AFFIDAVIT COMPLAINT

REPUBLIC OF THE PHILIPPINES

CITY
OF
D A V A O)s.s.
X_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x
I, MARIA B. CARGO, filipino, of legal age, married and a resident of Block 5, Lot 18, Phase
5, Ecoland Subdivision, Matina, Davao City, under oath, hereby states:
1 That my husband is PEDRO C. CARGO, who is a physician by profession, and,
especialized in Oncology;
2 That my husband and I contracted marriage in Davao City, on May 25, 1995, at the St.
Paul Church, Ecoland, Matina, Davao City, evidenced by a certificate of marriage hereto
attached as Annex A;
3 That out of our marriage, we begot two (2) children Mary B. Cargo, 12 years of age and
Pedrito B. Cargo, six (6) years of age;
4 That I am charging my husband for Violation of Section 5 (e) paragraph 2, otherwise
known as the Anti-Violence Against Women and their Children Act, committed as follows:
A That earlier said, my husband and I contracted marriage on
May 25, 1995;
B In the initial years of our marriage, life was so blissful for me
and our two (2) children;
C Aside from being loving and thoughtful, my husband was a
good provider not only to me but to our two (2) children as well;
D So to speak, it was like life living in an Oasis;

E However, this had all changed starting sometime in June 2007,

when my husband accepted an offer to work at the St. Lukes
Hospital in Manila;
F In the first two months of his work at the St. Lukes Hospital,
my husband was very prompt in sending to me and our two (2)
children the monthly support in the amount of ONE HUNDRED
THOUSAND (Php 100,000.00), Pesos Philippine Currency;
G However, starting the month of September 2007 and onwards,
suddenly, the monthly support given by my husband started to
become irregular;
H During, the month of September 2007, sent to me and our two
(2) children only the sum of Twenty Thousand (Php 20,000.00),
Pesos, Philippine Currency;
I That when I called up my husband through his cell phone to ask
why he only sent the amount of

Php 20,000.00, his

answer was he was paying for some accounts thereon;

J Trusting, my husband, I accepted at face value his explanation,
expecting that his monthly remittance for our support would
become regular starting October 2007;
K However, this turned out to be otherwise; In October 2007, my
husband sent only the amount of FIFTEEN THOUSAND (Php
15,000.00), Pesos, Philippine Currency;

L Again, when I called up my husband through his cell phone

about his reason or reasons in sending a very small amount for our
support, his answer was at least he was still sending money to me
and our two (2) children;
M For the month of November and December 2007, my husband
was only able to send the the total amount of THIRTY TWO
THOUSAND (Php 32,000.00), Pesos, Philippine Currency or at
Php 16,000.00 for each of the two (2) months;
N Worst, my husband never went home in Davao City, to spend
Christmas with me and our two (2) children;
O That starting the month of January 2008 and up to the present,
despite my repeated pleas both oral and written, my husband had
altogether refused to give money to me and our two (2) children,
both of whom were attending grade school at the Ateneo de Davao
University;
P That, this has caused so much emotional and financial distress
not only to me but to our two (2) children, where I could already
hardly give them their daily allowance in going to school;
Q That, because of this, I was forced to borrow money from my
parents just for my two (2) children to have their allowance in
attending school at the Ateneo de Davao Univeristy;
R That starting the month of January 2008 and up to the present,
my children and I have been totally dependent for support from my
parents;

S That the act of my husband without any justifiable reasons in

depriving me and our two (2) monthy support constitutes economic
violence under Section 5 (e) paragraph 2 of RA 9262, otherwise
known as the Anti-Violence Against Women and their Children
Act;
T That as a physician at the St. Lukes Hospital in Manila, my
husband earns a monthly income of Five Hundred Thousand (Php
500,000.00), Pesos, Philippine Currency, thus, there is no reason
that he would deprived me and our two (2) children the monthly
support thereof.