Republic of the Philippines
Province of Cavite
City of Bacoor
BARANGAY SALINAS I
OFFICE OF THE PUNONG BARANGAY
MICHAEL A. MIRANDA, MICHAEL P.
EVARISTO, PEPITO S. SANTOS,
MILANIO S. SANTOS, DONN C.
CRISOSTOMO, FERDINAND K.
BELLON, EDHEA S. CANSINO, MYLA S.
LIWANAG AND FERDINAND R.
GARDUQUE
Complainants,
-versus- Admin Case No. ________
For: Gross Misconduct and Abuse of
Authority/Conduct Prejudicial to the
Best Interest of the Service.
LYNDON G. SANTOS,
Respondent.
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COMPLAINT-AFFIDAVIT
We, MICHAEL A. MIRANDA, MICHAEL P. EVARISTO, PEPITO S. SANTOS,
MILANIO S. SANTOS, DONN C. CRISOSTOMO, FERDINAND K. BELLON, EDHEA
S. CANSINO, MYLA S. LIWANAG AND FERDINAND R. GARDUQUE, all of legal
ages, Filipinos, and residents of Salinas I, Bacoor, Cavite , sworn in accordance
with law, hereby depose and states that:
1. That we, MICHAEL A. MIRANDA, MICHAEL P. EVARISTO, PEPITO S.
SANTOS, MILANIO S. SANTOS, DONN C. CRISOSTOMO,
FERDINAND K. BELLON are duly elected barangay councilors
Barangay Salinas I, duly organized under the Local Government
Unit of Bacoor, Cavite through its Municipal Mayor to monitor the
implementation of projects and programs within the municipality;
2. That I, EDHEA S. CASINO, is the Secretary of the Barangay Salinas I
of Bacoor, Cavite duly organized under the Local Government Unit
of Bacoor, Cavite through its Municipal Mayor to monitor the
implementation of projects and programs within the municipality;
3. That I, MYLA S. LIWANAG, is the treasurer of the Barangay Salinas
I, Bacoor, Cavite duly organized under the Local Government Unit
of Bacoor, Cavite through its Municipal Mayor to monitor the
implementation of projects and programs within the municipality;
4. That I, FERDINAND R. GARDUQUE, is the elected Barangay
Chairman of Barangay Salinas I, Bacoor Cavite duly organized
under the Local Government Unit of Bacoor, Cavite through its
Municipal Mayor to monitor the implementation of projects and
programs within the municipality;
5. That we would like to file an administrative complaint against
LYNDON G. SANTOS, of legal age, Filipino, resident and Barangay
Councilor of Barangay Salinas I City of Bacoor, Province of Cavite
for Gross Misconduct, Conduct Prejudicial to the Best Interest of
the Service and Abuse of Authority arising from grave threat ;
6. That on January 7, February 11, March 10, April 10, April 20, May 20,
June 10, July 10 and August 10 all in the year of 2019, Respondent
Lyndon G. Santos, willfully did not attend the regular sessions
which is part of his responsibilities as an elected Barangay
councilor. The respondent did not even bother to explain to the
Barangay Office why he was not present on the said dates of the
regular session, Official Attendances of the regular session are
hereto attached as Annex “A” to “N” respectively;
7. That on December 2018 Respondent reneged on his written
promise to pay his valid and legally contracted loan to Mrs. Susan
Catapia by making unauthorized entry to the Barangay Payroll that
his salary was illegally withheld thru the alleged conspiracy of Brgy.
Chairman Garduque and Treasurer Myla Liwanag;
8. Not satisfied with his oppressive conduct, Respondent filed a case
of theft against Mrs. Catapia and technical malversation against us
(Chairman Garduque) and Treasurer Myla Liwanag) before the
office of the Ombudsman for Luzon. The cases just mentioned was
malicious and without basis in fact and in law.
9. Due to inherent propensity of the Respondent to stir controversy,
he then again filed a case of libel against us (Mrs. Susan Catapia,
Chairman Garduque and Treasurer Liwanag). To stir the
controversy even further, respondent handed to each and every
one of us a copy of the complaint for libel, technical malversation,
theft and violation of the Labor Code despite being fully aware
that all this cases were unfounded and designed merely to vex,
humiliate and threatened the council;
10. By reason of unfounded, baseless and malicious suit hurled by the
Respondent against us (Mrs. Catapia, Chairman Garduque and
Treasurer Liwanag, we have filed a case of perjury before the
Office of City Prosecutor, Bacoor City, Cavite to seek justice and to
serve as an example to public.
Affiant further sayeth naught.
In witness whereof, we have hereunto set our hands this __ day of
________ 2019 at Bacoor City, Cavite.
MICHAEL A. MIRANDA MICHAEL P. EVARISTO PEPITO S. SANTOS ID
_____________ ID _____________ ID _____________
MILANIO S. SANTOS DONN C. CRISOSTOMO FERDINAND K. BELLON
ID _____________ ID _____________ ID _____________
EDHEA S. CANSINO MYLA S. LIWANAG FERDINAND R.
GARDUQUE
ID _____________ ID _____________ ID _____________
Complainants
VERIFICATION/CERTIFICATION
We, MICHAEL A. MIRANDA, MICHAEL P. EVARISTO, PEPITO S. SANTOS,
MILANIO S. SANTOS, DONN C. CRISOSTOMO, FERDINAND K. BELLON, EDHEA
S. CANSINO, MYLA S. LIWANAG AND FERDINAND R. GARDUQUE, after having
been duly sworn to in accordance with law, do hereby state that we are the
Complainants in the above entitled case and in our capacity as such, have
caused the preparation of the foregoing Complaint, the contents of which are
all true and correct based on our own knowledge and authentic records.
We further certify that we have not commenced any action or filed any
claim involving the same issues in any court, tribunal or quasi-judicial agency
and to the best of my knowledge, no such other action or claim is pending
therein; nor is there any other pending action or claim involving the same
issues in any court, tribunal or quasi-judicial agency; and if we should hereafter
learn that the same or similar action or claim has been filed or is pending, we
shall report that fact within five (5) days there from to this Honorable Court.
MICHAEL A. MIRANDA MICHAEL P. EVARISTO PEPITO S. SANTOS ID
_____________ ID _____________ ID _____________
MILANIO S. SANTOS DONN C. CRISOSTOMO FERDINAND K. BELLON
ID _____________ ID _____________ ID _____________
EDHEA S. CANSINO MYLA S. LIWANAG FERDINAND R.
GARDUQUE
ID _____________ ID _____________ ID _____________
SUBSCRIBED AND SWORN TO before me this ___ day of _____ 2019 at
Bacoor City, Cavite affiant’s identity has been ascertained by me through their
respective ID’s indicated beneath their signatures;
