Ombudsman Complaint

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REPUBLIC OF THE PHILIPPINES)

City of Naga) S.S.

COMPLAINT

I, Mariss K. Sumbong, of legal age, a Filipino, and a resident


of #5 Ojedo Street, Dayangdang, Naga City, most respectfully
avers:

That I am employed at the Public Health Center of


Dayangdang, Naga City as a Doctor;

That on May 18, 2018, Barangay Captain Hermes P. Alis


received money amounting to Php250,000.00 from the
Department of Health for the purpose of purchasing medical
supplies and equipment for the Public Health Center of
Dayangdang;

That Barangay Captain Alis prepared a proof of purchase


indicating therein that medical supplies and equipment were
bought on April 14, 2018 for the Public Health Center of
Dayangdang;

That said barangay official Alis withdrew and disbursed the


public funds of Php250,000.00 supposedly for the purchase of
medical supplies and equipment;

That no medical supplies and equipment were purchased


and delivered for the Public Health Center of Dayangdang; and

That I am charging Barangay Captain Hermes P. Alis for the


commission of the crimes of Malversation of Public Funds and the
Anti-Graft and Corrupt Practices Act (RA No. 3019).

Mariss K. Sumbong

SUBSCRIBED AND SWORN to before me this 18th day of


May, 2019, in the City of Naga, Camarines Sur, Philippines.
JURIS PABLO G. FORMARAN V
City Prosecutor
MCLE V-0001519 11/24/14

CERTIFICATE OF NON-FORUM SHOPPING AND


VERIFICATION
I, Mariss K. Sumbong, of legal age, a Filipino, and a resident of
#5 Ojedo Street, Dayangdang, Naga City, after having been duly
sworn in accordance with law, depose and state that:

1. I am the complainant in the above-stated case;

2. I caused the preparation of the foregoing complaint;

3. I have read the contents thereof and the facts stated therein
are true and correct of my personal knowledge and/or on the
basis of copies of documents and records in my possession;

4. I have not commenced any other action or proceeding


involving the same issues in the Supreme Court, the Court of
Appeals, or any other tribunal or agency;

5. To the best of my knowledge and belief, no such action or


proceeding is pending in the Supreme Court, the Court of
Appeals, or any other tribunal or agency;

6. If I should thereafter learn that a similar action or proceeding


has been filed or is pending before the Supreme Court, the
Court of Appeals, or any other tribunal or agency, I undertake
to report that fact within five (5) days therefrom to this
Honorable Court.

IN WITNESS WHEREOF, I have hereunto affixed my


signature this May 18 2019 in Naga City

Mariss K. Sumbong
Affiant

SUBSCRIBED AND SWORN to before me this 18th day of


May, 2019, in the City of Naga, Camarines Sur, Philippines affiant
exhibiting to me his Passport ID No. 829, issued in Legazpi City on
January 12, 2018.
ATTY. MARIA JELA M. MORAN
Notary Public
Until December 31, 2020
IBP O.R. No. 900003; Jun. 16, 2019; IBP National Office
PTR No. 900000; Jul. 1, 2018; Iriga City
Attorney’s Roll No. 9090000; Page 323; Book XXXI; Jun. 19, 2018
MCLE Compliance Certificate No. 0808087

Doc. No. 514


Page No. 16
Book No. 5
Series of 2019

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