REPUBLIC OF THE PHILIPPINES DEPARTMENT OF JUSTICE OFFICE OF THE CITY PROSECUTOR TAGUIG CITY

GEORGE H. MORELLO, JR., Complainant -versusMARIETTA D. ROSARIO, ALEJANDRO A. ROSARIO, JR., J.C. DEL ROSARIO, Respondents. x------------------------x

I.S. No._______________ FOR:VIOLATION OF SECTIONS RA No. 7877

COMPLAINT-AFFIDAVIT I, GEORGE H. MORELLO, JR., of legal age, American citizen, residing at Unit 4G, Kensington Place Condominium, 1st Avenue cor. 29th Street, Crescent Parkwest, Bonifacio Global City, Taguig City, after having been sworn in accordance with law, do hereby depose and state that: 1. The respondents, Marietta D. Rosario, Alejandro A. Rosario,Jr., and J.C. Del Rosario, are corporate officers of the Jaltar Corporation, the owner of a condominium unit located at Unit 16-I, Kensington Place Condominium. They may be served with notices at the corporation’s office address at No. 33 Mary St., Cubao, Quezon City. 2. On 26 October 2011, I entered into a Residential Lease Agreement with Jaltar Corporation, for the lease of its condominium unit located at Unit 16-I at Kensington Place Condominium. A copy of this Residential Lease Agreement (Agreement) is attached hereto as Annex “A.” The Agreement named myself and my nurse, Ms. Shiela Marie Yeso Doria, as the tenants of Unit 16-I.

There were times when I felt really uncomfortable and even thought of resigning from work. complained about three (3) of the appliances provided by Jaltar. but still. I asked again if my lease could be extended for 1 November 2012. Burner Stove. which made me feel disgusted. As early as December 2011. Instant Water Heater for Shower. I. Tenant will keep appliances provided by Landlord in good working order and shall report any malfunction to the Landlord. I was advised that outside help would clean or replace the same. refrigerator. APPLIANCES I. It reads in part: 11. On 11 February 2012. Paragraph 11 of the said Agreement provides that the tenants shall keep the appliances provided by the Landlord (Jaltar Corporation)in good working order.3. Landlord will supply and maintain: Airconditioning Units. 7. Refrigerator. I again requested for a meeting in Jaltar’s office but nobody bothered to send me a reply even to just reject my request. during a meeting with Mr.. there were also instances when he would touch me. Aside from his text messages. Jr. xxx xxx xxx 4. no reply came from Jaltar’s end. namely: the dryer. In July 2012. Microwave Oven. . I had already complained that the exhaust fan over the stove burners and the guest bathroom fan were not in good working condition. it was plainly ignored. Alejandro Rosario. 5. but nothing was done thereto. 6. My complaint was for the following: a. LCD Television Screen. on two (2) instances. a. and microwave oven. The refrigerator had to be defrosted thrice in a week to prevent our food from spoiling.

” I was literally shaking but I was able to manage a reply. “‟Wag mo isiping ganon ako. hindi po pwede dahil may asawa na po kayo at boss ko po kayo. Mr. below is an accurate account of what happened next. I immediately backed away and hurriedly went downstairs. Reyes: “‟Wag mong isiping gagawin kitang kerida. may itatanong lang.” Mr.” Mr.” 9. hindi pa ho ba pagiging kabit ang tawag dyan sa gusto nyong mangyari?” Mr. “Hindi na po ako aakyat dyan ng mag-isa lang!” 11.wala namang makakaalam kung hindi mo sasabihin sa iba. Reyes: “Ja. Reyes sent me a text message asking me to go up to his office to hand him the Attendance Logbook. hindi ba talaga tayo pwede?” Me: “Sir. Reyes: “E imposible mangyari yun!” Me: “Ayun nga po sir. Mr.” Me: “Sir. ang ganda-ganda mo talaga. „Wag mo kasi isiping iiwanan ko ang asawa at mga anak ko. I received another text message from Mr. He was shouting “Ja. sir.” I knocked on the door and was about to open the same when I was surprised that Mr. Reyes saying “Akyat ka ulit. Reyes opened the door and he suddenly grabbed both my hands. Reyes: “E kailan tayo magiging pwede?” Me: “Kapag wala na po kayong asawa. IMPOSIBLE po kasi ang gusto nyo! Bababa na po ako. Ja. in the roundabout in Timog Ave. Reyes: “Nasa isip mo lang kasi „yon! Kailangan ko pa bang lumuhod sa harap mo para pumayag ka lang? Kasi kaya kong gawin yon. Another instance was last 30 April 2013 in Center Stage. Upon coming down and having returned to my desk. He then immediately sent me a text message saying.8. Ja. He started asking me questions on how to reprimand employees who always come late at work. which I did. Nakakahiya po kay madame yan.” but I never looked back.” Mr. At one instance.” Me: “Sir. After giving my answer. pinapahamak nyo po ako sa ginagawa nyo! Nakakahiya po kay Madame. Quezon . 10..

followed after office hours. Reyes was playing billiards and I was sitting on a stool and enjoying my drink with my coworkers. Again. that made me even more scared of him despite the presence of other people. Reyes would suddenly jump and squeeze himself in the group to be right beside me in order . The others had gotten theirs first. I tried avoiding him for the rest of the night seeing clearly that he was already drunk. It was our Supervisor’s (Ms. Mrs. It had a billiards table and a videoke machine. Reyes suddenly appeared in front of me and said. Reyes informed everyone thru text that there would be a sort of a “girls’ night out” videoke for some bonding time with the company employees. Escama) post-birthday celebration party in the Elbow Room in Metrowalk. and Tony. Pasig City. Ms. It was about three times that whenever a picture was about to be taken. I noticed that whenever it was Mr. Mrs. 12. Ortigas. This was seen by some of my co-workers. Mr. “Sir. Ms.” I said. “Sabay na kayo kasi dun naman si Tony dadaan sa bahay. another coworker. he would deliberately brush his bottom (puwit) onto my back. Escama rented a VIP room for the celebration. Reyes suddenly pressed his forefinger on my nose and lips. arrived later that night with his own car. 14. the company driver. kay Aldrin na po kami sasabay kasi magkakape pa po kami. After that. I was then reaching for a paper bag containing my lunch box when Mr. Aldrin Garcillano. Then before heading home. We rode the company van going to Center Stage. Escama asked that pictures be taken of the group. Reyes’ turn to play. Jasmine Pio and Florie Ann Escama. while me. Reyes together with two other co-workers. Then again on 26 June 2013. 13. Edward Paul Santos. Mr. Joanna Mary Cruz.” It was then when Mr. were already in the area. We finished around 12 o’clock midnight and we headed out to the company van to get our bags. respondent. this was seen by my other co-workers.City.

Mrs. I did not insist on giving them back because I was afraid he might get angry with me and risk my employment in their company. Reyes would just deny everything to his wife. 16. I would be left without a job. might think of me after witnessing the Respondent’s unnecessary gesture. I wanted to shout at that time but I decided not to because I might get myself into trouble with my bosses. Aside from the charm bracelet and teddy bear. 17. and last Valentine’s Day. a charm bracelet which he asked their family driver. I shrugged his arm and hurriedly went inside one of the company vehicles that just arrived. It is such a small company that I was afraid that Mrs. then Mr.to press his body onto mine. Reyes would later on find out. So I kept my silence. until recently. Kuya Leo. Also. At that time. and consequently. while we were waiting for the company drivers to get the company vehicles that would take us home. Reyes. 15. It wrapped me in a sort of a hug and its hands touched my lips up unto my nose. 1 Attached hereto are machine copies of the pictures of respondent’s gifts to me and marked as Annexes “C to C-4. I have given all his gifts to others because I did not want to use them because he might see such act that I was entertaining his actions toward me.” . Lastly. on several occasions. a silver chained-hearts bracelet. Reyes was just standing beside him. I had tried giving back his gifts but he had always refused. to personally deliver to our house. I felt an arm appeared on my left shoulder. I felt really ashamed of what the others. a box of rose and a teddy bear which he sent thru a courier service to our house. especially Mrs. until now. suddenly. I looked and saw it was Mr. I have told my closest friends of what Mr. a wristwatch. Reyes had been doing to me. Reyes. but I never told anyone in the office. the respondent would give me gifts.1 A silver chain bracelet. This was noticed by another co-worker.

RA 7877. education or training-related sexual harassment is committed by an employer. or offensive environment for the employee. Work. request or requirement . demands. Work. agent of the employer. I understand that these acts of the respondent Mr. to wit: SECTION 3. professor.[Emphasis and underscoring supplied] and supported further by jurisprudence that: Yet. coach. request or requirement for submission is accepted by the object of said Act. manager. sexual harassment is committed when: (1) xxx (2) xxx xxx xxx xxx xxx (3) The above acts would result in an intimidating. It is true that this provision calls for a "demand. instructor. he would still be administratively liable. or any other person who. influence or moral ascendancy over another in a work or training or education environment. (a) In a work-related or employment environment. Reyes constitute acts punishable under Section 3(a)(3) of the Anti-Sexual Harassment Act (RA 7877). Education or Training -Related. employee. even if we were to test Rayala’s acts strictly by the standards set in Section 3. trainor. regardless of whether the demand. supervisor. having authority. hostile. teacher. requests or otherwise requires any sexual favor from the other. Sexual Harassment Defined.18.

I am also asking that respondent MJR be held jointly and severally liable with respondent Reyes because when the General Manager. and making statements with unmistakable sexual overtones – all these acts of Rayala resound with deafening clarity the unspoken request for a sexual favor. Lourdes T. Rogelio I. on whether I would still be 2 Ma. Mrs. I asked Mrs. On 1 July 2013. 158700. request or requirement be made as a condition for continued employment or for promotion to a higher position. hindi ko pa kaya. 155840. Mrs. contrary to Rayala’s claim.[Emphasis and 2 underscoring supplied] 19. with equal certitude. giving her money allegedly for school expenses with a promise of future privileges. it is not essential that the demand. GR Nos. 18 February 2008 . Holding and squeezing Domingo’s shoulders. Mary Juvy Reyes. Rayala. Reyes asked me to turn over the company mobile phone and my set of keys to our office. It is enough that the respondent’s acts result in creating an intimidating. from the acts of the offender." But it is not necessary that the demand. It may be discerned. hostile or offensive environment for the employee. Reyes if I could go back to work but she just replied.” Up to now. Likewise. I have not received any advice from either Mrs. Domingo vs. request or requirement of a sexual favor be articulated in a categorical oral or written statement. 155831. instead of taking action. “Wag muna Janice. running his fingers across her neck and tickling her ear. Reyes or the respondent Mr. knew last 28 June 2013 of her husband’s unwelcomed harassing acts toward me. Reyes. having inappropriate conversations with her.of a sexual favor.

The employer or head of office. education or training environment if the employer or head of office. Attorney’s fees in the amount of FIFTY THOUSAND PESOS (Php50. For all the damages I suffered. the amount THOUSAND of TWO PESOS 19. . 19. 21.000. MORAL DAMAGES in HUNDRED FIFTY (Php250.000. 19.required to report for work. educational or training institution shall be solidarily liable for damages arising from the acts of sexual harassment committed in the employment.000.d. educational or training institution is informed of such acts by the offended party and no immediate action is taken.00). I am executing this affidavit to attest to the truth of the foregoing facts and circumstances . Costs of this suit. [Underscoring supplied] 20. it should be held liable as provided in Section 5 of RA 7877: SECTION 5.a. Mr. I am asking that the respondents be jointly and severally liable for: 19. EXEMPLARY DAMAGES in the amount of ONE HUNDRED TWENTY-FIVE THOUSAND PESOS (Php125. Liability of the Employer.00). Educational or Training Institution.b.c. Reyes’ acts and the sexual insinuations of his text messages rendered me to have sleepless nights. To set a good example to the public. wounded feelings. Head of Office.00) and. I found it hard to go to work and lost my enthusiasm in what I was tasked to do because of all these. and serious anxiety especially whenever I was in the office. For the company’s inaction to give redress to my plight.

AFFIANT FURTHER SAYETH NAUGHT. INVESTIGATING PROSECUTOR . for violation of Sections 3(a)(3) and 5. of the Anti-Sexual Harassment Act (RA No. Co.___ JULY 2013. Marikina City. Reyes is concerned.. respectively. JANICE DL.and to establish probable cause and hereby most respectfully request the Investigating Prosecutor to formally file an INFORMATION against the Respondents Marvin Undazan Reyes and MJR Beauty Secret Int’l. punishable under Article 339 of the Revised Penal Code. and any other crime and/or offense in relation thereto. insofar as respondent Mr. TIAMZON Affiant CERTIFICATION SUBSCRIBED AND SWORN TO BEFORE ME this ______day of July 2013 at Marikina City. 7877) and/or Acts of Lasciviousness. and I hereby certify that I have personally examined the affiant and I am satisfied that she has voluntarily executed and understood her affidavit.

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