The undersigned accuses SPO1 SEVERINO TABAYAYAC and all police
officers of Guihulngan City, involved of the crime of HOMICIDE, punishable under Article 249 of the Revised Penal Code, committed as follows:
That on or about the afternoon of 30 August 2016, in the City of
Guihulngan and within the jurisdiction of the Honorable Court, the said accused and his co-police officers while chasing the victims father whom they suspected as a drug lord, did willfully, unlawfully and feloniously opened fire at the victims father who was shot at his back and that the bullet which hit the father passed through his chest and hit the victims spine, causing the death of the victim, ALTHEA FHEM BARBON, four (4) years old, of Guihulngan City, two (2) days or on 1 September 2016 at Negros Oriental Provincial Hospital, CONTRARY TO LAW.
LEILA MARIE V. TRILLANES
Assistant City Prosecutor CERTIFICATE OF PRELIMINARY INVESTIGATION
I hereby certify that a preliminary investigation in this case was
conducted by me in accordance with law; that I examined the complainant; that there is reasonable ground to believe that the offense charged had been committed and that the accused is probably guilty thereof; that the accused was informed of the Complaint and of the evidence submitted against him and was given the opportunity to submit controverting evidence; and that the filing of this Information is with the prior authority and approval of the City Prosecutor.
LEILA MARIE V. TRILLANES
Assistant City Prosecutor
SUBSCRIBED AND SWORN TO BEFORE ME this 20 th day of October 2016