REPUBLIC OF THE PHILIPPINES

HOUSE OF REPRESENTATIVES
COMMITTEE ON JUSTICE
House of Representatives Complex
Constitution Hills, Quezon City

IN THE MATTER OF THE

IMPEACHMENT OF MARIA
LOURDES P. A. SERENO AS
CHIEF JUSTICE OF THE
SUPREME COURT OF THE
PHILIPPINES,

ATTY. LORENZO G. GADON,

Complainant,
x------------------------------------------------x

More Lies, More Lies and More Lies of Maria Lourdes

(as Verified Reply to her Verified Answer)

Undersigned Complainant, by himself, unto this Honorable Committee on

Justice of the House of Representatives, most respectfully states:

1. The 84-page Verified Answer of Respondent Sereno is nothing but a

litany of lamentable lies and lame logic crafted to escape her
impeachment and eventual removal from office. It is overflowing with
legal jargon, semantics and technicalities to justify highly questionable
acts that actually justify her impeachment and immediate removal from
office.

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2. Pages 1 4 school us on the nature of impeachment cases; pp. 5 10
enumerate the achievements of a collegiate court for which she solely
takes credit; pp. 11 19 are just general admissions and denials; while
pp. 20 onwards discuss her affirmative allegations and defenses, let us
discuss them.

3. Disrobed of legal niceties, let us go to the bare facts and simple

arguments.

4. Respondent Serenos mental and psychological evaluation results.

Respondent Serenos mental and psychological evaluation results are
NOT covered by the doctor-patient privilege nor her right to privacy.

4.1. First, she was never a patient (unless she is now admitting to be a
mental patient) of the psychologists / psychiatrists who conducted
the tests and evaluated her. She voluntarily submitted herself to
them on this single instance because she wanted to become chief
justice, plain and simple. A physician-patient relationship is only
created when a patient engages the services of a physician and the
latter accepts or agrees to provide care to the patient. 1 The
doctors in this case never provided care to Respondent Sereno.

4.2. Second, any claim to her privacy must fail when confronted with
the public interest doctrine. The right of privacy is not an
absolute right, and a limited intrusion into a persons privacy has
long been regarded as permissible where that person is a public
figure and the information sought to be elicited from her or to be
published about her constitute matters of a public character. 2
Simply put, the public must be informed of the state of mental
health of the Chief Justice.

1
Casumpang v. Cortejo, G.R. No. 171127, 11 March 2015.
2
Ayer Productions v. Capulong, G.R. No. 82380, 29 April 1988.

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 4.3. Respondent Sereno is not consenting to the release of her mental /
psychological evaluation results simply because they will clearly
show her mental unfitness to be and remain as chief justice.

4.4. True, a failing mark of 4 as argued by Respondent Sereno is

not an offense, let alone an impeachable one. For, it is an
indication of a serious illness that needs immediate medical
attention and help.

4.5. Respondent Sereno denies firing the two (2) psychiatrists who
gave her a failing mark, but admits that the Judicial Bar and
Council (JBC) no longer renewed their contracts after she later
became its ex officio Chairperson. Same banana.

4.6. Complainant never alleged her mental condition as a ground for

impeachment, because it is not. Rather, it is the underlying reason
for her continuous commission of impeachable offenses.

5. Falsifying Supreme Court resolutions. Under the Revised Penal

Code, a public officer is guilty of falsification when he or she takes
advantage of his or her position to commit certain acts, including
causing it to appear that persons have participated in any act or
proceeding when they did not in fact so participate, and attributing to
persons who have participated in an act or proceeding statements other
than those in fact made by them.3

5.1. Respondent Sereno falsified no less than three (3) Supreme Court
resolutions by making it appear that the contents of these
resolutions were agreed upon by, and reflect the final consensus
of the Court En Banc, when in fact, they do not. That the
resolutions are supposedly based on Respondent Serenos notes
does not necessarily mean that her notes reflect the actual
3
Art. 171, Revised Penal Code of the Philippines

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 consensus reached by the Court En Banc because what she writes
down as her notes are her views, and not the prevailing views as
voted upon by the majority of the members of the Court.

6. Falsification of SC Resolution in A.M. No. 12-11-9-SC. Respondent

Sereno blames the Clerk of Court for preparing the erroneous 27
November 2012 Resolution. Poor Clerk of Court who supposedly solely
relied on Respondent Serenos notes to come up with the Minutes of the
En Banc session and the resulting 27 November 2012 Resolution. But
isnt Respondent Sereno, as Chief Justice, suppose to review all
resolutions, especially those allegedly prepared by the Clerk of Court,
before they are officially released? Clearly, the subsequent 22 January
2013 En Banc Resolution revoked the 27 November 2012 Resolution as
the latter resolution was in direct contravention to the earlier one.

6.1. Respondent Sereno continues to argue that the 22 January 2013

Resolution was arrived at after further discussions subsequent to
the 27 November 2012 Resolution. This is a big fat lie. Simply
put, there would not have been any further discussions if she
did not make it appear that the earlier Resolution was an En Banc
Resolution.

7. Falsification of the TRO in G.R. Nos. 206844-45. Respondent Sereno

again falsified a resolution of the Court, this time a TRO, by making it
appear that the TRO she issued in G.R. Nos. 206844-45 was upon the
written recommendation of the Member-in-Charge. Another lie!
Respondent Sereno in fact deliberately tampered with and altered the
contents of the draft TRO sent by the Member-in-Charge. Hence, after
she released the falsified TRO dated 29 May 2013, to rectify the
erroneous TRO, the Court had to issue a status quo ante order on 5 June
2013 which expressly stated that [p]revious orders, resolution or

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 issuances of the Court in these consolidated cases are superseded only
insofar as they may be inconsistent with this present resolution.

7.1. She argues that she did not falsify the TRO because the Supreme
Court Internal Rules expressly empowers her to act on urgent
cases requiring immediate action when the Court is in recess, even
without the recommendation of the Member-in-Charge. This is so
if the Member-in-Charge is absent and cannot be reached.

8. Falsification of SC Resolution in A.M. No. 16-08-04-SC. Respondent

Sereno, for the third time, committed falsification when on 9 August
2016, she authorized the release of a supposed En Banc Resolution in
A.M. No. 16-08-04-SC which resolved to DIRECT Executive
Secretary Salvador C. Medialdea to submit Complaint-Affidavits against
the four (4) judges within seven (7) days, which the Public Information
Office (PIO) in fact released to the media that same afternoon.

8.1. The 9 August 2016 Resolution released by the PIO that same
afternoon categorically directed the Executive Secretary to submit
Complaint-Affidavits against the four (4) judges. It did not
merely invited the law enforcement authorities to submit
complaints or other information against the four judges, as she
argues. This is clear as daylight.

8.2. Respondent Sereno argues that what the PIO released was a draft
resolution, which had already been voted on and approved in
principle. Another total lie! Because what the Court En Banc
voted on and approved was the tenor of the 16 August 2016
Resolution which resolved to invite law enforcement officials,
and not direct the Executive Secretary, to submit complaints-
affidavits.

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 8.3. The release of the 9 August 2016 Resolution by the PIO, upon
instruction of Respondent Sereno but without authority of the
Court En Banc, clearly constitutes falsification of a Supreme
Court resolution because it was made to appear that said
resolution was decided and agreed upon by the Court En Banc,
when in fact it was not. The subsequent 16 August 2016
Resolution, which is the final and signed resolution, is totally
different from the 9 August 2016 Resolution.

9. Inordinate delay on numerous petitions for retirement benefits of

justices and judges, or their surviving spouses. Respondent Sereno
claims that she did not delay action on the resolution of these
applications since she herself has no power to act unilaterally on these
petitions. Moreover, applications with issues must pass through the
Special Committee on Retirement and Civil Service Benefits or a
Technical Working Group (TWG) for further study before endorsing to
the Office of the Chief Justice and/or En Banc for approval. A blatant
lie! It is simply undeniable that as Chief Justice, Respondent Sereno
could have easily expedited the resolution of these urgent applications, if
only she were in her right senses. After all, the Court, in 271 earlier
cases, has consistently resolved these applications.

9.1. Respondent Sereno claims that the creation of the Special

Committee and TWG, as part of her supposed administrative
reforms, was a result of the many inconsistent decisions of the
Supreme Court in granting or denying these petitions, with the
Supreme Court being strict in some cases but lenient in other
depending on the recommendation of the Members-in-Charge.
Is Respondent Sereno saying that the Supreme Court justices have
been wrong in their earlier decisions to award or deny petitions
for retirement benefits, that she went to the extent of creating
committees and TWGs composed of her newbie lawyers to study
the matter?

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 9.2. Respondent Sereno further claims that this new system in place
resulted in significant improvement in the speed, efficiency, and
consistency in the processing of petitions for retirement benefits.
This is complete bogus! Many of these applications, filed by
septuagenarians, octogenarians and nonagenarians, have sat
unattended for a year or two or more, celebrating their birthdays
on the table of her newbie lawyer, the de facto head of her TWG,
while previous applications have been resolved promptly. These
applications only moved recently, after the issue was included as
an article of impeachment against Respondent Sereno.

9.3. This inordinate delay simply shows her incompetence and

insensitivity to the plight of these septuagenarians, octogenarians
and nonagenarians who are not in the pink of health and do not
wish to spend their benefits on extravagance, but for urgent living
and medical expenses.

10. Manipulating and delaying the resolution of A.M. No. 17-06-02-SC.

Respondent Sereno claims that she did not manipulate or delay the
resolution on the transfer of Maute Cases to Taguig and reasons that she
had to coordinate the matter not only with the Supreme Court En Banc,
but also with the Secretary of Justice, the Armed Forces of the
Philippines, and the PNP in view of security concerns. Another
blatant lie!

10.1. Sure it took only all of eight (8) days, from 29 May 2017 to 6
June 2017, for the Court to act on the initial request of the Justice
Secretary to transfer the Maute cases out of Mindanao, but only
because the request was DENIED! It was actually so fast that the
Resolution of the Court was out in the afternoon of the morning
the justices deliberated. But then again, the request was denied,
and the Maute cases were transferred, not out of Mindanao as

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 requested, but only to two (2) cities away, within Mindanao, from
Marawi to Cagayan de Oro, barely two (2) hours away by land
travel.

10.2. The Motion for Reconsideration to transfer the Maute cases to

Taguig which was filed on 13 June 2017 however did not enjoy
the same prompt action. It was belatedly calendared on 27 June
2017 (not the following Tuesday, 20 June 2017), despite the
urgency of the matter, and the Resolution was even more
belatedly released on 18 July 2017, or 21 days after the Court
decided. Why? Because the Court unanimously decided to
GRANT the Motion for Reconsideration so unlike the original
request the denial of which was released on the same day of the
deliberations.

10.3. That she did not call Justice Tijam to inform him that the matter
had been assigned to him (a brazen lie) is evidentiary in nature
shall may be verified later.

11. Failure to truthfully disclose her Statement of Assets, Liabilities,

and Net Worth, or SALN. Respondent Sereno claims that she fully
disclosed her assets, liabilities and net worth in her SALN when she
joined the Judiciary. She argues that the lawyers fees she received in
connection with her engagement as legal counsel in the PIATCO Cases,
which she received between 2004 to 2009, did not remain intact until
2010. Another brazen lie!

11.1. In fine, her unsubstantiated allegations remain just that

unsubstantiated. This will seriously be refuted during the
evidentiary hearing.

11.2. She likewise argues that assuming that she indeed failed to
truthfully disclose her SALN, this was done before she joined the

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 Judiciary in 2010 and hence, is not an impeachable offense. It
may not yet be an impeachable offense, but it already displays a
despicable mind.

12. Manipulation of the JBC shortlist to exclude then Solicitor General

Francis H. Jardeleza. Respondent Sereno claims that she acted in good
faith and in accordance with the JBC rules when she voted to exclude
then Solicitor General Jardeleza from the shortlist since she had genuine
concerns about his integrity. She argues that Justice Jardeleza was
excluded, not because of her supposed manipulations, but because he did
not obtain the unanimous vote required under the rules.

12.1. Simply, however, Respondent Sereno, as ex-officio Chair of the

JBC, was overturned by the Supreme Court En Banc, as it
refuse(d) to turn a blind eye on the palpable defects in its
implementation and the ensuing treatment that Jardeleza received
before the Council,4 and cited the violation by the JBC of its
own rules of procedure and the basic tenets of due process.

12.2. Respondent Sereno also points out that she did not impair the
Presidents power to appoint members of the Judiciary, since
Justice Jardeleza was eventually included in the shortlist and
appointed by then President Benigno C. Aquino III. Yes, but only
after the JBC, which Respondent Sereno manipulated, was
reversed by the Court En Banc.

13. Manipulation of the JBC shortlist for the six vacancies in the
Sandiganbayan. Respondent Sereno denies manipulating the JBC
shortlist and argues that the practice of clustering nominees, which the
JBC, acting as a collegial body, introduced, is not expressly prohibited
under the Constitution.
4
Jardeleza v. Sereno, G.R. No. 213181, August 19, 2014, 31.

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 13.1. Respondent Sereno argues that President Aquinos appointing
power did not suffer any prejudice because he actually
disregarded the so-called clustering of nominees. Precisely so -
he disregarded such clustering. Otherwise, the Presidents
appointing power would have been impaired.

13.2. Respondent Sereno interjects that she did not file any petition to
assail the manner by which President Aquino had chosen his
appointees nor did she formally take issue with the Presidents
apparent disregard of the so-called clustering. Good for her.
At any rate, she was not the aggrieved party to begin with.

14. Manipulation of the JBC shortlist for the two vacancies in the
Supreme Court. Respondent Sereno claims that there was no
clustering for these vacancies, which did not occur simultaneously but
at least 35 days apart.

14.1. In Aguinaldo v. Aquino, [t]he Court note(d) that the clustering of

nominees is a totally new practice of the JBC. Previously, the
JBC submitted only one shortlist for two or more vacancies in a
collegiate court. The Court then reproduced the examples cited
by the OSG where only one (1) shortlist each was submitted for
two (2) or three (3) vacancies. Some of these vacancies were
more than 35 days apart.

14.2. And yet for the vacancy created by the retirement of SC Justice
Jose Mendoza on 13 August 2017, she caused the JBC to vote on
the shortlist for his successor on 7 July 2017, a good 36 days
before the retirement of Justice Mendoza. Why? Because a JBC
Member who is allied to her will be retiring on 9 July 2017. The

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 new JBC member may not vote with her anymore. Isnt this
manipulation?

15. Respondent Sereno made it appear that several justices requested

that they do away with voting for the
recommendees to vacancies in the Supreme Court. Respondent
Sereno downplays the Separate Concurring Opinion of Justice Brion
who revealed that when confronted, the Chief Justice failed to name
anyone, as merely one of former Associate Justice Brions separate
opinion.

15.1. But isnt a separate concurring opinion a prima facie evidence to

establish the facts it recites? If not, where else do we rely for the
facts of a case?

15.2. At any rate, Respondent Sereno commits to name the several

justices at the appropriate time. We fondly await this.

16. Manipulation of the JBC, especially its four (4) regular members, by
Respondent Sereno. Respondent Sereno denies ever manipulating any
member of the JBC. A patent lie! At the outset, Complainant referred
only to the four (4) regular members she was influencing, excluding the
ex-officio members, namely the Secretary of Justice and the member of
Congress.

16.1. Isnt by calling the four (4) regular JBC members individually to
her chambers to personally convince, persuade and beg them to
either vote or reject a particular applicant a form manipulation?

16.2. In fine, the JBC has rejected a highly-qualified first-level court

judge, and a senior official with excellent academic credentials

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 and who has been with the SC for 30 years, but shortlisted
Respondent Serenos lightweight chief of staff who was in fact
just known as her umbrella boy and her other neophyte lawyers
in numerous branches of the RTC in the NCJR.

16.3. That Respondent Sereno is not aware of the shortlisting of the

son-in-law of a JBC member who is her ally, in numerous
branches of the RTC in the NCJR, despite the applicants being
short of years as a judge in the province, is a barefaced lie. Well,
perhaps she does not care because it does not concern her.

17. Acquisition of Toyota Land Cruiser 2017 model using public funds.
Respondent Sereno claims that the acquisition was neither an
extravagant purchase nor an illegal use of public funds because it was
approved by the Court En Banc in its 28 March 2017 Resolution in A.M.
No. 17-03-06-SC.

17.1. The top-of-the-line 2017 Toyota Land Cruiser which costs the
general public P5.1 Million is not extravagant??? Is she too high
a public official to ride a Toyota Hi-Ace which costs less than
half, and which has been the customary vehicle for justices of the
Supreme Court, including chief justices? In the entire 116-year
history of the Supreme Court, it is only now that a chief justice
has ordered the purchase of such a luxurious vehicle. Isnt she
ashamed of herself?

17.2. Poor trial court judges who are assigned to two (2) or more courts
as they must travel between their courts using ordinary public
conveyance or customary modes of transportation (which) shall
be the most advantageous to the government from the standpoint

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 of economy and efficiency 5 in order to be reimbursed for their
transportation expenses. And these judges sometimes have to
cross the seas or traverse mountains, unmindful of the perils and
dangers that face them.

17.3. Respondent Sereno wants the judges, court personnel and the
general public to pity her. For years, she laments, she did not
ask for a new or luxury motor vehicle Instead, she
improvised. She hung a personally-purchased bullet-proof
blanket on one side of the interior of the Hyundai Starex van that
was handed down to her. She also covers her back seat with a
bullet-proof vest which her husband had given her as a gift. This
continues to be her vehicle security upgrade at personal cost until
today. This can hardly be characterized as an extravagant
lifestyle.

17.4. What she does not tell us is that she travels the streets of Metro
Manila escorted by a coterie of security personnel in two (2) to
three (3) motorcycles to clear her path, while the rest are packed
in two (2) Toyota Innovas as her security back-up, all at the
expense of public funds. One begins to wonder, has she wronged
so many for her to be so paranoid and move around with a platoon
of security personnel? As one senior justice of the Supreme Court
quipped, Dont we decide the same cases?

17.5. But there is also an irregularity in the procurement of this brand

new Toyota Land Cruiser as the justices of the Supreme Court
were surreptitiously deceived in approving its purchase.
Respondent Sereno purposely did not commence the procurement
process with a Request for Approval of Purchase from the En
Banc, as what is customarily done. The 28 March 2017
Resolution, the only Resolution approved by the En Banc on the
5
Administrative Circular No. 15-2005.

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 matter, already referred to the Request for Approval of the Award
of the Contract for the Supply and Delivery of the Toyota Land
Cruiser to Toyota Makati, Inc.

17.6. All told, despite being allowed by some existing rules to purchase
and use a luxury vehicle, what is at issue here is the propriety of
purchasing a luxury vehicle with public funds. Nothing more.

18. Use of public funds to finance her extravagant and lavish lifestyle.
Respondent Sereno claims that she did not get herself billeted in a
Presidential Villa of Shangri-la Boracay and points to the En Banc
Resolution approving the P2.6 Million budget for the 3rd Meeting of
ASEAN Chief Justices and the ASEAN Law Association General
Assembly to be held in Boracay on March 2-4, 2015, which
specifically included the use of the Presidential Villa as the meeting
area for 24 hours.

18.1. Nowhere however in the said Resolution was the Presidential

Villa of Shangri-la Boracay mentioned. In fact, in her recent Ulat
ng Hudikatura Town Hall held in Cebu City on 24 August 2017,
Respondent Sereno answered reporter Joseph Morongs question
with a straight face: I wanted to, first of all, assure you already
that I have never done anything irregular and everything has been
above board. We needed a room for a major photo taking session
of the chief justices of the ASEAN. This was in Boracay. And
they said, instead of just renting it, we are willing to rent it, it
became part of the package. In other words, it was offered to us,
free. FREE.

18.2. Respondent Sereno, in her Verified Answer, however alleges that

the Resort offered the Presidential Villa as part of a Room Block
for the event, with the Resort charging P134,192.25 for (its) use

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 (and not the regular rate of P280,000.00) as part of the Room
Block. So which is which: free, P134,192.25, P280,000.00, or
P2,600,000.00? Take your pick.

18.3. Incidentally, the uploaded video in YouTube.com of the Ulat ng

Hudikatura Town Hall held in Cebu City on 24 August 2017 has
been surprisingly taken down by the SC PIO.

18.4. Respondent Sereno claims that the signing of the Boracay

Accord, photo-op of the ASEAN Chief Justices, and side
meetings between Chief Justices in the ASEAN prior to the gala
dinner, all took place in the Presidential Villa. We have yet to
see the pictures of the chief justices taken inside the Presidential
Villa.

18.5. In the end, Respondent Sereno admitted: Thus, by using (and

sleeping at) the Presidential Villa at no additional cost, the Chief
Justice actually saved public funds. An expensive lie. And the
nerve to say that she saved public funds.

18.6. Indeed, Respondent Serenos conflicting stories are consequences

of her desperate attempt to cover up her newly-acquired
extravagance and taste for the finer things in life, at the sorry
expense of the Filipino people.

18.7. Respondent Sereno denies insisting on flying business class,

together with her security and staff, whether on domestic or
international flights. She points to the Human Resource Manual
of the Supreme Court, which expressly allows the chief justice to
travel on full business class, while the other members of the
Court are not allowed to do so, to justify her business class
travels. However, she did not provide any affirmative allegation

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 or defense for the business class travels of her security and staff
asserted by the Complainant. Why the selective silence?

18.8. What is at issue with Respondent Serenos insistence on taking

business class, even for one-hour local flights, is not its legality
but its propriety.

18.9. With respect to the charge she brings a huge entourage of lawyers
to her supposed official foreign trips, Respondent Sereno asserts
that there is no rule which prohibits the Chief Justice from
bringing her staff on foreign trips. That said, (she) never brought
with her a huge entourage of lawyers but only such number of
lawyers as were necessary to assist her given the nature and
objective of the official trip. Same banana!

19. Obstruction of justice by ordering the Muntinlupa judges not to

issue warrants of arrest against Senator Leila M. De Lima.
Respondent Sereno claims that she never spoke to any of these judges
on this matter, nor did she instruct any Supreme Court official to instruct
the judges not to issue a warrant of arrest. This claim is evidentiary in
nature and will be verified later. That Senator De Lima was arrested and
is presently detained is beside the point.

20. Obstruction and perversion of justice by meeting the Presiding

Justice and Associate Justices of the Court of Appeals (CA) and
instructing them not to comply with the processes of the House of
Representatives and to immediately question the same before the
Supreme Court. Respondent Sereno denies giving such instructions, as
well as meeting with the CA Justices on this matter. She claims that
then Presiding Justice of the CA, now Supreme Court Associate Justice
Andres B. Reyes, Jr., conferred with her on the matter and she
essentially advised him that the CA judges should consider their own
legal remedies. Another shameless lie!

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 20.1. That Respodent Sereno did not meet with the CA justices on this
matter nor did she instruct them not to comply with the process of
the House of Representative and question the same before the
Supreme Court is evidentiary in nature and will be verified later.

21. Failure to report her extortionate attorneys fees and pay the
appropriate taxes therefor. Respondent Sereno claims that she paid all
applicable taxes on her legal fees, without however, offering any
evidence to support her claim, which should be readily available to her.
By alleging payment of taxes, the burden of proof has shifted to her. It
is thus surprising that while she has appended three (3) inches thick of
documents as her annexes, she has failed to attach simple copies of her
ITRs and receipts to prove her allegation that she paid more than Eight
Million Pesos in taxes.

22. Embellishment of her Personal Data Sheet (PDS) in applying for the
Judiciary to overstate her credentials. Respondent Sereno denies
embellishing her PDS to overstate her credentials. She insists that she
possessed the functional title of Deputy Member of the Presidential
Committee on Human Rights, and later on, Deputy Commissioner of the
Commission on Human Rights (CHR). She claims that in her PDS in
support of her application for the position of Chief Justice (the 2012
PDS), she specifically stated TECHNICAL CONSULTANT/DEPUTY
COMMISSIONER (FUNCTIONAL TITLE).

22.1. Responden Sereno did not offer any evidence proving that she
indeed held that title or position in the CHR. Moreover, her 2012
PDS indicates DEPUTY COMMISSIONER as her position in
the CHR, and NOT TECHNICAL CONSULTANT/DEPUTY
COMMISSIONER (FUNCTIONAL TITLE) as she claims.

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 22.2. Respondent Sereno likewise insists that her PDS was truthful
when she stated she was a lecturer at the Hague Academy of
International. She never claimed she actually lectured in the
Netherlands and indeed was a lecturer for the Cambodia
Extension Program of the Hague Academy of International Law.

22.3. There is a HUGE difference between a university and its

extension programs. Schools like Harvard University even have
guidelines for listing degrees obtained through their extension
schools for resume purposes, requiring the alumnus to indicate
either Harvard University Extension School or Extension
Studies, Harvard University. 6 Respondent Sereno purposely
failed to include Cambodia Extension Program in her PDS to
make people think that she was a lecturer at the university, the
Hague Academy of International Law, rather than in its extension
program.

22.4. The same goes for her stating that she was a lecturer in both the
University of Western Australia and Murdoch University, which
again, is very misleading and inaccurate. Based on the
Certification made by Antonio P. Esteban, Executive Director,
Australian International School (formerly Esteban School),
Respondent Sereno was a Philippine-sourced faculty for the
transnational Master of Business Administration program in the
Philippines of the Esteban School, a locally-based school, in
partnership first with Murdoch University and then with the
University of Western Australia. She is actually a lecturer in
the Esteban School, and NOT in Murdoch University and
University of Western Australia.

6
Graduation and Honors, Harvard Extension School, available at
https://www.extension.harvard.edu/resources-policies/completing-your-degree/graduation-
honors (last accessed 27 September 2017).

Page 18 of 29
 22.5. Respondent Serenos deliberate omission of these details show
her clear intent to overstate her credentials in order to mislead the
JBC and the appointing authority. Lies, lies, lies

22.6. That these so-called errors cannot be used to impeach her

because they happened before she became Chief Justice is not a
valid defense, considering that Court personnel have been
dismissed for misrepresenting their PDS, which amounts to
falsification of a public document.

23. Hiring of an Information and Communications Technology (ICT)

consultant with an excessive compensation without public bidding,
in contravention of existing laws, Commission on Audit (COA)
rules, and public policy. Respondent Sereno claims that the hiring of
the ICT Consultant, Ms. Helen Perez-Macasaet, was done in accordance
with the Government Procurement Reform Law, and her compensation
was not excessive.

23.1. Respondent Sereno claims that is was the Supreme Court, and not
her, who hired Ms. Macasaet (from among three choices)
through negotiated procurement, because her services are highly
technical in nature and, therefore, exempted from the public
bidding under Sec. 53.7 of the then prevailing 2009 Revised
Implementing Rules and Regulations of R.A. No. 9184.

23.2. Respondent Serenos allegation that it was the Supreme Court,

and not her, who hired Ms. Macasaet as ICT Consultant is
unsubstantiated. In fact, the Court En Banc is unaware of this.
The Supreme Court Bids and Awards Committee (BAC) on
Consulting Services is under the direct control and supervision of
the Chief Justice. Hardly is the Court En Banc informed of the
actions of the BAC unless memoranda are submitted to the former
for approval. In this case, nothing was submitted.

Page 19 of 29
 23.3. This actually does not end with Ms. Macasaet. Respondent
Sereno has hired quite a number of consultants:

23.3.1. Retired Ambassador Jose A. Zaide was engaged as a

Protocol Officer to advise the Office of the Chief Justice on
etiquette and courtesies expected during official visits,
courtesy calls and official functions such as but not limited to
providing guidance on customs regarding bowing, shaking
hands, interacting with the opposite sex, and generating
welcome and thank you letters, among others, at the rate of
Six Hundred Thousand Pesos (P600,000.00), for a period of
six (6) months, or One Hundred Thousand Pesos
(P100,000.00) per month, beginning February 1, 2013 until
September 30, 2013.7

23.3.2. Not satisfied with the expensive services of her previous

protocol consultant, Respondent Sereno engaged Verna D.
Albano as a Consultant of the Chief Justice to provide
technical, strategic, and efficient advise and policies to the
Court on protocol matters, at a monthly rate of Thirty
Thousand Pesos (P30,000), beginning October 1, 2015 until
present.8

23.3.3. Mr. Alexander Arevalo was engaged as Consultant in

the Office of the Chief Justice to provide recommendations
and advice on the implementation of the Supreme Court of the
Philippines information communication technology and
computerization projects at a monthly fee of Thirty
Thousand Pesos (P30,000.00), beginning September 16, 2013

7
Contract of Services of Jose A. Zaide dated February 1, 2013.
8
Contracts of Services of Verna D. Albano dated September 17, 2015, June 1, 2016,
December 7, 2016, and June 1, 2017.

Page 20 of 29
 to March 15, 2014. 9 Note that Ms. Macasaet was first
engaged as ICT Consultant within that same period,
beginning October 1, 2013, to do essentially the same task,
but this time at the rate of Six Hundred Thousand Pesos
(P600,000.00) for a six-month period, or One Hundred
Thousand Pesos (P100,00.00) a month, which was
subsequently raised to One Million and Five Hundred
Thousand Pesos (P1,500,000.00) for a six-month period, in
her subsequent contracts.

23.3.4. Atty. Carlos N. Garay was engaged as the Information

Communications Technology (ICT) Consultant in the Office
of the Chief Justice at a monthly fee of Thirty Thousand
Pesos (P30,000.00), beginning June 8, 2015 until May 20,
2016.10 During this period, Respondent Sereno saw the need
to hire another ICT Consultant despite the very expensive one
she already had, Ms. Macasaet.

23.3.5. The list goes on. Did the hiring of all these consultants,
especially those in the Office of the Chief Justice, pass
through the Court En Banc?

23.3.6. Respondent Sereno seeks to justify Ms. Macasaets fees

with the result of (her) work and that she developed and
reviewed the Terms of Reference, provided technical
assistance during procurements and quality assurance for at
least 16 projects, worth P3,467,275,676.71. Has any of these
16 projects been successfully completed, considering that Ms.
Macasaet has been the consultant for four (4) years now?

9
Contract of Service of Mr. Alexander M. Arevalo dated September 16, 2013.
10
Contract of Service of Atty. Carlos N. Garay dated June 3, 2015 and December 21,
2015.

Page 21 of 29
 23.3.7. Ms. Macasaets monthly fee of Two Hundred Fifty
Thousand (P250,000) greatly exceeds the salary of an
Associate Justice of the Supreme Court, which is at One
Hundred Fifty-Two Thousand Three Hundred Twenty-Five
Pesos (P152,325.00).11

23.4. It may not be amiss to mention that President Rodrigo Roa

Duterte just recently fired the head of the Sugar Regulatory
Administration (SRA) for hiring three (3) consultants who were
paid Two Hundred Thousand Pesos (P200,00.00) each a month.12

24. Strongly-worded but misplaced reply to President Rodrigo Roa

Duterte on the judges linked to drugs invites a head-on collision
between the Presidency and the Judiciary. Respondent Sereno argues
that her reply did not amount to a betrayal of public trust because she did
not violate Canon 3 on impartiality, since the letter she wrote was not in
the exercise of her adjudicatory functions.

24.1. The specific section of Canon 3 cited by Complainant talks about

impartiality as reflected by a judges conduct, both in and out
of court.

25. Prevented the Justices of the Court of Appeals to do a courtesy call

on President Rodrigo Roa Duterte. Respondent Sereno denies
preventing then CA Presiding Justice Reyes, Jr. from paying the
President a courtesy call. She claims, however, that she may

11
Based on Republic Act No. 6758 (Compensation and Position Classification Act of
1989) and the Second Tranche, Step 1 for Salary Grade 31 in Executive Order No. 201, series of
2016 (Modifying the Salary Schedule for Civilian Government Personnel and Authorizing the
Grant of Additional Benefits For Both Civilian and Military and Uniformed Personnel).
12
Genalyn D. Kabiling, Duterte fires SRA chief, limits hiring of consultants by govt
agencies, Manila Bulleting, September 19, 2017, available at
http://news.mb.com.ph/2017/09/19/duterte-fires-sra-chief-limits-hiring-of-consultants-by-govt-
agencies/ (last accessed September 27, 2017).

Page 22 of 29
 occasionally remind magistrates of the first Canon of the Code of
Conduct, which is entitled Independence.

25.1. Whether or not Respondent Sereno prevented the Justices of the

Court of Appeals from paying a courtesy call to President Duterte
is evidentiary in nature and will be verified later on.

26. Attacked the imposition of Martial Law in a commencement

address while the validity of Martial Law was still pending before
the Supreme Court, and later continued to participate in the
Courts deliberations. Respondent Sereno believes she did not attack
martial law in her commencement address, which she claims was an
exercise of her right of free speech. She also points out that she
delivered the speech days before the first petition questioning the
imposition of Martial Law in Mindanao was filed.

26.1. The Code of Conduct is clear: judges shall not knowingly, while
a proceeding is before or could come before them, make any
comment that might reasonably be expected to affect the
outcome of such proceeding or impair the manifest fairness of
the process.13

26.2. If she were even a mediocre Justice, Respondent Sereno would

have easily foreseen that an issue of such magnitude will
eventually ripen into a case before the Supreme Court.

26.3. That there are people, like Complainant himself, who took
Respondent Serenos statement as an attack against Martial Law,
thereby indicating her bias against it, shows that she did not
consider all the effects her statement could reasonably bring
about. As Chief Justice, she should be more circumspect of the
effects or reactions her words could elicit. The Code of Judicial
13
Canon 3, Sec. 4, New Code of Judicial Conduct.

Page 23 of 29
 Conduct enjoins judges to consider not only their own
impressions of their statements, but more importantly, the
possible impressions these could have on other people.

27. Joint Statement with the Presiding Justice of the Court of Appeals
regarding CA-GR SP No. 151029 which can very well be elevated to
the Supreme Court. Respondent Sereno insists that the cited Canons
are inapplicable because the Joint Statement contained absolutely no
comment on the proceedings in CA-G.R. SP No. 151029 and did not
touch on the substance or merits of said case. Rather, it focused solely
on the House Committees unprecedented issuance of show cause
orders against the three members of the Special 4 th Division of the CA.

27.1. Respondent Sereno is splitting hairs here. Firstly, the show cause
order, the very subject of the Joint Statement, is an incident
arising out of the proceedings in CA-G.R. SP No. 151029.
Secondly, by calling on the HOR to reconsider its [show cause]
order and avail of all legal remedies provided to it under the
Constitution, the law and the Rules of Court, Respondent
Sereno already revealed her position on the matter should the
case be elevated to the Supreme Court. This is exactly what the
cited Canons of the Code of Judicial Conduct seek to guard
against.

27.2. Respondent Serenos consequent inhibition of herself from G.R.

No. 232385, the Petition for issuance of Writ of Amparo filed by
the Ilocos 6, is precisely what is expected of her considering that
she already compromised her impartiality by issuing the Joint
Statement.

28. Practiced favoritism by allowing key positions in the Supreme

Court to remain unfilled for a long period of time in order to wait
for her staff to qualify, to the detriment of the service and great

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 demoralization of qualified Court employees. Respondent Sereno
claims that the matter of unfilled positions is an internal matter that is
currently pending before the Court En Banc, which should be allowed to
resolve it. She explains that the appointments to the vacancies were
deferred to await the resolution of a number of issues related to the
organizational development of the Supreme Court.

28.1. The key positions Respondent Sereno allowed to go unfilled are

vital for the efficient running and management of the offices they
belong to. In effect, it is as if Respondent Sereno allowed a
leaking pipe to remain unfixed or go un-replaced pending the
reorganization of her homes pipelines. No one in their right
mind would allow that to happen.

29. Appointment of a key official without authority or approval of the

Court En Banc, in violation of Court-established rules and the
Constitution. Respondent claims that this internal matter is also
pending before the Supreme Court En Banc. She maintains that the
appointment of the Chief of Office of the PMCO was in accordance with
applicable rules.

29.1. There is a procedure for the appointment of the Chief of Office of

the PMCO: first, the appointee must be recommended by the
Philippine Judicial Academy Board of Trustees to the Court En
Banc, and second, it is the Court En Banc which shall appoint the
said Chief of Office. Did Respondent Sereno follow this
procedure? No!

29.2. Respondent Sereno claims that the appointment was a collegial

act concurred in by Associate Justices Carpio and Velasco, Jr.
Are they the En Banc? Obviously not!

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 30. Giving her newly-hired staff foreign travels and granting them
travel allowance for their foreign travels without authority or
approval of the Court En Banc, in violation of Court-established
rules and the Constitution. Respondent Sereno claims that this matter
is likewise pending before the Supreme Court En Banc. However, she
opines that foreign travels (and related travel expenses) of court
personnel do not have to be approved by the Supreme Court En Banc.

30.1. Respondent Sereno cites the Human Resources Manual to justify

her position, stating that foreign travels of Justices or Judges and
court personnel must be duly approved by the Chief Justice and/or
the Chairpersons of the Divisions and that said provision does
not differentiate between foreign travel on official time and
official business.

The specific provision of the Human Resources Manual, which

was approved by the En Banc in a Resolution dated January 31,
2012 in A.M. No. 00-6-1-SC, cites Administrative Circular No.
15-2005 dated March 22, 2005, as its source. However, the En
Banc Resolution dated June 13, 2012 in A.M. No. 12-6-13-SC,14
promulgated on a later date, specifically states that requests
for travel abroad (of Supreme Court personnel) on official
business or official time are covered by A.M. No. 96-3-06-0,15
as amended. A.M. No. 96-3-06-0 did not delegate the approval
of foreign travel of members and personnel of the judiciary on
official time or official business to the Chief Justice.

31. All told, all these lies, excuses, and attempted justifications show her
unfitness to remain as Chief Justice of the Supreme Court. Hers are not
14
Guidelines on Requests for Travel Abroad of All Members and Personnel of the
Appellate Courts and Trial Courts, and Officials and Personnel of the Supreme Court and the
Office of the Court Administrator.
15
Guidelines on Requests for Travel Abroad on Official Business or Official Time by all
Members and Personnel of the Judiciary.

Page 26 of 29
 isolated cases but a series of continuing intentional violations and
excesses, from the day she took office until present. Shall we wait for
more and graver infractions and imprudence?

CLOSING STATEMENT

Reports say that Respondent Sereno was raised by her parents who were
simple public servants. She grew up in a modest environment and lived a simple
lifestyle while excelling in her studies.

Unfortunately, she is no longer the same simple Meilou Sereno people knew
from before.

From her present actuations, it is evident that power, authority and

extravagance have gone to her head. She has considered her lonesome self as the
Supreme Court En Banc. She has considered her lonesome self as superior to both
the Executive and Legislative Departments. She has considered her lonesome self
as entitled to the extravagance that is fitting with her superiority, at the expense of
public funds. Not to mention her natural propensity to lie with a straight face,
without remorse, which makes her a pathological liar.

She must go soon. Either she resigns or is impeached and removed from
office immediately. Her seven (7) years in office, two (2) as an associate justice
and five (5) (!!!) as a chief justice, are more than enough chances to show and
prove her character. We have seen enough. We have experienced enough. It is time
for her to go.

Page 27 of 29
 PRAYER

WHEREFORE, in view of the Impeachment Complaint, Respondent

Sereno's Verified Answer, and the herein Verified Reply, undersigned
Complainant Gadon respectfully prays that the House Committee submits a
favorable report to the House of Representatives, which in turn shall affirm the
favorable resolution with the Articles of Impeachment, and transmit to the Senate
of the Philippines the Verified Complaint for Impeachment/Resolution of
Impeachment against Respondent Chief Justice Maria Lourdes P. A. Sereno to
serve as the Articles of Impeachment for trial.

Thereafter, Complainant Gadon respectfully prays that the Honorable

Members of the Senate conduct trial forthwith and thereafter, render a judgment of
conviction against Respondent Chief Justice Maria Lourdes P. A. Sereno.

Other reliefs, just and equitable, are likewise prayed for.

Quezon City, Metro Manila, September 28, 2017.

ATTY. LORENZO G. GADON

Complainant

Page 28 of 29
 VERIFICATION

I, Atty. Lorenzo G. Gadon, of legal age with residence at No. 35, 7th Street,
New Manila, Quezon City, Metro Manila, after having been duly sworn, depose
and say:

1. That I am the complainant in the above entitled More Lies, More Lies and
More Lies of Maria Lourdes (as Verified Reply to her Verified Answer);

2. That I drafted said Verified Reply; and

3. That the allegations therein contained are true and correct based on my
personal knowledge or based on authentic records or public documents.

Witness my hand this _____ day of _____________ 2017 at

_________________________________, Philippines.

ATTY. LORENZO G. GADON

Affiant

SUBSCRIBED AND SWORN to before me this _______ day of

_______________________ in __________________________, Philippines.

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