Few must have ever believed that former Ako Bicol Rep. Zaldy Co is the only potentially corrupt lawmaker in the House of Representatives (HOR). The Independent Commission for Infrastructure’s (ICI) request to the justice department to issue an immigration lookout bulletin order (ILBO) names 18 other HOR representatives, including presidential cousin former House Speaker Martin Romualdez.
This may give an impression of a widening net in the Marcos Jr administration’s supposed anti-corruption drive. However, a net ten times bigger or more may be needed to catch all the corrupt fish in Congress – an analysis of flood control projects on the “Sumbong sa Pangulo” website indicates that anywhere from around 100 to 230 HOR lawmakers may be involved in suspicious flood control projects.[1]
The website is a noticeably incomplete database though and the number of lawmakers potentially implicated may be even higher. The total Php540.4 billion project cost for the 9,759 projects listed are less than one-third (32%) of the Php1.7 trillion in flood control projects over 2018-2025. It is not even one-half (45%) of the Php1.2 trillion in flood control projects over 2022-2025. These projects are from the 18th and 19th Congress – the earliest starting February 2018 and the latest in March 2025 – and implemented by 2,407 contractors.
It is unclear why so many projects are missing and what the criteria are for posting on the website. Nonetheless, it is still a unique dataset that provides insight into the extent of corruption in Congress and, indirectly, within the public works department.
There are glaring red flags pointing to conscious manipulation of project costs. In thousands of projects, there are repeated exact values and, moreover, conspicuous clustering just below the Php50 million and Php100 million thresholds. The odds of these occurrences happening naturally are exceedingly small, making it reasonable to call these projects in 105 to 226 or more legislative districts suspicious.
This is not to say that every suspicious flood control project means that the lawmaker from that district is corrupt or perhaps connived with a corrupt party-list lawmaker. Still, the series of recent congressional hearings and multiple investigative reports have established that flood-control projects are among the most politically influenced types of public works in the Philippines.
Lawmakers apparently wield substantial informal influence over how projects are awarded and implemented, as they are responsible for identifying and secure funding. This combines with the politicized nature of the Department of Public Works and Highways (DPWH) and the technical opacity of flood-control projects to create vast structural opportunities for rent-seeking through collusion between lawmakers and their favored contractors.
Hence, while not conclusive, current publicly-available evidence strongly suggests systematic collusion involving hundreds of lawmakers and thousands of contractors. It is plausible that provable criminal cases can be pursued against them. Subsequent efforts at transparency, auditing, and citizen oversight are actually strengthened or weakened by the extent by whether or not such accountability happens.
Most guilty: Perks of power
The distribution of flood control projects predictably corresponds to proximity to power with ruling parties having the most legislative districts and, correspondingly, the most projects by numbers and value. Taking all the projects in the “Sumbong sa Pangulo” website as a whole, districts of the ruling Partido Federal ng Pilipinas (PFP) and Lakas parties account for 3,329 flood control projects worth Php194.9 billion, equivalent to over 36% of all projects by value. (See Annex 1)
The three billionaire political parties National Unity Party (NUP), Nationalist People’s Coalition (NPC), and Nacionalista Party (NP) are not directly associated with either of the last two presidents. However, districts with their representatives conspicuously account for a large Php243 billion or 45% of all projects by value. In a way, this quantification confirms the continuity of their presence whichever party the president comes from. Districts with Liberal Party representatives had a much smaller Php15.7 billion.
The publicized data seems to confirm that being with the political party or parties most closely associated with the president provides certain benefits. It is unclear to what extent this is from resulting insider access during the budget preparation stage – which occurs in the first six months of the year overseen by the Department of Budget and Management (DBM) to prepare the President’s Budget submitted to Congress – or from the ruling party’s influence over the budget legislative process in the last six months of the year, or from both.
In the 18th Congress under the Duterte administration, the number and average total value of projects per district with a Hugpong ng Pagbabago (HNP) representative was the highest among all political parties at Php1.5 billion. (See Annex 2) HNP was by that time the de facto party of the Duterte administration.
In the 19th Congress under the Marcos Jr administration, the number and average total value of projects per district with a representative from the president’s PFP was the second highest at Php1.9 billion. This was exceeded only by the striking 63 projects worth Php4.7 billion accounted for by the United Nationalist Alliance’s (UNA) sole district representative. (See Annex 3) Former senator Nancy Binay (UNA) is among those the ICI is requesting for a lookout order.
The legislative districts with the most flood control projects listed on the website are Bulacan 1st district (Php13.2 billion), Tarlac 1st district (Php10.4 billion), Bulacan 3rd district (Php9.5 billion), La Union 2nd district (Php9 billion), and Cebu 7th district (Php8.7 billion). (See Annex 4) Rep. Romualdez’s Leyte 1st district does not fall in the top 20 with the “Sumbong sa Pangulo” website reporting only Php5.3 billion worth of flood control projects there.
The provinces or cities with the most flood control projects are Bulacan (Php43.7 billion), Cebu (Php26.6 billion) Isabela (Php22.6 billion), Tarlac (Php18.2 billion), and Camarines Sur (Php17 billion). (See Annex 5) Further research would be needed to establish how flood-prone these areas are and, particularly, if the amounts involved are technically justified.
Red flags
Nonetheless, the data already points to the very plausible and serious likelihood of widespread large-scale corruption in Congress involving flood control projects – even without yet examining the hundreds of billions of pesos annually budgeted for unlisted flood control projects and for other similarly corruption-prone roads, bridges, and buildings. Data from the “Sumbong ng Pangulo” website data reveals red flags so extensive and patterned that they strongly indicate systematic collusion between lawmakers and contractors. The scale and consistency of these anomalies make it improbable that they occurred without the knowledge of congressional leaders and even the president himself.
Flood-control project costs would naturally be expected to vary widely, given the differing locations, scales, materials, and technical requirements shaped by each community’s specific conditions and terrain. Yet, even allowing for possible DPWH standard cost templates, the frequency and scale of suspicious project costs suggest something far beyond natural coincidence and points instead to deliberate and programmatic manipulation.
Red flag #1: Suspiciously repetitive project costs
The “Sumbong ng Pangulo” list shows highly repeated identical project costs recurring dozens to hundreds of times across ostensibly different projects – 1,946 projects or one-fifth (20.3%) of all projects, in 105 legislative districts, share an exact cost with at least one other project. This can be considered a low estimate of the number of districts with suspicious projects.
The most frequently repeated exact amounts are: Php49 million (appears 309 times), Php96.5 million (307 times), Php29.4 million (81 times), Php19.6 million (76 times), Php4.95 million (61 times), Php67.55 million (55 times), Php39.2 million (51 times), Php9.8 million (45 times), Php77.2 million (44 times), Php24.5 million (39 times) and Php99 million (27 times). These repeat across different contractors in different regions or provinces, and sometimes even within a congressional district by the same contractor.
This is an unnatural repetition given presumably varied costs. Projects seem to be deliberately broken into uniform amounts to stay under approval thresholds or to disguise pork allocations. Amounts may in some instances also be equal to ensure an equal distribution among different favored contractors. For whatever reason, this is a strong indicator of templated or engineered allocations rather than genuine project-based costing.
The districts with the most number of suspicious repeated identical project costs are: Tarlac 1st district (58 projects); Davao City 2nd district (68 projects), Nueva Vizcaya lone district (48 projects), Abra lone district (45 projects), Misamis Oriental 2nd district (44 projects), Isabela 3rd district (29 projects), Albay 1st district (57 projects), Pangasinan 1st district (32 projects), Camarines Sur 5th district (26 projects) and Rizal 3rd district (43 projects). (See Annex 6) The cumulative value of such projects per district ranged from Php1.9 billion (Rizal 3rd) to Php4.6 billion (Tarlac 1st).
These projects with repeated costs are associated with 781 contractors – which can be considered a low estimate of the number of dubious contractors colluding with lawmakers. These contractors account for 5,408 of all listed projects cumulatively worth Php333.1 billion (roughly over 60% of total value of projects listed). The frequency of repeated costs among these firms – with the top 15 contractors having many dozens each (See Annex 7) – again very strongly suggests coordinated bidding or cost-setting practices.
The contractors and districts of particular political parties most tied to projects with suspiciously repeated costs during the 19th Congress can be mapped against each other. (See Annex 8) Mapping like this reveals how a small cartel of contractors appears to be well-connected to various political parties. This greatly amplifies the risk of institutionalized corruption and points to a systemic patronage economy embedded in the Congressional budget process and DPWH project execution.
Rent-seeking networks evidently cut across administration-opposition lines. Among the contractors with notable cross-party networks are Alpha & Omega Gen. Contractor & Development Corp., Legacy Construction Corporation, Sunwest Construction & Development Corp., and Royal Crown Monarch Construction & Supplies Corp. These firms are likely able to diversify contracts among different lawmakers from having an extensive reach within the DPWH’s procurement system.
Red flag #2: Suspicious clustering of project costs
The “Sumbong ng Pangulo” list also shows a large share of projects tightly clustering just below certain rounded thresholds – estimated as those priced within 5% of the threshold. The biggest clusters of projects are just below Php50 million (1,737 projects in 226 districts, totaling Php84.7 billion) and Php100 million (1,312 projects in 195 districts, totaling Php126.8 billion).
Nearly one-third of all projects in over two-thirds of all congressional districts are suspicious for their clustering just below the Php50 million and Php100 million thresholds. In all, 3,049 projects spread across up to 226 legislative districts are concentrated in these two narrow cost windows. This can be considered a high estimate of the number of districts with suspicious projects.
These 3,049 suspicious projects are implemented by 936 contractors – which can be considered another low-end estimate of the number of dubious contractors colluding with lawmakers. The below-Php50 million and -Php100 million pricing bands are clear areas of focus for these contractors. For instance, taking just the top 10 of these 936 contractors, these two pricing bands account for a disproportionate 41% to as much as 82% of each of their flood control project portfolios.
But there is also dubious clustering just below other rounded-off thresholds: Php5 million (539 projects totaling Php2.6 billion), Php20 million (484 projects, Php9.4 billion), Php25 million (219 projects, Php5.3 billion), Php30 million (510 projects, Php14.9 billion), Php70 million (244 projects, Php16.6 billion), and Php80 million (280 projects worth Php21.7 billion).
Plotting the number of projects at different cost levels shows the highly unnatural clustering of project costs particularly just below Php5 million, Php20 million, Php50 million, and Php100 million. (See Annex 9) Instead of a smooth distribution, sharp spikes appear at these points which suggests projects being deliberately priced – with the strongest peaks just below Php50 million and Php100 million.
The top 10 provinces with the most number of suspicious clustering are: Bulacan (198 projects totaling Php15.8 billion), Cebu (171 projects, Php13.5 billion), Isabela (149 projects, Php12.2 billion), Leyte (84 projects, Php5.8 billion), Pangasinan (85 projects, Php5.6 billion), Negros Occidental (62 projects, Php4.7 billion), Tarlac (53 projects, Php4.5 billion), Abra (54 projects, Php4.0 billion), Pampanga (56 projects, Php3.8 billion), and Ilocos Norte (56 projects, Php3.7 billion).
The clustering is an unnatural concentration of presumably varied project costs according to varied project circumstances. This is not in itself proof of corruption but the sheer scale, frequency, and patterning of such projects give strong grounds for suspicion. They are very unlikely to be natural engineering outcomes due to technical project requirements and, instead, seem to be systematic and standardized packaging for political or administrative convenience.
Project pricing and splitting may be done to fall under procurement, audit or other regulatory ceilings. The Php50 million threshold, for instance, might be the limit for delegated field approval by DPWH regional or district offices. As it is, the median cost of the projects listed in the website is conspicuously about Php49 million. The Php100 million threshold in turn may be an informal threshold for stricter Commission on Audit (COA) auditing or DBM monitoring. Meanwhile, amounts like Php20 million or Php30 million may just be accustomed pork barrel units for equal distribution as patronage.
Red flag #3: Rounded artificial-looking values
Real construction project costs rarely come out to neat rounded numbers. However, at least 353 projects in 87 legislative districts are priced in neat, rounded millions (e.g., exactly Php50,000,000.00, Php100,000,000.00), and at least 1,066 projects in 175 legislative districts within ±Php10,000 of a clean million (e.g., Php49,990,000 or Php50,008,000). These reinforce the likelihood of manipulated amounts.
Least guilty: Conniving contractors
The “Sumbong sa Pangulo” website lists 2,400 unique contractors by name, not yet considering any cross-ownership. The overwhelming majority of 2,115 contractors (88%) operates in just one region, 202 contractors in two regions (8.4%), and just 83 contractors (3.5%) in three or more regions nationwide.
It was already mentioned how some 800-900 of these contractors can be considered a low estimate of the number of dubious contractors colluding with lawmakers, because of their high repetition and clustering of project costs. A few other observations can be made.
There is heavy concentration among a few firms with 10 contractors accounting for a very large share of total flood control contract costs. Each of these handled projects in at least five (5) regions with some reaching 10–13 regions.
Moreover, the same big names dominate both pre-June 2022 (Duterte term) and from July 2022 onwards (Marcos Jr. term) which indicates continuity of corrupt political-business networks despite changes in ruling parties. This shared-pool of politically-trusted contractors is a cartel which needs to be investigated for collusion, price-setting, and controlled biddings.
Only a handful of firms have nationwide reach presumably backed by strong political connections and ties within the DPWH. These include the controversial “Alpha & Omega” of the Discayas which is among the most dominant, consistently ranking first or second in total contract value and appearing across multiple periods and regions. Such firms are among the few capable of facilitating the distribution of lawmakers’ pork barrel projects across different legislative districts – and, correspondingly, among the few able to point to many potentially corrupt senators or representatives.
Naming names
In a recent podcast, the president feigned surprise at the extent of corruption. Yet the Marcos Jr administration still refuses to marshal the resources needed to investigate the hundreds of lawmakers potentially implicated – including taking testimonies, tracking financial records and paper trails, and conducting forensic audits to uncover graft or kickback schemes. Doing any less is protecting the corrupt through calculated inaction.
Genuinely building the capacity of the government to crack down on systemic corruption involves first of all cracking down on corruption in the anti-corruption agencies themselves – i.e. Ombudsman, Commission on Audit (COA), Bureau of Internal Revenue (BIR), Civil Service Commission (CSC), Comelec, and justice department. This is absolutely necessary for any increase in their personnel or capacity to be meaningful. As it is, inter-agency teams to go after corrupt high-level officials may need 30 or more people each – multiplying this even by just the number of potentially corrupt legislators in the HOR already means 6,000 additional people needed, on top of those already assigned current workloads.
Naming names in a corruption scandal is not trial by publicity. It is the first step towards breaking the normalization of corruption and shattering the shield of impunity. Naming the powerful signals that no one is untouchable and rallies citizens to collective action.
The pace-setters in the country’s endless corruption scandals have long been rival factions of the elite. Corruption endures because these exposés are driven more by factional in-fighting than a real effort to uproot it. This points to how the only force strong enough to overcome entrenched corruption is a broad mass movement determined to challenge it wherever it is, from the lowest to the highest levels of government.
The government already has more than enough information to name more names than the handful it has so far. If the Marcos Jr administration remains so selective, it will only confirm that its hyped anti-corruption drive is just another of the country’s periodic symbolic purges staged to refresh and re-legitimize the stubbornly corrupt old order.
[1] IBON used AI and manual methods to process data from the Sumbong sa Pangulo website scraped by journalist Jaemark Tordecilla.
Annex 8. Contractor vs. Political Party with Repeated Project Costs
Annex 9. Project Cost Distribution
