REPUBLIC OF THE PHILIPPINES, CITY OF MANILA L a AFFIDAVIT I, PATRICIA PAZ C, BAUTISTA, of legal age, married, and with residential address at Unit 3a/b, South Tower, Pacific Plaza Towers, 4" Avenue & 25th Street, Fort Bonifacio, Taguig City, with the assistance of counsel, do hereby depose and state the following: 1, 1 am the legal wife of Juan Andres D. Bautista (‘Andy’), the current Commission on Elections (“COMELEC”) Chairman. I have four (4) children with Andy, namely, Andres Xavier C. Bautista, Jose Mateo C. Bautista, Juan Alvaro C. Bautista and Rafael Jacobo C. Bautista. | have been married with Andy for seventeen (17) years now, having celebrated our marriage on January 2000 at the Archbishop's Chapel in Intramuros, Manila. 2: lam executing this Affidavit to disclose certain information and documents that would show that Andy might have had, or currently has, lealing and corrupt practices while in government service. More specifically, the documents and information I have with me would constitute to charge Andy, among many others, for violation of the Anti- Graft and Corrupt Practices Act under Republic Act No. 3019, dishonesty in the submission and contents of his Statement of Assets, Liabilities and Network (“SALN”), betrayal of public trust as a public officer, violation of the Anti-Money Laundering Act (“AMLA") and unethical practices as a member of the bar. 3. Moreover, I understand that since Andy holds the position of COMELEC Chairman, he is liable to be impeached should there exist valid and sufficient grounds to hold him in trial for an impeachable offense under Section 2, Article XI of the 1987 Philippine Constitution. FACTUAL BACKGROUND 4. Before I begin the disclosure of the confidential information and documents I hold against Andy, I would like to make a narrative of the surrounding, circumstances and facts leading to the execution of this Affidavit. 5: Before Andy took on his public positions, he previously was in private practice as a lawyer, mostly abroad. Andy worked for theinternational law firms White & Case LLP and Allen & Overy/Anglo- Oriental Consulting. When he came back to the Philippines, he became the President of Shangri-La Properties, before he finally entered the public sector. As a public servant, Andy was appointed in 2010 as the Chairman of the Presidential Commission on Good Government (“PCGG") then as COMELEC Chairman in 2015. 6. 1 always regarded Andy as a brilliant lawyer, who has had several accolades and achievements under his belt, He has also commanded the respect and admiration of his peers in the legal circle and elsewhere. Aside from being the former PCGG Chairman, Andy is well- recognized in the legal community for his remarkable contributions in the profession. Some of his notable achievements and accolades in the legal profession include: (a) Former Dean of the Institute of Law of the Far Eastern Unive and Master of Business Administration-Juris Doctor degree from the De La Salle Graduate School of Business; (6) Former President of the Philippine Association of Law Schools; (©) Former Bar Reviewer in Constitutional Law at the National Bar Review Consortium; (a) Former Lecturer in Constitutional Law and Project Finance at the Ateneo Law School; (c) Former Trustee of the Philippine Judicial Academy; () Former Member of the Supreme Court Committee on Legal Education and Bar Matters; (g) Former Member of the Governing Board of the Mandatory Continuing Legal Education Office; (h) Former Vice-President for Academic Affairs of the Philippine Constitutional Association; and () Former Director and Corporate Secretary of the British Chamber of Commerce. 7. Within our family, Andy was the one who provided most of our family’s expenses. These include the purchase of our residential houses, the payment of our children’s tuition fees for school, the purchase of family vehicles, family trips and vacations, and other similar expenses. This is so because between the two of us, Andy was the one who always had the high paying jobs, while I mostly worked for my mom in her salons as the company President and later in her foundation as its Managing director. Although my job paid reasonably well, but it was not enough to provide for all the needs of my 4 children. 8. With Andy's hefty income from his private practice, he has made several financial investments by himself and without involving me. 1 =was not privy nor had control over said investments. Until I saw the documents I will described below, I completely had no idea whatsoever that Andy had made such purchases and investments. 9, In the recent past, or sometime in the first quarter of 2016 to be exact, friends and relatives started discreetly telling me information about Andy. These information relayed to me are generally about his alleged misdealings and questionable actions as the then PCGG Chairman and the current COMELEC Chairman. Although I had no complete grasp of what these information mean, since I do not meddle nor inquire with Andy as to what he actually does in his public positions, but from all indications of the information relayed to me, it would appear that Andy has been doing something illegal or at the very least, being dishonest in his public position(s). | 10. As more and more people started telling me about all these matters, the more I became curious and apprehensive. As a background, I have never actually suspected Andy of being corrupt or dishonest in his work, more so that he assumed his public positions. I never thought that ‘whatever properties, money or finances our family has could have been the fruit of any illegal or immoral activity, since I know that from Andy’s previous work, he was earning a hefty income, which was more than enough to provide for our family and our needs. 41. Because of all these information I had been receiving at that time, I became more and more curious and apprehensive as well as to the truth of these matters.\One day, when Andy was at work, | accidentally found the documents I mentioned below laying around in our house, (2) includi ift-wrapped sitting in a bag in our living room} T glanced” eect leew and I began noticing that these are items "and properties Andy owns, but which I was not made aware of. This led me to become more attentive and conscious of the other documents and papers that were laying around our house, and it was then that I began to discover more and more properties and money that I only became aware of for the first time. BANK ACCOUNTS A. Luzon Development Bank (“LDB”) Accounts 12. Among the several documents and papers | discovered, what struck me the most was the several passbooks from LDB in its Fort Bonifacio, Taguig City Branch, which collectively totals PhP227,701,053.00, more or less, and composing of thirty (30) separate accounts that I foundunder Andy’s name jointly with those of some of his family members. These LDB Bank Accounts are as follows: _040- 6A31,181.76 | z 040-17-00009-5 7,425,296.54 040-17-00010-3 15,931,505.09 | 040-17-00012-6 6,918,192.63 e 040-17-00016-1 pata 6,982,936.92 040-17-00017-8 9,120,942.52 __040-17-00018-4 ae 6,439,702.59 a 040-17-00020-9 11,636,802.58 040-17-00022-1 i 11,592,878.45 ~_040-17-00025-1 ~_ 6106,361.82 (040-17-00028-0 6,812,489.82 040-17-00029-6 8,581,859.35 | 040-17-00031-1 6,241,455.48 al (040-17-00033-3, 10,738,222.74 040-17-00037-9 6,316,398.56 040-17-00038-5 13,144,118.47 | 040-17-00040-0 9,172,839.99 040-17-00084-2 ~__ 8,123,352.02 040-17-00044-5 7,838,177.41 040-17-00046-8 __5,942,573.33 040-17-00047-4 = 7,648,378.12 040-17-00049-7 7,990,420.78 | (040-17-00050-5 9879,912.23 040-17-00052-8 6,354,028.51 040-17-00055-7 5,508,591.05 040-17-00051-1 400,000.00 | 040-17-00042-1 z 8,092,689.71 040-01-00058-2 37,055.17 a 040-17-00053-4 2,200,000.00 040-17-00042-2 8,092,689.71 | Total - PhP227,701,053.00 13. Based on the passbook of each of the 30 bank accounts, deposits and withdrawals were made during the year 2016 for substantial amounts. However, these amounts were not all declared in Andy's 2016 SALN. 14. Apart from these 30 bank accounts, Andy likewise maintains several bank accounts of LDB in its Makati City Branch, totaling five (5)accounts, which totals to, more or less, PhP101,519,909.00. These are the following: 028-05-00103-5 12,225,070.69 028-17-00010-3 24,451,842.42 028-17-00012-8 29,469,320.37 028-17-00005-0 21,732,835.77 028-05-00104-1 13,640,840.34 Total - PhP101,519,909.00 B. Rizal Commercial Banking Corporation (“RCBC”) Accounts 15. Andy likewise holds a Foreign Currency Account and Peso Account with RCBC, under the following details and information: 8275007227 "USDollars | __—_—‘12,778.30 1-275.93084-9 Pesos 257,931.60 Total- US$12,778.30/PhP257,931.60, 16. also found RCBC checkbooks, which also indicate substantial deposits to LDB Accounts, which I again assume are the same LDB Bank Accounts indicated above. C. Hong Kong and Shanghai Banking Corporation (“HSBC” 17. Andy likewise has an HSBC Bank Account in Hong Kong with the following details: 611-355967-888 HK Dollars Total - HK$948,358.97 148. A mathematical computation of all these amounts shows that Andy did not declare in his 2016 SALN all of these stated amount and actually left out a substantial portion thereof. For his latest 2016 SALN, Andy only declared a total of PhP176.3 Million, which amount already comprises both his personal and real properties. 19. Based on these Bank Accounts, counsel advised me of the(a) The substantial deposits and withdrawals on each of these bank accounts were made within the last two (2) years, and coincidentally, while Andy was already the COMELEC Chairman and when the 2016 National and Local Elections were conducted. (b)Most of the deposits were made below the PhP500,000.00 threshold, probably to avoid any AMLA detection. (©) The deposits and/or withdrawals were made almost every day and as if in a distinct order. 20. Upon realizing that I had become aware of these accounts and their possible sources, it is most likely that Andy had either moved these money from the aforementioned account and deposited them somewhere else and/or closed these bank accounts completely. Overall, I find these highly questionable given his stature as a high ranking government official and the sensitive nature of his work in overseeing the country’s elections REAL PROPERTIES 21. Beside Andy's bank accounts, I also discovered several properties that are under Andy's name or purchased by him; and which properties were not all declared in his SALN as well. These real properties are as follows: a. House and Lot Phase 1, Blk. 10, Lot. 81, Pili Road, Ayala Westgrove Heights, Silang, Cavite (included in the SALN); b. Units 3A/B South of Pacific Plaza Towers (included in the SALN); ©. Unit 17A, The Suite at One Bonifacio High Street plus parking slots (not included in the SALN);! d. Unit 4503, Two Maridien plus parking slots (included in the SALN);? e. Two Meridien Unit plus parking slots (included in his SALN); . St. Francis Place (included in his SALN); g. Ayala Greenfield Estates, Phase II, Block 8, Lot 1 (included in the SALN); h. Ayala Greenfield Estates, Phase III, Block 2, Lot 8 (included in the SALN); . Unit 11L, North Tower, One Shangri la Place (included in the SALN)?. Unit 12L, North Tower, One Shangri la Place (included in the SALN);#* i. 1 Twas unaware of this specific property. 2 Twas unaware of this specific " > _ Iwas initially unaware that I was made a co-owner of this property 6k. Unit 38D, North Tower, One Shangri la Place (included in the SALN) 5 1. The District in San Francisco, California, U.S.A. (not included in the SALN)$ m.Taytay, Rizal Property (included in the SALN)7 and n. Parking Slot Nos. 91 and 92, One Shangri la Place (included in the SALN)S 22. Based on my own assessment, the cumulative value of these properties at their acquisition costs is easily between PhP250,000,000.00 to PhP300,000,000.00, more or less, and definitely more than PhP158.5 Million, the total amount Andy declared for real property in his 2016 SALN. The values Andy attributed to the current market price of the properties were considerably lower than their current worth 23. Except for the Pacific Plaza units, which are our residential homes, I have no idea of the other mentioned real properties above. FOREIGN INVESTMENTS AND PROPERTIES 24. Apart from Andy’s local properties, both personal and real, I also discovered investments abroad in the form of his interests in corporations and loan agreements as follows: a. Bauman Enterprises Limited - a company established in the British Virgin Islands on 29 September 2010. This is the trustee company that Andy set-up with Bank of Singapore. This was not reflected in his SALN. b. Mantova International Limited - a company established in Brunei Darussalam on 26 April 2011 c. Mega Achieve Inc. ~ a company established in Anguilla on 15 July 2014 25. I previously confronted Andy about these companies, and he bluntly denied that he is involved in any way with any of them. However, it is highly suspicious why he would have copies of pertinent documents relative to such companies when he claims that he does not have any | was initially unaware that I was made a co-owner of this property. ‘Twas initially unaware that I was made a co-owner of this prope: was unaware of this property. Twas unaware of this ‘was initially unaware that Iwas made a co-owner of this property 7involvement with any of those. Again, these were not declared in his SALN: COMMISSION PAYSLIPS/CHECKS FROM DIVINA LAW 26. Atty. Nilo Divina (“Nilo”) is one of Andy's best friends. He has known Nilo for, more or less, 6-8 years now; and he is actually the godfather to my eldest son, Xavier. 27. I likewise discovered several checks and commission sheets from Nilo. It would, thus, appear that Andy secured the services of Divina Law, Nilo's law firm, in order to profit from his (Andy) position in the COMELEC. Based on the documents I found, Nilo issued several checks in y’s name and that of his family members, as Andy’s commission for ing the law firm’s clients with the COMELEC. What made me highly suspicious is that Nilo’s law firm has been handling, among others, government clients such as BASECO and UCPB, two (2) government entities that Andy constantly dealt with while he was the PCGG Chairman. 28, I created an impression, based on the breakdown sheets and checks I found that Andy was getting commissions from Nilo, while he was/is in active government service. Surely, a private practitioner such as Nilo would not give commission or some form of incentive to Andy if it wasn’t for any favor or service that he (Andy) had done for him (Nilo), However, it appears that Andy would get some sort of commission from Nilo for the clients that his (Nilo) law firm handled before the COMELEC as well as other private people and institutions. 29. As my lawyers advised me, the discoveries | made regarding Andy's finances, including the assets he owns or under his name, could subject him to several criminal violations (ie. Anti-Graft and Corrupt Practices Act, Anti-Money Laundering Act) and possibly for impeachment. 30. I was prompted to execute this Affidavit and expose Andy’s misdealing and seeming corrupt practices for the following reasons (@) [ fear that perhaps some properties and finances our family may have accumulated/benefitted from during his time in office may have originated from illegal or immoral acts or conducts. My family and children are all Catholics, and they (children) all attend the Ateneo. The last thing that | want my children to learn is that our family’s wealth has been sourced from corruption and illegal actions.(b)I want to make a distinction of the “clean” and “dirty” money that forms part of our conjugal property as husband and wife. After all, Andy worked in the private sector before joining the government; and his income from the private sector was substantial as well. I can say for certain that a large portion of Andy’s assets are from his previous work. It is difficult for me, however, to make such aimee since Andy controls most, if not all, of our finances; and he has been the one who controls most of the family’s major spending. All I want is to be able to make this distinction and separate what legally belongs to my family/children. ()As can be seen from some of the documents and papers I disclosed, my name appears thereon; and I likewise fear that my name and reputation might be dragged and implicated in these (ill-gotten) properties should there be any eventual and formal investigation conducted against Andy. I do not want to be regarded as complicit, in any way, to whatever corrupt, illegal or immoral actions Andy has done or is currently doing. I have not participated, even once, in any of these matters I discovered. (d)Andy knows that I have in my possession the documents and papers that I have mentioned in this Affidavit. As his reprisal, Andy has purposely cut-off any financial support that he has previously given to me and my family, in the hopes that this act would pressure me to give up the documents and information I have against him, and to keep me silent about all these. () Asa concerned citizen, I believe that someone like Andy, although extremely professionally qualified, should not be allowed to hold any government position as a consequence of the possible ramifications of what I have found. It is my fervent duty to inform all concerned parties about these information and documents so that the appropriate actions may be undertaken. (6 As of this writing, Andy continues to deprive me and my children of the financial support that we deserve. The income that I receive from my work is not enough to support all 4 of my children, and Andy has always been the one who would provide for the substantial expenses of the family. This prompted me to file a case of Violence Against Women and Children (VAWC) before the Office of the Prosecutor in Taguig City against Andy for the emotional and economic sabotage, among others, that he is performing against me and my family.(g) Lastly, Lam also executing this affidavit because I am fearful upon understanding the possibility that Andy’s affiliation with Nilo Divina as well as other activities may put me and my children in harm’s way with people/institutions I may not even be aware of. Given Andy's wide network, locally and internationally, it is likewise my fear that he may be connected with a larger group of people/ organization with unknown reach and influence. 31. For the record, I was completely shocked and surprised with the discoveries I made about Andy's substantial finances, properties and money. The time I discovered the documents and papers was actually the first time I learned of Andy’s hidden wealth. He has always been frugal in his spending, to say the least, so to find all this is absolutely shocking. I understand that Andy, being a high ranking public official should be accountable and transparent to the public about all these finances, properties and money which, obviously, he was not. 32. In support of all the statements I made herein, I have attached with this Affidavit the relevant documents and papers. 33. I am executing this Affidavit to attest to the truth of the foregoing matters and to serve whatever purpose it may have. IN WITNESS WHEREOF, I have hereunto affixed my signature this 1s day of August 2017. PATRICIAPAZ C. BAUTISTA. Affiant SUBSCRIBED AND SWORN to before me this 1* day of August 2017, I hereby certify that I have personally examined the Affiant, and that 1am fully convinced that she voluntarily executed the foregoing Affidavit and that she as read and understood the contents thereof ADMINISTERING OFFICER a7 S71