Now Being Taught in Every DepEd Classroom
By Louis “Barok” C. Biraogo –November 21, 2025
MGA ka-kweba, boys and girls, future taxpayers of this benighted republic:
Gather round while Education Secretary Sonny Angara gives us all a masterclass in Evidence Law 101.
His syllabus in one sentence:
“If there’s no GoPro footage of me personally pocketing a briefcase stuffed with crisp thousands, it’s just hearsay. Case dismissed.”
Bravo, Secretary. Truly the kind of critical thinking we want leading the Department of Education.
Let’s dissect this steaming pile of legal sophistry, shall we?

1. The “Hearsay” Defense: Technically Correct, Strategically Pathetic
Yes, Your Honor — I mean, Secretary — under Rule 130, Section 36 of the Revised Rules on Evidence, an affidavit is classic hearsay if the affiant doesn’t take the stand and get cross-examined. The Supreme Court has said it a thousand times: affidavits are hearsay and have zero probative value in court unless the maker testifies. See People v. Alhambra, G.R. No. 207774, 30 June 2014 — you know, basic sh*t.
But here’s the part Sonny conveniently forgets while polishing his halo:
Roberto Bernardo didn’t just mail in a notarized love letter.
He showed up at the Senate Blue Ribbon Committee hearing, took the oath, read his supplemental affidavit, and subjected himself to questioning. That’s live testimony, genius — the exact thing that cures the hearsay defect.
And even if it were pure affidavit, guess what?
In preliminary investigations, in Ombudsman fact-finding, in Senate inquiries in aid of legislation — affidavits are more than enough to open the floodgates (pun fully intended) of subpoenas, bank-record lifts, lifestyle checks, and forensic audits.
Probable cause ≠ proof beyond reasonable doubt.
The Ombudsman already announced it’s investigating everyone named in Bernardo’s affidavit. That’s not “hearsay.” That’s game on.
2. “No Specific Transaction” — Except the Part Where Your Own Staffer Quit the Day After Being Named
Angara’s other gem: “Walang specific accusation… no mention of any transaction.”
Really, Secretary?
Bernardo said, under oath:
Your former chief-of-staff Trygve Olaivar — now magically your DepEd Undersecretary — “received deliveries” equivalent to 12% of flood-control projects every time you were Senate Finance chair.
That’s not “someone said something.”
That’s: named perpetrator → named bagman → exact percentage → specific project type → exact period you held the gavel.
And then — plot twist! — the day after Bernardo dropped that bomb, Trygve Olaivar suddenly resigned “for personal reasons.”
How convenient. Nothing screams innocence like your alleged bagman sprinting for the exit the moment sunlight hits him.
Two decades of a “clean record”?
Congratulations. It just means the operation was sophisticated enough to stay hidden until someone finally sang. Longevity in Philippine politics isn’t a certificate of purity — it’s usually a loyalty discount at the corruption buffet.
3. Tale of the Tape: Bersamin & Pangandaman vs. Saint Sonny
Let’s run the comparison nobody in Malacañang wants you to make:
| Official | Allegation Severity | Evidence So Far | Response |
|---|---|---|---|
| Lucas Bersamin | Generalized cloud over budget insertions | Political pressure + family ties | “Resigned” (claims he was fired) |
| Amenah Pangandaman | Same budget mess, indirect links | Same | Tendered courtesy resignation |
| Sonny Angara | Direct, named 12% kickback scheme via personal staffer | Sworn affidavit + live Senate testimony + bagman quits | “Hearsay lang po, pass ako” |
Translation: the first two fell on their swords (willingly or with a gentle push) over amorphous suspicion.
Angara is accused of running a percentage-based kickback pipeline through his own aide — and he gets the red-carpet treatment.
Why the special privilege?
Because he’s from “good stock”? Because he still has allies in the Senate?
Or because the administration is terrified that if the Education Secretary goes, the whole house of cards starts tumbling?
4. The Law Doesn’t Need 4K Video to Bite Your Ass
Possible charges on the table right now:
- RA 3019 §3(e) — causing undue injury through manifest partiality (those flood-control projects got funded, didn’t they?)
- RA 3019 §3(g) — entering into contracts grossly disadvantageous to the government
- RA 6713 §7(d) — Code of Conduct violation (if your own staffer is collecting “deliveries,” that’s a conflict of interest the size of Luzon)
- Plunder (RA 7080) — if the total take crosses P50 million, hello lifetime subscription to Bilibid
Criminal conviction? Needs proof beyond reasonable doubt.
Administrative dismissal? Only substantial evidence — and Bernardo’s testimony plus Olaivar’s magical resignation is already flirting with that threshold.
5. Delicadeza Is Not a Suggestion, It’s the Bare Minimum
Secretary Angara, do the honorable thing:
- Resign immediately — not because you’re guilty, but because delicadeza still means something to the rest of us mortals.
- Waive bank secrecy for yourself and all your former and current staff from 2019–2024. Let the National Bureau of Investigation (NBI) and the Anti-Money Laundering Council (AMLC) run wild. If you’re clean, you have nothing to hide.
- Support a complete ban on congressional insertions that aren’t publicly sponsored, justified, and geo-tagged. End this pork-barrel ghost once and for all.
Until then, spare us the Evidence Law lectures.
The country already has enough failing marks in Reading Comprehension — we can read between the lines just fine.
Yours in perpetual rage,
—Barok
Key Citations
- Chi, Cristina. “Angara Rejects Calls to Resign, Labels Allegations ‘Hearsay’.” Philstar.com, 19 Nov. 2025.
- Republic Act No. 3019, “Anti-Graft and Corrupt Practices Act.” Official Gazette of the Republic of the Philippines.
- The Philippines. Republic Act No. 6713: Code of Conduct and Ethical Standards for Public Officials and Employees. 20 Feb. 1989. LawPhil.
- The Philippines. Rules of Court. Rule 128-134: Rules on Evidence. LawPhil.
- People v. Alhambra, G.R. No. 207774, 15 Dec. 2015. Supreme Court E-Library.
- Republic Act No. 6770, “The Ombudsman Act of 1989.” Official Gazette.
- Abarca, Charie. “Former DPWH official links more senators to kickbacks.” Inquirer.net, 15 Nov. 2025.
- “Roberto Bernardo tags Grace Poe, Jinggoy Estrada, Sonny Angara in flood control corruption.” Rappler, 14 Nov. 2025.
- Panti, Llanesca T. “Ombudsman: All lawmakers, officials in Bernardo affidavit under investigation.” GMA News Online, 17 Nov. 2025.
- Chi, Cristina. “DepEd undersecretary linked to flood control scandal resigns.” Philstar.com, 18 Nov. 2025.
- Presidential Communications Office. “President Marcos accepts resignations of ES Bersamin and DBM Secretary Pangandaman.” Presidential Communications Office, 17 November 2025.
- “Manila Court Finds Senate Witness Guteza’s Affidavit Falsified.” Inquirer.net, 28 Oct. 2025.
- Republic Act No. 7080, “An Act Defining and Penalizing the Crime of Plunder.” Official Gazette.

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