You are on page 1of 9

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
QUEZON CITY, METRO MANILA
PEOPLE OF THE PHILIPPINES
Plaintiff,

- versus -

I.S. No. _____________
For: Rape, under Article 266-A,
Par. 1 of the Revised Penal Code

RAY PEACE
Defendant.
x------------------------------------------x
COMPLAINT
COMES NOW, the complainant, MARIA LEONORA TERESA,
together with the undersigned counsel to this most honorable court, MOST
RESPECTFULLY STATES THAT;
1. The Complainant, MARIA LEONORA TERESA, is of 19 years of
age, Filipino and with residential address at 182 Mabini St., Quezon
City. The Defendant, RAY PEACE, is 30 years of age, with
residential address at 175 Mabini St., Quezon City.
2. On or about 8:00pm, of October 1, 2014, the Complainant, a student
of Mabini College, was on her way home from school.
3. Defendant, of a strong build, was drinking alcohol with a friend in
Aling Nena’s store right in their neighborhood, when the complainant
passed by them.

have carnal knowledge of Complainant. under Article 266-A Par. it is most respectfully prayed of this Honorable Court that after due hearing. premises considered. Defendant did then and there. willfully. to wit: Article 266-A. WHEREFORE. and in using a rock to knock her unconscious. 5. Defendant tried to convince Complainant to drink with them but Complainant refused. b) When the offended party is deprived of reason or otherwise unconscious. 1 of the Revised Penal Code. Rape: When And How Committed. By using a rock. and taking advantage of nocturnity in committing the offense in a dark alley during nighttime. Defendant be judged guilty of the crime of RAPE. Defendant intentionally hit Complainant’s head which immediately rendered Complainant unconscious. threat. through force and without her consent. 8. or intimidation. Defendant then followed Complainant. unlawfully.4. treachery in committing the offense while Complainant is unconscious and unable to defend herself. 6. and feloniously. 7. . Said offense is aggravated by the following circumstances: abuse of superior strength as he is of strong build. despite her resistance. .Rape is committed: 1) By a man who shall have carnal knowledge of a woman under any of the following circumstances: a) Through force. grabbed her arm and dragged her to a dark alley near her house.

2014. 669433/21/12-AC Roll No. I hereby certify that I have examined the affiant and I am satisfied that he has voluntarily executed this Affidavit and that he has read and understood the contents hereof. Philippines. Maricel Carmen A. this 9th of October. and be sentenced to suffer the penalty in accordance with law. 2014 in Quezon City Metro Manila. This complaint is also being execute to support any other charge for any such crime or offense that this Honorable Court may deem appropriate. even though none of the circumstances mentioned above be present. and d) When the offended party is under twelve (12) years of age or is demented. 87263-4/13/12-AC PTR NO. Quezon City. Vitug Counsel for Accused 402 Xavierville Avenue.c) By means of fraudulent machination or grave abuse of authority. with the aforesaid aggravating circumstances. ______________________ Asst. Quezon City IBP NO. City Prosecutor . 98631 SUBSCRIBED AND SWORN to before me this 9 October. Loyola Heights. Atty.

2014 in _________with Driver’s License No. Book No. or any other tribunal or agency. That I have caused the preparation and filing of the foregoing Complaint and I have read all the allegations therein which are true and correct based on my personal knowledge and authentic documents. .VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING I. of legal age. and a resident of 182 Mabini St. That I further certify that there is no pending action or proceeding involving the same issues in the Supreme Court. 2. Court of Appeals. . ______________________________ Affiant SUBSCRIBED AND SWORN TO before me this 9th day of October. Series of 2014. . If I should thereafter learn that the same or similar action is pending. 3. I shall undertake to inform the Honorable Court of this fact within five (5) days therefrom. MARIA LEONORA TERESA. do hereby depose and state: 1. .. No. Notary Public Doc. That I am the Complainant in the above-entitled case. valid until __________ and I hereby certify that I personally examined the affiant herein and that I am fully satisfied that she voluntarily executed the foregoing petition and she understood all the allegations herein. Filipino. Page No. _________. IN WITNESS WHEREOF. Quezon City after having duly sworn to in accordance with law. I have hereunto affixed my signature this 9th day of October 2014 in __________________.

No. under Article 266-A. Quezon City. but I ignored him. Par.01 On the 1st day of October. x------------------------------------------x COMPLAINT-AFFIDAVIT I. Filipino and with residential address at 182 Mabini St.S. . hereby depose and state that: 1. after having been sworn in accordance with law.versus - I. I often see him there with his friend as he was also our neighbor. MARIA LEONORA TERESA. as I was walking inside the neighborhood on my way home from school. 2014. ..REPUBLIC OF THE PHILIPPINES DEPARTMENT OF JUSTICE NATIONAL PROSECUTION SERVICE OFFICE OF THE CITY PROSECUTOR QUEZON CITY. at around 8:00 PM. __________________ For: Rape. METRO MANILA Maria Leonora Teresa Complainant. 1.02 Ray Peace was drinking alcohol with a friend there. He called my name first. 19 years of age. 1 of the Revised Penal Code Ray Peace Respondent. He called me another time and tried to convince me to drink with them but I refused. I passed by Aling Nena’s store.

I still tried to pull away. 1. 1. grabbed my arm and dragged me to a dark alley near our house. I hurried home and told my parents about it. Ray Peace was on top of me. he hit my head.07 When I woke up. Rape: When And How Committed. We went to the nearest police station to report what had happened. He laid me down and by using a rock. despite my resistance.05 When I woke up.03 I quickly walked away from them. . 1. through force and without my consent. had carnal knowledge of me. with abuse of superior strength and treachery.Rape is committed: 1) By a man who shall have carnal knowledge of a woman under any of the following circumstances: . I felt him pulling down my underwear. I still felt dizzy and was unable to move. 2. I am executing this ComplaintAffidavit to charge Respondent Ray Peace. he hit me with the rock again and I fell unconscious. When I tried to fight him. I fell unconscious.1. unlawfully. but he had a strong hold on my arm. but to no avail. he pinned my hands down.04 I was telling him to let me go. Par. I tried to shout for help but he put a handkerchief on my mouth.06 After that. at nighttime. 1 of the Revised Penal Code. and feloniously.01 On the basis of the foregoing. to wit: Article 266-A. who willfully. 1. Ray Peace then followed me. he was already nowhere in site. and eventually had carnal knowledge of me. with the crime of Rape as defined and punished under Article 266-A.

Metro Manila. or intimidation.S. City Prosecutor REPUBLIC OF THE PHILIPPINES ) QUEZON CITY. c) By means of fraudulent machination or grave abuse of authority. Metro Manila. even though none of the circumstances mentioned above be present. . METRO MANILA ) S. b) When the offended party is deprived of reason or otherwise unconscious. IN WITNESS HEREOF. MARIA LEONORA TERESA Affiant SUBSCRIBED AND SWORN to before me this 8 October 2014 in Quezon City. _________________________ Asst.a) Through force. I have hereunto set my hand this 7 October 2014 in Quezon City. 2. and d) When the offended party is under twelve (12) years of age or is demented. threat.02 This affidavit is also being executed to support any other charge for any such crime or offense that this Honorable Court may deem appropriate. I hereby certify that I have examined the affiant and I am satisfied that she has voluntarily executed this Complaint-Affidavit and that she has read and understood the contents hereof.

2. offered her gin and asked her to join us but Maria vehemently refused saying she had to do something and hurriedly left. 3. Teacher’s Village. I have known both of them since childhood since we have been neighbors for a long time. Filipino. at around 8 o’clock in the evening. . 2. of legal age. Commonwealth. 2.01 I am currently a 7th year Nuclear and Biophysics Engineering student at Noynoy Aquino Colleges Foundation. Bawal Tumawid Nakamamatay.AFFIDAVIT I.06 At about 9 pm we left Aling Nena’s store together. I noticed that he was flustered and uneasy. I agreed.01 I execute this affidavit to attest to the veracity of the foregoing and in support of any legal proceedings in connection with the facts mentioned herein.03 After about 2 minutes. with home address 8888 Matimtiman.02 Ray called Maria. Ray told me that he had “to go answer the call of nature” and left. we parted ways. 2. Quezon City. 2014. 2. PIOLO PASCUAL. located at Brgy. Quezon City 1101 Philippines. Maria Leonora Teresa walked by.05 I asked him why he took so long and he told me that he must’ve eaten something bad and was experiencing diarrhea. He walked me home and when we reached my house. He asked me if we could continue our inuman some other time.04 Ray came back after approximately an hour. 2. while I was drinking gin with Ray Peace at Aling Nena’s store.01 On October 1. state under oath that: 1.

______________________ Asst. 2014 in Quezon City Metro Manila. City Prosecutor .PIOLO PASCUAL Affiant SUBSCRIBED AND SWORN to before me this 8 October. I hereby certify that I have examined the affiant and I am satisfied that he has voluntarily executed this Affidavit and that he has read and understood the contents hereof.