REPUBLIC OF THE PHILIPPINES) Province of ____________________) S.S. City/Municipality of _____________ x-----------------------x
AFFIDAVIT – COMPLAINT COMPLAINT
I, SADDI STA, of legal age, married, Filipino citizen and a resident at #69 Brookside, Baguio City, Philippines, after having been sworn to in accordance with law, do hereby depose and say:
1. That I am instituting this CRIMINAL COMPLAINT against MARIA STA. CRUZ, of legal legal age, married,Filipino married,Filipino citizen, resident at #70 Brookside, Baguio Baguio City, Philippines for ORAL DEFAMATION as defined defined and penalized under Article 353 in relation to Article 358 of the Revised Penal Code of the Philippines; 2. That the acts complained of were committed as follows:
heading home at # 69 Brookside, Baguio Baguio City a. Yesterday at around 5pm, I was heading when I met my neighbor, Maria Sta. Sta. Cruz who, without saying saying nothing, to my surprise, she intentionally shouted (”PUTA KA!, INAGAW MO ASAWA KO, PALAGI KAYONG NAGLALANDIAN SA ILALIM NG BAHAY NAMIN”), You are a whore!You stole my wife!,You are always flirting with each other uttered a lot of times and was heard by my neighbours under our house. It was uttered and my son who is Five years old. b. That the statement was uttered by Maria Sta. Cruz on September 06, 2011publicly and clearly prompted not by a sense of moral duty but by personal personal ill-will, spite and/or malice with the object of destroying my reputation and discrediting and ridiculing me as an individual before the bar of public opinion and contempt; c. The ill-effects of the malicious utterances are shown by the negative responses that I have-received from my neighbors, especially my son, expressing belief in respondents' baseless allegations as shameful, heinous and unequivocally barbaric - all to my damage and prejudice; 3. That by reason of the foregoing, I suffered sleepless nights, wounded feelings, moral and social embarrassment which Maria Sta. Cruz should compensate by way of damages which is the natural, proximate and necessary result of the malicious publication in the amount of not less than One Hundred Thousand Pesos (PhP 100,000.00) which shall be donated for various programs for the welfare of the children of Barangay Brookside; 4. That I am executing this affidavit to attest to the truth of the foregoing averments and for the purpose of criminally prosecuting said Maria Sta. Cruz for ORAL DEFAMATION/SLANDER as there are grave utterances as determined by the City Prosecution Office in the preliminary investigation.
IN WITNESS WHEREOF, I have hereunto affixed my signature this 6 September, 2011 at Baguio City, Philippines.
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SADDI STA Affiant CTC No.:01-55454543- 1 Issued on: February 17, 2011 Issued at: Baguio, City
JURAT and CERTIFICATION
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SUBSCRIBED and SWORN to before me this 6 day September, 2011 at Baguio City, Philippines. I hereby certify that I have personally examined the affiant and t hat I am satisfied that he read and understood the contents of his affidavit-complaint and that he voluntarily executed the same.
AMELING, PHILIP RAY B. City Prosecutor
