Republic of the Philippines Department of Justice National Prosecution Office Office of the City Prosecutor Manila
People of the Philippines, Plaintiff, -
versus -
CRIMINAL CASE N0. 23458 FORCIBLE ABDUCTION WITH RAPE
JULIO JOSE 234 Asuncio Street, Tondo, Manila. Accused. x------------------------------------------------------------------------------------------------------------------x COMPLAINT
The undersigned accuses Julio Jose of the crime of Forcible Abduction with Rape, committed as follows: That on or about July 9, 2012, in the City of Manila, Philippines, the said accused, with lewd designs, did then and there willfully, unlawfully and feloniously abduct, take and carry away the undersigned complainant while coming out of a toilet in her home at 113 Magsaysay, Tondo, in said City, by means of force, violence and intimidation to wit: by pulling her and forcing her to walk, at the same time pointing at her a gun and threatening to kill her should she cry out for help, succeeded in bringing her to ride in his car, where they rode going to the house of the accused’s Uncle Sam where the said accused, by means of force, violence and intimidation, succeeded in having sexual intercourse with her against her will. Contrary to law. KATERINA MONTENEGRO Complainant SUBSCRIBED AND SWORN TO before me this 13th day of August, 2012, in the City of Manila, Philippines, by Katerina Montenegro, the complainant.
______________________________ Assistant Prosecutor
I hereby certify that an ex-parte investigation in this case has been conducted by me in accordance with law; that there is reasonable ground to believe that the offense charged has been committed; and that the accused is probably guilty thereof. Manila, August 13, 2012.
________________________ Assistant Prosecutor
WITNESSES: 1. Katerina Montenegro, 113 Magsaysay St., Tondo, Manila. 2. Det. Roger Salas, and Det. Arturo Santos, both of DB Detachment 3, MPF 3. Dr. Lorenzo Clarion, Medico Legal Div., MPF 4. Nathaniel Montenegro, 113 Magsaysay St., Tondo, Manila. BAIL RECOMMENDED: THREE HUNDRED THOUSAND PESOS (P300,000.00) ONLY.
