding against Respondents Joel Reyes

and Jose Antonio Carrion. My lawyers told me that this is very clea

Page 34 of48


30 of the Rules of Court which states that as an exception to the principle of Res

Inter Alios Acta, the admissions of a co-conspirator relating to the conspiracy

may be given in evidence against a co-conspirator after the conspiracy is shown

by evidence other than the act or declaration.

14.) They said that in the case of People of the Philippines vs. Rolusape Sabalones alias

"Roling, H Artemio Timoteo Beronga, Teodulo Alegarbes and Eufemio Cabanero, the

Supreme Court declared that:

"The well-settled rule is that the extrajudicial confession of an accused is binding only upon himself and is not admissible as evidence against his coaccused, it being mere hearsay evidence as far as the other accused are concerned. But this rule admits of exception. It does not apply when the confession, as in this case, is used as circumstantial evidence to show the probability of participation of the coaccused in the killing of the victims or when the confession of the co-accused is corroborated by other evidence."

15.) This was reiterated in the case of People v. Condemna (L-22426, 29 May 1968,

23 SCRA 910; People v. Pareja, L-21937, 29 November 1969,30 SCRA 693), and People

v. Paz, (L-1 5052-53, 31 August 1964, 11 SCRA 667; People v. Agdeppa, L-17489, 24

December 1969, 30 SCRA 782), where the Supreme Court declared that "While the

general rule is that an extra-judicial confession of an accused is binding only

upon himself and is not admissible against his co-accused, it has been held that

such a confession is admissible against a co-accused where the confession is

used as circumstantial evidence to show the probability of participation by the

Page 35 of48


co-conspirator and where the co-conspiratorts confession is corroborated by

other evidence."

16.) The importance of corroboration is emphasized in the case of People of the

Philippines vs. Roger Victor @ "Ger" and "Gerry", et. al. (GR. No. 75154-55 Febnlary

6, 1990 citing People v. Tabayoyong, L-31084, May 29, 1981,104 SCRA 724 and People

v. Cuya, L-33046, 18 Februanj 1986, 141 SCRA 351)], where the Supreme Court

declared tha t:

"In determining the weight and sufficiency of the testimony of a self-confessed co-conspirator implicating his co-accused, it has been held that such testimony cannot by itself and without corroboration be considered as proof to a moral certainty that the latter had committed or participated in the commission of the crime. It is required that the testimony be substantially corroborated by other evidence in all its material points. x x x It is also required that such testimony be credible." (underscoring supplied)

17.) "The general rule is that the testimony of a co-conspirator is not sufficient

for conviction unless supported by other evidence. The reason is that it comes

from a polluted source. It must be received with caution because, as is usual with

human nature, a culprit, confessing a crime, is likely to put the blame as far as

possible on others rather than himself. As an exception, the testimony of a co-

conspirator may, even if uncorroborated, be sufficient as when it is shown to

be sincere in itself, because given unhesitatingly and in a straightforward

manner and is full of details which by their nature could not have been the

result of deliberate after thought." (People v. Sarmiento, 69 Phil. 740 ci

Page 36 of48


v. Cuya, Ibid ; Also People v. Lanas, 93 Phil, 147, US v. Remigio, 37 Phil. 599, People v.

Bumanglag, 56 Phil. at 14; People v. Canete, L-30491/ 21 January 1972, 43 SCRA 14,

26; People v .. Aquino, L-27184, 21 May 1974, 57 SCRA 43, 48).

18.) In the case of People of the Philippines vs. Roger Victor @ "Ger" and "Gerru",

et. al. [(GR. No. 75154-55 Februarv 6, 1990 citing People v. Tabayoyong, L-31084, May

29, 1981,10'4 SCRA 724 and People v. Cuya, L-33046, 18 Februan) 1986, 141 SCRA

351)], the Supreme Court observed the requirements of credibility and

corroboration on material points of the evidence on record in deciding the case,

and declared that:

First of all, the uoluniariness of the testimony is beyond question. x x x

. '-..---"

Second, the testimony of Roger Victor is replete with details that only a participant in the crime could have known, such as, how and when Guneda proposed the commission of the crime (TSN, 26 September, 1985, pp. 26-29), how they first tried to rob Myles Castle (fSN, 26 September 1985, pp. 8-10); where they first examined the articles taken from the victim Charles Turner (Ibid, p. 33-35); how Turner uias killed; and who took custody of the loot (Ibid, pp. 29-35). All such details underscore the credibility of Victor's testimony (People v. San Miguel, L-30722, 31 July 19'81,106 SCRA 290) .

Third, the testimony of Roger Victor is corroborated in its material points by other evidence on record, to 'wit: the testimony of Captain Gem} Barias and Patrolman Marcos Florida that the weapon used in killing and the articles taken from the victim were in the possession of Roberto Montebon when he was arrested (TSN1 24 July 1985, pp. 15-16; 31 May 1985, pp. 9-30); the testimony of Artemio Panganiban [r., Supervising Ballistician of the NBI, that the .38 caliber "paltik" revolver taken from Roberto Montebon was the same weapon which fired the cartridge found in the possession of Roger Victor (TSN, 27 June 1985, pp. 11-56); the testimony of Carlita Lozada, the Sensaldo bus conductor, that Roger Victor and Roberto Montebon boarded his bus at Baljoon enroute to Cebu City (TSN, 26 June 1985, pp. 8-10); the testimony of Juanita Guneda Victor, wife of Roger Victor and a reiaiioe of accused-appellant Ceferino Guneda, that the latter and her husband knew each other and that they 'would often go to the market of Boljoon where according to Roger Victor, Guneda proposed the commission of the en

Page 37 of 48


(TSN, 26 July 1985, pp. 14-22); and, lastly, the testimony of Josefina Romero, corroborating that of victor. that both the latter and Montebon were among the customers in her store in the afternoon of 16 October 1984, before the crime 'was committed. AU these testimonies corroborate Victor's and serve to strengthen his credibility.

Finally, there is the extra-judicial confession of Roberto Montebon (Exhibit "Z"), SlLJOrn to by him before Judge Alfredo Buenconsejo of the Municipal Trial Court of Boljoon during the Preliminaru Investigation, which confession points to Guneda as the mastermind. As stated earlier, the latter argues that this confession is inadmissible for having been obtained through force, threat and intimidation. Roberto Montebon himself testified in open Court that he was maltreated or beaten up by the police and PC investigators Ieaoing him 110 choice but to sign the confession in question. (emphasis supplied)

19.) In their desperate attempt to extricate themselves from liability in

-'

orchestrating the plan to murder Dr. Gerry Ortega, Respondents even tried to

discredit the allegations in my Sinumpaang Salaysay by impugning my character

and stating that my allegations are inconsistent, as follows:

20.) In paragraph 8.5 of his Counter-Affidavit, Respondent Gov. Carrion stated

that I have pending criminal cases for rape, murder and qualified theft.

20.1) This is absolutely not true .. I have no. pending criminal

cases for rape and murder. As to the criminal case for qualified theft, I

admit that there was a case filed against me before the Office of the

Provincial Prosecutor of Lucena City, but THE SAlD COrvrPLAINT FOR

QUALIFIED THEFT WAS ALREADY DISMISSED!

21.) In his Counter-Affidavit, Respondent Gov. Carrion also denied that he

discussed with me the plan to kill Dr. Gerry Ortega while we were at his house at

Page 38 0/48

of Supplemental Affidcroit

Merville, Paranaque by stating that he was not in Manila on the last week of June

2010.

21.1) Contrary to his claim, I am absolutely sure that this incident

actually happened. It was sometime in the latter part of June 2010 when he

talked to me and told me about the plan to kill Dr. Ortega. We were at his

house at Merville, Paranaque when he informed me about this plan.

22.) In paragraph 8.3 of the Counter-Affidavit of Respondent Gov. Carrion, he

also stated "Mr. Manoy recently informed me that sometime last year (2010), Mr.

Edrad told him that lowed him (Mr. Edrad) P1 Million. Mr. ManDY did not report the

matter to me at that time since he thought it absurd and of no moment. Mr. Edrad's

claim is, of course, outrageous but it shows his character and frame of mind"

22.1) I maintain that Respondent Gov. Carrion owed me money.

However, contrary to his allegations, he owed me only P500,OOO.00 and

'--'

not PI Million Pesos.

22.2) As close-in security of Gov. Carrion for the past two (2)

years, I also served as his bag man. Thus, from time to time, Respondent

Gov. Carrion would give me money since I have a 10% share in the money

from the deliveries of Pharmaceutical companies in Marinduque, while he

gets 40% as his share.

Page 39 of48


22.3) The P500,OOO.OO which I lent him was supposedly to be used

for the operation of my mother. He had already paid me back P125,OOO.OO

in cash while he was paying the remaining balance of P375,OOO .. O by way

of giving me guns.

23 .. ) As to the allegations of Respondent Joel T. Reyes, I hereby maintain my

allegations in my Sinumpaang Salaysay and further clarify as follows.

24.) In paragraph 51 of his Counter-Affidavit, Respondent Joel Reyes stated

that I claimed that I was an ex-marine officer who was discharged from service

'-_./

following the failed Oakwood mutiny in 2003.

24.1) This allegation of Respondent Reyes is false. I never claimed

that I was a marine officer, more so, that I was discharged from service

foHowing the failed Oakwood mutiny in 2003. Nowhere in my

Sinumpaang Salaysay would show that at any point, I claimed that I was a

marine officer ... I was never part of the military force and I would never

claim such.

24.2) The truth is, I am a member of the "Guardians", a

brotherhood well-known in the Philippines. I became a member of the

said brotherhood when I became the dose-in security of Respondent Jose

Antonio Carrion. As most people know, Respondent Joel Reyes and

Respondent Mario Reyes are also members of Guardian fraternity.

Page 40 of48

of Supplemental Afftdavi t

25 . .) In paragraph 53 of his Counter-Affidavit, Respondent Joel Reyes stated

that I had an outstanding warrant of arrest for the crime of murder and estafa.

He also stated that "Far from being a credible uiitness. Bumar is a fugitive from justice

unworthy ofbelief".

25.1) This is absolutely wrong! I have no outstanding warrant of

arrest for murder, estafa or any other criminal case ... When I surrendered,

the National Bureau of Investigation, made a background check on me

and they failed to find any outstanding warrant for any criminal case

against me.

25.2) It is also not true that I am a fugitive from justice.

Respondents know that I voluntarily surrendered to the NBI in order to

ten the truth in this case. I was told that my testimony is instrumental in

searching for the real masterminds in the murder of Dr. Gerry Ortega.

-- 26.) In paragraph 46.1 and 46..2 of his Counter-Affidavit, Respondent Joel

Reyes denied that I was his close-in security. He stated that I applied to be part of

his security personnel but he turned me down. The fact that I was his close in

security had already been lengthily and exhaustively corroborated by

independent evidence above-stated.

27 . .) In paragraph 46.11 of his Counter-Affidavit, Respondent Joel Reyes also

denied that he gave me FIVE HUNDRED THOUSAND PESOS (P500,OOO.OO)

through his brother Respondent Mario Reyes. He however admitt

Page 41 of48


me money, but only FIVE THOUSAND PESOS (P 5,000.00), stating that I

borrowed money allegedly because my motorcycle was mortgaged and would

be repossessed / foreclosed if I didn't pay my debt. This is a complete lie!

27.1) First, my motorcycle was never mortgaged to anyone. It is

already old and dilapidated, now parked in my garage at home in Quezon

Province.

27.2) It is also not true that Respondent Joel Reyes gave me only

FIVE THOUSAND PESOS (P 5,000.00). Contrary to his claim, he gave me

a substantial amount of FIVE HUNDRED THOUSAND PESOS

(pSOO,OOO.OO) and this was contained in an envelope when it was handed

to me by his brother Respondent Mario Reyes. I would also not accept

only the amount of Five Thousand Pesos (PS,OOO.OO) considering that:

a) We traveled all the way from Quezon to Manila and

arrived at Ayala Alabang, Muntinlupa late at night.

If Respondent Joel Reyes' claim was true, why would I travel

all the way from Quezon to go to Resorts World Manila and

thereafter go to his brother's house at Ayala Alabang at the wee

hours of the night only to get a measly sum of FIVE THOUSAND

PESOS (P 5,OOO.00)?

b) At that time, I still had some jewelries that I could

pawn and easily get FIVE THOUSAND PESO

Page 42 0}48


would I still travel from Quezon Province to Ayala Alabang just to

get this small amount of money?

c) The measly sum of FIVE THOUSAND PESOS

(P5,OOO.OO) would never be enough to cover our expenses just to

go to Respondent Mario Reyes' house.

It must be stressed that I rented the van which we used in

going to Manila for the amount of THREE THOUSAND FIVE

HUNDRED PESOS (P3,500.00) excluding gasoline. exepenses for

our travel. In addition, we also spent around ONE THOUSAND

PESOS (P 1000.00) for our food when we stopped by at Pizza hut in

Resorts World Manila to eat With these, FIVE THOUSAND PESOS

ONLY would be barely enough to cover food and transportation

expenses.

d) After getting the money from Respondent Joel Reyes'

brother at Ayala Alabang, I gave several amounts of money to my

companions, broken down as follows:

- TWENTY THOUSAND PESOS each for Arandia and

Salbakotah or a total amount of FORTY THOUSAND

PESOS (P 40,000.00);

- SIXTY FIVE THOUSAND PESOS.(P65,OOO.00) was sent to

Dennis Aranas.

Page 43 of48


e) All these amounts were confirmed and admittedly

received by Arandia, Salbakotah and Aranas .. "Where would I get

the money to give them if respondent Joel T .. Reyes did not give me

the amount of FIVE HUNDRED THOUSAND PESOS

(P500,OOO.OO)?

28.) From the foregoing, simple common sense dictates that indeed FIVE

HUNDRED THOUSAND PESOS (P500,OOO.OO) and not only FIVE THOUSAND

PESOS (P 5,000.00) was given to me by respondent Joel T. Reyes who perhaps

wrongly believes that he could evade criminal liability by simply reducing the

amount of money that he gave to me. This is I think anaffront to the intelligence

of the members of the Honorable Investigating Panel.

29.) Contrary to the claims of Respondent Joel Reyes, the minor inconsistencies

in. my allegations in the Sinumpaang Salaysay dated 06 February 2011 do not at

all affect the credibility and veracity of my statements. While they may be some

<::-: inconsistencies as to some minute details, especially since my Sinumpaang

Salaysay was taken before the NBI at around evening which lasted in the wee

hours of the morning, these minor inconsistencies do not erase the fact that

Respondents Joel Reyes and Gov. Carrion were the masterminds in the murder

of Dr. Gerry Ortega.

30.) The fact that the minor inconsistencies do not affect the credibility of my

statements as to the truth behind the killing of Dr. Ortega was confirmed by the

Page 44 of48


Doe, II Eliseo Bi-Ay, Jr. Y Sarintas alias II Gideon, II [G.R. No. 192187, December 13,2010]

when it declared that:

"Truth-telling witnesses are not expected to give flawless testimonies, considering the lapse of time and the treachery of human memory. The Court has stated time and again that minor inconsistencies in the narration of witnesses do not detract from their essential credibility as long as their testimonies on the whole are coherent and intrinsically believable. Inaccuracies may in fact suggest that the witnesses are telling the truth and have not been rehearsed. Instead, they may even serve to strengthen their credibility as they negate any SuspICIOn that their testimonies have been fabricated or rehearsed." (emphasis supplied)

31.) This was reiterated by the Supreme Court in the case of People of the

Philippines vs. Alberto Lase, Alias II Bert" (G.R. No. 97957 March 5, 1993), where the

Supreme Court stated that "The alleged contradictions or inconsistencies in the

testimony of Cpl. Mitra relate to minor, if not inconsequential, matters. The rule

is settled that minor inconsistencies do not affect the credibility of

witnesses; 32 on the contrary, they may even heighten their credibility"

(emphasis supplied)

32.) In this light, it must be stressed that the Supreme Court declared that on

the contrary, minor inconsistencies are signs that the witness was not rehearsed

and that he was telling the truth when it declared in the case of People of the

Philippines vs. Arthur De Leon y Lagmay alias "[oel" (G.R. Nos. 124338-41 May 12,

2000) that:

Page 4S of48


"The inconsistencies pointed out are minor that cannot be considered as prevarication. On the contrary, minor inconsistencies are signs that the witness was not rehearsed and that she was telling the truth. "Inconsistencies in the testimony of witnesses, when referring only to minor details and collateral matters, do not affect the substance of their declaration, their veracity or the weight of their testimony. Although there may be inconsistencies on minor details, the same do not impair the credibility of the witnesses where there is consistency in relating the principal occurrence and positive identification of the assailants. II

33.) Respondents belittle my testimony and claim that I am a worthless and

incredible witness .. If this is true, then why would Respondent Joel T. Reyes'

lawyer, Atty. Ferdinand Topacio (Globe Mobile No. 0917-5976666) call me and

offer all the resources of his client in exchange for ensuring that I keep quiet

about the murder of Dr. Gerry Ortega? If this is true, I dare respondent Joel T.

Reyes to submit all his phone records, including the full transcript of our

exchange of text messages, to the Honorable Investigating PaneL This way we

would easily see who is telling the truth and who is the inveterate liar!

34.) If it is true that I am a worthless witness who falsely claims that I was his

former close-in security, then how else could have I known the following

personal details:

a) Respondent Joel Reyes is fond of color black. He has three (3) vehicles, a Toyota Fortuner, Jaguar and a Rubicon Wrangler-all colored black. He also wears the color black in most of his outfits.

b) Respondent Joel Reyes has a mistress who stayed in Charter House Makati where we brought her food ..

Page 46 0/48


c) Respondent Joel Reyes has an apartelle near Palawan Center, Makati.

We often go to this Apartelle because he has a mistress who stayed there at that time.

d) The house in Dasmarinas Village is owned by Respondent Joel Reyes' mother-in-law Atty. Clara Espiritu. Both the families of Chito Espiritu and Respondent Joel Reyes live here.

e) Since most of the time, we were at the house of Atty. Clara Espiritu every time Respondent Joel Reyes was in Manila, I am already familiar with their household helpers. They have four (4) household helpers, two of whom were named Hilda and Marlyn. They also have three (3) drivers at Dasmarinas Village named Jay (the personal driver of Atty. Clara Espiritu), Gary (personal driver of Respondent Joel Reyes' sister-inlata) and Edwin (personal driver of Respondent Joel Reyes' 'wife Phem Reyes)

f) Everytirne Atty. Clara Espiritu would leave the house, she would always bring with her Marilyn (one of her household helpers) and her driver Jay.

g) The drivers - Gary, Edwin and Jay - and I all stayed in the house of Atty. Clara Espiritu. I stayed in the room with Jun Cabalsa, Jay and Edwin and we slept in our respective places in the two double-deck beds inside our room/quarter.

h) They have two dogs named Kobe and Shasha.

35 .. ) In view of all the foregoing, I sincerely believe that my statements are

solid, credible and fully corroborated in all its material points by independent

evidence. I must admit that I was a part of a criminal conspiracy to kin Dr. Gerry

Ortega involving former Governors Joel T. Reyes and Jose Antonio Carrion as

Masterminds, I myself as Project Coordinator, Armando Noelalyas Salbakotah,

Arwin Arandia, Dennis Aranas and Marlon Recamata as the hired killers.

36.) I know I did a terrible wrong to the family of Dr. Gerry Ortega for which I

know no amount of apology would suffice to ease the pain for the loss of the

Page 47 of48


head of their family .. My only hope is that by telling the truth, I would somehow

be able to help them find justice which they rightfully deserve.

37.) I have been offered no less than nvENTY FIVE MILLION PESOS

(P25,OOOO,OOOO.OO) in exchange for recanting my previous statements against the

masterminds of the murder of Dr. Gerry Ortega. I have refused and will continue

to refuse, any bribe offered to me. The truth cannot be bought. I will not and will

never recant. If I ever do, for reasons of safety of my family and loved ones, this

early, I already request the Honorable Investigating Panel or the Honorable

Court to receive any recantation with extreme caution as it would never be a

product of my free will.

38.) I am executing this Supplemental Counter-Affidavit to attest to the truth

of all the foregoing statements and in support of finding the truth in the murder

of Dr. Gerry Ortega.

AFFIANT FURTHER SA YETH NAUGHT.

IN 'WITNESS 'WHEREOF, I have hereunto affixed my signature this 15th

day of April 2011 at the Department of Justice, Manila.

Page 48 of48


SUBSCRIBED AND SWORN to before me this 15th day of April 2011 at

the Department of Justice, Manila.

CERTIFICATION

I HEREBY CERTIFY THAT I HAVE HEREUNTO EXAMINED THE

AFFIANT AND THAT I AM SATISFIED THAT HE VOLUNTARILY

EXECUTED AND UNDERSTOOD THE CONTENTS OF HIS

SUPPLEMENT AL AFFIDAVIT.

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ANWEXMC.

Republika ng Piiipinas

(Republic of the Philippines) Kaqawaran ng Katarungan (Department of Justice) PAMBANSANG KAWANIHAN NG PAGSISIYASAT (NATIONAL BUREAU OF INVESTIGATION) Manila

NBlj07.0

Tanggapan ng Patnugot (Office 0" he Director)

09 February 2011

Atty. RONALD LEDESMA

Conun issioner

Bureau oj Immigration and Deportation Manila City

i\

\,

Sir;

In connection with the investigation being conducted by this Bureau on the alleged killing of Dr. GERARDO "Gerry" ORTEGA, may we please be furnished with an official certification as to whether M _RIO JOEL T. REYES; Birthdate: October 19, 1952 and JACQUELI E REYES; Birthdate: January 16, 1987 have a departure record in the month of January 2011.

Your preferential attention on matters of public concern will be highly appreciated.

Vel)' truly, ours,

Atty. fIACTAl GGOL B. GATDULA '-" Director

For ~i9tm y///

t:«: __ .A _ _'/'v/\'// ,-,/

!/tAtty. RUEL M, LASALA

DrPUIy Director for Intelligence Services

L

Republika ng Pilipinas

(Republic of the Philippines) Kagawaran ng Katarunqan (Departmen.t of Justice) PAMBANSANG KAWANIHAN G PAGSISIYASAT (NATIONAL BUREAU OF INVESTIGATION) Manila

Tanggapan ng patnugot (Office of the Director)

NBl2020

09 February 2011

Atty. RONALD LEDESMA

Commissioner

Bureau of Immigration and Deportation Manila City

. "

su,

"-:rn connection with the investigation being conducted by this Bureau on the alleged killing of Dr.

GERARDO' GetTY' ORTEG , may we plea e be furnished with an official certification as to whether MARIO JOEL T, REYES; Birthdate: October 19. 1952 and JACQUELI E REYES; Birthdate: January l S, 1987 have a departure record in the month of January 2011.

Your preferential atten ion 011 matters of public concern will be highly appreciated.

Very truly vour I

Atty. MAGTANGGOL B. GATDULA Director

'-.....--

r"> // ..

For~{D7tO< e.:

~J'--'/\"/V" t_......

/It-A ty. RUEL 1\1. LASALA

D .puty Directorfor Intelligence Services

REPUBLIC OFTH.E PHILIPPiNES DEPARTMENT OF JUSTICE

BUREA.U OlF ~GRA1fION MAGALLANES DRIVE. TNTRAMUROS

1002 MANILA

February 14, 2011

Control No. 021420110SP0976G

CERTIFICATIO'N

THIS IS TO CERTIFY THAT the name REYES, JACQUELINE ESPIRITU appears in our available Computer Database File with the following travel records:

Date of Departure : 01/10/2011

Flight No. : KL804-KLM ROYAL DUTCH AIRLINES

Destination : NOT AVAILABLE

Passport No. : XX0357508

Date of birth : 01/16/1987

Nationality : PHL-FILIPINO

Phil. Address : NOT AVAILABLE

Immig. Status : NOT AVAILABLE

Immigration Officer: MALICSE

This certification is issued upon request of Atty. Ruel M. Lasala, Deputy Director for Intelligence Services, National Bureau of Investigation, Manila for whatever legal purpose it may serve.

Verified by : Manalo A. Melendres

Date & Time: February 14,2011.

Computer Sectlon-Main 11 :31am

ISSUED GRATIS

www.imrnigiation.gov.ph

REPUBLIC OF THE PHlLlPPINES DEPA~T IE T OF JUSTICE

Bl]REAU OF IMMlGRA nON MAGALLANES DRIVE. INTRAMUROS

1002 MANILA

February 14, 2011

Control No. 021420110SP0975G

CERTIFICATION

THIS IS TO CERTIFY THAT the name REYES, MARIO JOEL TOLENTINO appears in our available' Computer Database File with the following travel records:


Flight No. : KL804-KLM ROYAL DUTCH AIRLI ES


Passport No. : XX0359286


ationality : PHL -FILIPI 0

Phil. Address : NOT IWAILABLE

Irnrniq. Status : NOT AVAILABLE


This certification is issued upon request of Atty. Ruel ,Lasala, Deputy

Director for Intelligence Services, National Bureau of Investigation, Manila for whatever legal purpose it may serve.

Verified by : Manolo A. I ~elendres

Date & Time: February 14, 2011

Computer Section-Main 11:28am

ISSUED GRATIS

SI~~EZ

feting Chier, Verification and Certification Unit~,i '/

.J

--~--"-' - _._-_-

REPUBUC OFTHE PHILIPPINES DEPARTMENT OF JUSTICE

BUREAU or IMMIGRATION

MAGALLANES DRIVE, INTRAMUROS 1002 MANlLA

February 14, 2011

Control No, 021420110SP0976G

CERTIFICATION

THIS IS TO CERTIFY THAT the name REYES, JACQUELINE ESPIRITU appears in our available Computer Database File with the roliowlnq travel reeo ods:


Flight No. : KL8D4-KLM ROYAL DUTCH AIRLII ES


Passport 0, : XX0357508


Nationality : PHL-FILIPINO

Phil. Address : NOT AVAILABLE

Irnrnlq. Status : NOT AVAILABL.E


This certification ls issued upon request of Atty, Ruel M, Lasala, Deputy Director for Intelligence Services, National Bureau of Investigation, Manila for whatever legal purpose it may serve.

Verified by : Maholo A. Melendres

Date & Time: February 14, 2011

Computer Section-Main 11:31am

ISSUED GRA IS

sr~'z

Acting Chief, Verification and Certification Unit.ll

I .,; ..

(;

..... --.- ... ----~ .... ---~-----~-:.....___-~---------

iREPUBUC OF THp PHILIPPINES DEPARTMENT OF JUSTICE

BUREAU OF IMl\DGRATION

MAGALLANES DRIVE, INl'RAMUROS 1002 MAN!LA

ANNEX If'

March 02,2011

11111111111111111111111111111111111111111111111

,\<81·0/)2011 OOO! 635

Atty. MAGTANGGOL 13. GATDULA Director

National Bureau of Investigation Taft Avenue. Ermita

Manila, Philippines

Trunck liue No. +632-523-823.1

ATTIE TION: Atty.lRUEL Mo .LASALA

Deputy Directorfor intelligence Services

Dear Director Gatdula,

This refers to your request for travel records dated 09 February 2011. Based on verification from om available database file, the following are the result(s).

I. MARiO JOEL T. REYES 2. JACQUELINE REYES

ReSlIl( Record Found Record Found

~~. nothingfoitows *'0

Verified by:

Source/s:

Date:

Coverage:

Louella L. Luge & Djarnina D. Diampuan

BI-rvJain Computer SectionfNAIA I, II & III, MCIA, DMIA, AlA, DIA March 02, 2011/02:18 P.M.

Travel Records from January I, 1993 - March 1, 20 I J

However, multiple results with different middle names, addresses and / or passport numbers are providea bas,ed on the data or information given by the

, .

requesting government agency.

Please se attached document/s

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·_--_·_-··_·_·-1

I

ANNEX 11<

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Page i of 1

ANNEX

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U-U5 J ~~::U~:i~~'-

2SJanll 08:25

Fl i ght:

NavitaireTEOutPut

cebu Paci Fi c Ai I" Flight Close

539 MNLPPS Date: 19Janll/1545

By:asppsg324

===========~~~~~==~==========~~=~~=~~====~~======~====~==~~~=~=~=~=============~

Totals:

~1an . fested unconfirmed standby pax

Thru Manifested Th ru No shows Total Manifested

Inf, Manifested ehild Manifested Female Manifested ta l e Manifested

checkedin/80arded No shows

cleared Standby pax Thru Checkedin/Boarded

168 o 1 o o 169

o 11 67 91

o 169

Total Checkedin

Inf. checkedin/Boarded child checkedin/80arded Female checkedin/Boarded Male checkedin/Boarded

Flt Cpns Required

Total B~g weight

Flt cpns possible Total Bag Checked Pax checkedln by Zone

Displayed:l of 10 pages, Continue (y,n):

zone 1 Zone 2 Zone 3

110 1121 2231

Totals:

ent Name (i = I F) Checkedin/Baarded:

1 Raga, Aleks2 drs 2 Raga, Liene

3 saban, saturnina 4 BENTILLO, CAMELA 5 TRAMPE, MA LUZ

6 sinocruz, adrian

7 APALACIO, RAYMOND 8 BARSABAL, ADRIA NE 9 BARSABAL, MARY ANN 10 ESPINOZA, DANILO 11 Boncodin, Jer y

12 Alegria, Glenda

13 Sch~attenhol Z, Lars MU=move up. Displayed:2

M r- 28 21 3D 19 26 23

C TTL 4 53 1 50 ·5 54

I o 1 1

Fare Class

c C E E D E E D o E C E E

(Y,n):

14 GARCELLANO, HELEN 15 ADIO, ADREA REPALA 15 CHAN, SIU KUE I 17 YIP, TAl HO G 18 Lingat, Ayalon 19 Lingat. Freddie 20 CASTRO, FIDEL 21 GOBUYAN, JENNIFER 22 HUSOL, EDGARDO 23 VAFAJOIE, JIEBE BRYAN 24 ARANAS, DE NIS 25 DE CHAVES, t· ARLO 26 NOEL, ARMANDO 27 MUYUELA, ROMMEL 28 CABUNGCAL, LEONARDO 29 BALASOTE, HERALD GLENN 30 BALASOTE, HO ORIO 31 8ALASOTE, IFEMINDA 32 CHAN, GRACE 33 SIGZON, GENESIS 34 YAP, RICHIE 35 BRISTOL, LEONORA 36 BRISTOL SR, JIMMY

37 GOMARASCHI, ALBERTO NBWYUA 0

M =nove up. Displayed:3 of 10 pages, continue (y,n):

84 63 10 157

2

PNR

M7B2KM M782KM A828KW c52KJC 04CUHV EI.lFCQW F9M8VT

JCP2MK JCP2MK z620FS GFCWVR RBKEHA RBKEHA

of 10 pages, continue

MAR E

J9p8MT XBSy2N

GEVIQR GEVIQR ODGBNX ODGBNX A<\pvws G7K2QZ G7K2QZ Nc3~\QN N6SQVC N65QVC N65QVC G"CNVR P8ULH\1 2BSU7Q ZB5U70 ZB5U7Q ZBSU7Q v941RJ v941RJ W3HFML W3HHIL

seq No

Date

1 18)an11 2 18Janll 3 1'1)an11 4 BJanll 5 14Jan11 tJ 07Jan11 7 10Jan11 8 17Janll 9 17Jal 11

10 12Janll 11 18Jan11 12 12Jan11 13 12]an11

C E D D E E.

14 17Jan11 15 12Janll 161JJunl0 17 llJunl0 18 070ctlO 19 070ctlO 20 18)an11 21 17J<1n11 22 17)anll 23 17)anl1 24 1lJanll 25 17)an11 26 17Janll 27 16Jan11 28 17)an11 29 12Jan11 30 12)an11 31 12 Janll 32 12Janll 33 1B)anll 34 1B)anll ]S 10Janll 36 10)an11 37 17Jan11

\'1 C C C C C

c o Q Z z

z Z

IN I~ E

E

page 1

Seat

NO COst Flt

SA 56 BC

15F

SA 280 29c 2SA 25B

lc 6F llA 11B

OPPS OPPS OPPS OPPS OPPS OPPS OPPS OPPS OPPS Opps OPPS OPPS OPPs

GA Opps 80 OPPS IF OPPS lE Qpps lA OPPS 1B OPPS

19A OPPS lOA OPPS lOs OPPS 10c OPPS

5D OPPS SE OPPS SF OPPS 2F OPPS

120 OPPS lA OPPS 7B OPPS 7C Qpps 70 OpPS 2B OPPS 2c Qpps

1SA OPPS 15B Qpps 5B OPPS

157 11 o

o

157

o 10 63 84

1616

o

639 639 G39 639 639 639 639 639 639 639 639 639 639

639 639 639 639 639 639 639 639 639 639 639 639 639 639 639 639 639 639 639 639 639 639 539 539

.] ./

Nav;ta;reTEoutPut
38 NIERVA, ERMA NB\NUA D 38 17Janll 6c QpPS 639
39 OIOA, HORACIO HGT97z v 39 18J anll 'IF OPPs 639
40 OIDA, JOSEPHI E H6T97z V 40 18Janll 9E OPPS 639
41 OIOA, KAROL JO H6T97z V 41 IBJan11 90 OPPS 639
42 OIDA, KATHRINE H6T97z V 42 18Jan11 BF OPPs 639
43 OIDA, KRAMER ACE H6T97z V 43 18Janll BE QPPS 639
44 Cruz, conrado SS~T'N V 44 1BJanll 4F QpPs 639
45 1"10 TIMOR, REYNAlOO H8QGGG 0 45 15Janll 3F OPPS 639
46 de Jag e r, Ari e s9v3RG E 46 15DeclO 21A OPPS 639
47 de Jag e r , Rosita S9v3RG E 47 150eclQ 21B OPPs 639
48 oulla, Joseph F4Y29S 0 48 lSJanll 4A OPPS 539
49 Juniosa, Nolasco F4Y295 D 4') J_SJanll 4B OPPS 639
50 ZHOU, van F4 Y295 0 50 15Janll 4C Qpps 639
51 JOYA, KRISTINE JA E F8v3MG L 51 12Janll 20F OPPs 639
52 8AAL, CRISTDPHER SS8IKF E S2 QSJanll 7F QpPS 639
53 OMAGAP, RUOMAR SS8lKF E S3 QSJan11 7E OPPS 639
54 G.lIRAOOS, MARISSA U3RUJY V 54 lSJanll 9A OPPS 639
55 LAZO, NANCY M3M66v Q 5S IBJanll 20D OPPS 539
56 AC, EILl, JOHN GRA'T V6QEFP E 55 280eclO 6E OPPS 639
57 cho v , Barton Z4ZWUl E 57 2Soec10 19E OPPS 639
58 Chow, Starlet z4ZWOL ·E 58 25Dec10 19F OPPS 639
59 BDNOOC JR. , RAFAEL S8GSRQ D 59 lSJanll 22A OPPS 539
60 MARCO, MARLON SBGSRQ 0 60 lSJanll 22B OPPS 639
61 8acolod, camilo WBGPFQ E iiI I4)anll 240 OPPS 639
MU=n1ove LIp. Displayed:4 of 10 pages, Continue (y, n) :
62 Oliva, Joel WBGPFQ E 62 14]an11 24 E OPPs 639
63 oliva, Noel ~JBGPFQ E 63 14 an11 24 F OPPs 639
54 Alar-con, Jen;lee Anne A5H63M 0 64 10JUnlO 23F OPPS 639
65 DEGAWAN, MERlI 'OA P9FJY\>1 Z 55 l1Jan11 22c Qpps 639
66 DRQUEZA, DOUGLAS MBP3GN 0 66 17Jan11 22F OPPS 639
67 PEOIAPCO, AILEEN MFRHXR C 67 17Jan11 22E OPPs 639
68 PEOIAPCD, MARK NOlY MFRHXR c 68 17Jan11 22D OPPS 639
69 ClUZEL, JONATHAN PDHHYK L 69 19Janll 27E QpPS 639
..._ 70 PAJOT, CYNTHIA PDHHYK L 70 19Janll 270 OPPS 639
71 dela fuente, IVy ~,; chell E TD3K4x C 7J 02Nov10 16B OPPS 639
72 dela Fuente, Josephine T03K4x C 72 02Nov10 16c OPPS 639
73 Demaal a, lucena TD3K4X C 73 02NovlO 160 OPPS 639
74 RU/ILO, JHONA A6CJFM C 74 18Jan11 16A OPPS 639
7S CAPIlITAN, SARAH YIBJTE Q 75 18Janll ISo OPPs 639
75 ROJO, ERICA LAI E F4\~BSS c 76 QIAprl0 27A OPPs 639
77 ROJO, lALAINE F4wBSS C 77 01AprlO 27B OPPS 639
78 ROJO, PATRICIA LAI E F4wBSS C 78 0IApr10 27c OPPS 639
79 ROJO, PATRICK SAMUEL F4wBSS C 79 01AprlO 2BA QPPS 639
80 ROJO, RIC DANIEL F4wBSS C 80 01Apr10 288 OPPS 639
81 ROJO, RICARDO F4\~BSS C 81 01Apr-1O l8c OPPS 639
82 LA8ASAN, MARIWE 158LSP Z 82 llJanll 2A OPPS 639
83 Bal ior e s , Mary Jane SE49HH E 83 OSJanll 2SD Qpps 639
84 ao rcha rrtr , Jan SE49HH E 84 OBJanll 25E QpPS 639
85 TI'iller, Jor1 SE49HH E 85 08Janll 25F Qrps 539
MU=move up. Diso ayed:S of 10 pages. continue (y, n) :
86 PACHECO, :viA UEl pBTS3G E 85 05Janl1 2Sc OPPS 639
87 BABUT, Robin r89WQJ G 87 18Jan11 28F OPPS 639
88 CALOEIRO, Maria IS9WQJ G 88 18Jan11 281: Qpps 639
89 LIt~ , DID lClO JAMES LY718Q E 89 14Janll 10F QpPs 639
90 RELOX, ARNEL 08KJ?T C 90 18Janll 27F OPPS 539
91 BELTRAN, JACKIELOU J2L6KL E 91 13Janll 17A OPPS 639
92 MAC."SAET, JASSANI CCLMYK E 92 lZJanll 17B OPPS 639
93 PALAO, OMAR IAN CCLMYK E 93 12Janll l7c OPPS 639
...____., 94 ERCURIO, NIXD UECY7U V ')4 18Janll 26F Qpps 639
95 RACO, JDEMAR NYTNJQ ' E 95 06Janll 29F OPPS 639
96 ~ ENANO, RICHARD J9I3GT W 9G IBJanll 14F OPPS 639
97 STA FORTH, SIMON r9GTGT Q 97 19Janll 12 F QpPS 639
98 MIKLAucrCH, I~ATTHEW CRAIG p2Z8YB Q 98 19Janl1 12E OPP5 639
99 HERUELA, GUILLER VY2PPC; E 99 l3Janll 14E Qpps 639
100 , AGBANUA, GIL C2HZYL C 100 ISJanll llF QPPS 639
101 JAGI~IS . LOURDES T41L5F v 101 18Janll llE OPPs 639
102 ]USOS, Mary gold Z9KLVJ X 102 05Janll 17F Qpps 639
103 I i 1 5 S on, Ma r t i n Z9KLVJ X 103 05Janll 17E OPPS 639
104 Brechtel, Thomas T7NQK~1 C 104 02Nov10 12A OPPs 639
105 Compuesto, Ari S T7NQKM C lOS 02NOVIO 12B Qpps 639
106 BAGUYO, MARIA PAZ B5RL3M E 106 13Janll 26A Opps 639
107 GABO, CARMELITA B5RL3M E 107 Blanll 2GB 0 PS 639
108 GABO, GERA AY BSRL3M E 108 13Janll 25c OPPs 639
109 Ii, RTIN, TERESA SSRL3M E 109 13Jan11 26D OPPs 539
MU=move up. oisplayed:6 of 10 Pages, Contlnue (y,n):
page 2 110 VE TURILLO, LUNA 111 KIM, SANG GI

112 schuetze, ruth 113 DE TORRES, ERIC 114 ACOSTA, ROVELYN 115 /·1oral, Karen

116 WaSSE Andreas 117 CHEN, YIYEN

118 LEU, rTYNG

119 SHEN, HUIYU

120 TIAN, HSUANHAO 121 vee, Eunice Car a 122 chen, JUChi

123 ROSS, Maxx

124 CARLOS, TRIZ KHEN JOHN 125 CARLOS, MHEL JHUN

126 DUAY, KENNETH MAE

127 LAMANILAO, FELIX JR 128 Nguyen, Mal

129 jagercik, tomas

130 s i ou l ova , ivana

131 LATONIa, EDITHA

132 SISON, JONATHAN

133 Huang, LiYing MU=move up. Displayed;7

134 LEE, HANTSE

135 VEOAD, RICHARD

136 CLARITO, ARSELNA

137 CLAR TO, MEDAROQ

138 BOULHARI, MARCA A

139 INFANTE, FAITH NICOLE 140 LUCIO, GUADALUPE

141 gilong05, esperanza 142 gilongos, sherw'n ivan 143 trongco. merenc'ana 144 HALUSKA, JONATHAN

145 cayao, Dexter

146 VENZON, RAMON CARLITO 147 murphy, n i a l

148 smy th, 1 i am

149 van 8eijnen, Jonah 150 CABANILLAS, CRISTALYN lSI koch, john jr

152 rana, darious

153 CORTES, CAR~ELO

154 BUENCONSEJO, OEL

155 DICHOSO, JOHN REY

156 CABRERA, FLOROELUNA 157 ESPINOSA, LISETTE

MU=move up. oisplayed:B of 10

NO shows:

1 BAtBAO, CELIBRADO

2 BAMBAO, CEONCEPCION 3 UY, XAVIER

d UY, RONA MARIE

5 UY, XEDRIC REILLY {) HU, SHIYI

7 tanchoco, darwin

B tanchoco, anna linda 9 TULLAD, JERWIN

10 Ah , Hyun Chul

11 Bongolan, Charlton

NavitaireTEOutput

E 1]0 13Janll C III l8Jan11 Z 112 1.lJanll V 113 18Jan11 E 114 06Jan11 x lIS 06Jan11 X 116 06Jan11 C 117 i isovio C lIB llNovl0

C 119 llNovl0 c 120 llNovlO

C 121 llNov10 E 122 08J an 11 Z 123 12Jan11 Z 1.24 VJanll Z 125 12Jan11 Z 126 12Jan11 C 127 17Janll D 128 17Jan11 E 129 os iao u E 130 os iant.i o 131 lSjanll E 132 29Decl0 c 133 OlDeclO of 10 pages, continue (y,n):

B SRL.3M ZYUTRT N8QC5G AEIFJR P8NRQJ uB5BpD UB58PD

FFPWYB FFP\,fYB Frp\~YB FFPWYB

FFPIVYB F3NIV7F

IBFFVA CY4SJQ CY4SJQ CY~S.lQ H425NV DCN9HX TD7VHK TD7vHK OD9ETK S71T~t·

EYJGF/\

EYJGFA UYC790 TBlEQM T81EQM HBQBTN N69DGP N690GP B7Z67J 137Z67J 87Z67 J ~\y76XT UlZSQQ CyruxQ K3EJTY K3EJTY H5c9xs XB2cHO H7EE6J H7EE6J C32GJI JSNEIK J5NEMC EFYVYR EFYYYR

pages, Continue

CBBRVW CBBRVW C8aRvw C8BRVW CBBRVW

FFP\yYB J21L3Y J21L3Y MCRFtX V7QRPM Z4Z\'~UL

C 134 01oecl0 C 135 17Jal11 C 136 17 Janll C 13 7 17 Jan11 o 138 16Jan) l. Z 139 12Jan11 Z 140 12)an11

o 141 17Janl1

o 142 17Janll

o 143 17)an11 E 144 13)anl1 L 145 19Janl1 K 146 19J an11 C 147 18Jan11 C 148 1BJan11 D 149 15Jan11 C 150 17 J anll E 151. 14Jao11 E 152 14 ]an11 Z 15j IlJan11 K 154 19.1an11 K 15S 19)anll C 156 18)<1n11 C 157 18)an11

(y,n):

o o o o a

C

C C [ o E

o 100ctl0

o 100ctl0

o lOOctlO

o iooc ero

o lOOctl0

o llNovl0

o 02Apr10

o 02Aprl0

o 06Jan11

o 10Jun10

o 2.5Dec10

Thru CI eckedin/Boarded

There are 0 Thru Pax who have checkedin/Boarded. ,.

Thru NO shows

There are 0 thru No Shows on this flight ...

Unconfirmed

There are 0 unconfirmed on this flight ...

Cnt

Name (i = INF)

Fare priority

U=move up. Displayed:9 of 10 pages, Continue (y,n):

class

code page 3

PNR

Z6E OPPS 16F OPPS

9C OPPS 29A Orps 298 QPPS 18A QppS 18B Qrrs

30A OPPS 30B OPPS 30e QppS 300 OPPS

30E OPPS

30F OPPS 18F OPPs 24A QpPS 24B OPPS 24c OPP5 29D OPPS 2lF OPPS HF OPPS HE QpPs 29E OPPS 3lA OPPS

318 OPPS

31c OPPS ZIC OPPS 20A OPPS 208 OPPS 20c OPPs

3A OPPS 3B OPPS 3c OPPS 3D OPPS 3E OPPS

140 QpPS 170 OPPS 18D OPPS 210 OPPS ZIE OPPS 12C OPPS 15C OPPS 19B OPPS 19c Qpps 20E Qpps 10D OPPS 10E QpPS

4[ OPPS 40 OPPS

23A OPPS 231l OPPS 230 OPPS 23c OPPS 23E OPPS

OPPS OPPS OPPS OPPS OPPS

190 Qpps

Date

Ost

'1/

. "

639 639 639 639 639 639 639

639 639 639 639

639

639 639 639 639 639 639 639 639 639 639 639

639

639 639 539 639 639 639 639 639 639 639 639 639 639 639 639 639 639 639 639 639 639 639 639 639

639 639 639 639 639

639 639 639 639 639 639

N~vitaireTEOutPut

standby

1 RODRIGUEZ, JESS

BlE78 L

x

SA

03Jan11 OPPS

Cnt

Name (i = IW)

PNR

r ar e Class

seq 0

Date

Seat No

Unapproved Stand by status:

There are 0 unapproved standby pax on this flight ... MU=move up. Displayed:lO of 10 Pages, continue (y,n):

Page 4

ANNEX" •

. ~

I !

.~-: .

.-

--~ ..

1107j

Supplemental Affidavit-Rodolfo Edrad JR

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﻿Republic of the Philippines DEPARTMENT OF JUSTICE Manila

P ATRIA GLORIA ORTEGA, Complainan i,

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Republic of the Philippines DEPARTMENT OF JUSTICE Manila