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Republic of the Philippines


8th Judicial Region
Branch 23
Allen, Northern Samar



Criminal Case No.

For: Violation of RA 7610
(Child Abuse)

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We, MILDRED CASTILLO and ENER LEDESMA, all of legal age, Filipino
citizens, Husband and wife to each other and residents ofBrgy. San Roque, San
Isidro, Northern Samar, after having been duly sworn to in accordance with law
hereby depose and say:
1. That sometime on April 2010, when the herein complainants were inside
their house at Brgy. San Roque, San Isidro, Nothern Samar, the herein
respondent entered into their parking lot where the motor vehicle
(scooter) Wave 125 was parked, and hit the same using sledge hammer
without any reason, and thereafter, destroyed their electricity
connections using a long bolo;
2. That the herein complainants did not report the circumstances to the
police authorities and even to the Brgy. because the herein respondent is
the brother of herein complainant Mildred, and she dont want to make
things worse between them, so they decided not to charge the herein
3. That on August 15, 2011 around eight oclock in the morning (8:00am),
while the sister of the herein complainant Lynie Kuchar was carrying her
child Kera, the herein repondent threw a big stone to Lynie her child but
because of poor aim, it did not hit Lynie and the child, instead it hit the
glass window of the house which hit the cousin of the herein
complainants named Randing, and then the respondent got near Lynie
and shouted at her saying , Ill be headed you and that child, Youll not
be rich if you did not become a prostitute or hostess;
4. That the herein respondent said that, he will kill the herein complainants
and will behead their children named Shekhiera Lyn Ledesma and
Cherry Rose Ledesma if they go home at Brgy. San Roque, San Isidro,
Northern Samar, attached hereto is the copy of the Brgy. blotter marked
as Annex A;
5. That said acts of the herein respondent endangered and/or impaired the
childs physical and emotional health development;

6. That the above-mentioned acts of the respondent clearly constitute

violation of R.A 7610. (An act providing stronger deterrence and special
protection against child abuse, exploitation and discrimination, and for
other purposes);
7. R.A 7610 provides, Article I, Section 3, paragraph C-"Circumstances
which gravely threaten or endanger the survival and normal
development of children" include, but are not limited to, the following;
(1) Being in a community where there is armed conflict or being
affected by armed conflict-related activities;
(2) Working under conditions hazardous to life, safety and normal
which unduly interfere with their normal development;
(3) Living in or fending for themselves in the streets of urban or
rural areas without the care of parents or a guardian or basic
services needed for a good quality of life;
(4) Being a member of a indigenous cultural community and/or
living under conditions of extreme poverty or in an area which is
underdeveloped and/or lacks or has inadequate access to basic
services needed for a good quality of life;
(5) Being a victim of a man-made or natural disaster or calamity;
(6) Circumstances analogous to those abovestated which
endanger the life, safety or normal development of children;
8. That as shown above, respondents actions were prompted by ill-will,
spite and evil motives, as they were deliberately done to threaten or
endanger the lives of the children;

9. That base on the foregoing, it is clear that the respondent should be

charged with the violation of R.A 7610;

That the complainantsare executing this complaint-affidavit to
attest the truth of the foregoing statements, for the purpose of
instituting criminal procedings against respondent Rochelle Castillo for
the violation of R.A 7610, and any other applicable crimes as maybe
determined by this honorable court.


SUBSCRIBED and SWORN to before me this ___ day of __________, 2015 at
Catarman, Northern Samar. Affiants exhibited to me their ID

competent evidence of their identities.



I HEREBY CERTIFY that I have personally examined the herein affiants

and I am satisfied that they fully understood all the allegations contained in
their herein Complaint-Affidavit and that they voluntarily executed the same.