You are on page 1of 3


I, Julia Marie B. Torres, the undersigned, of legal age, and a resident of #69,
Bario Talaan, Lian, Batangas, accuses Ronald D. Galang a.k.a Bato, of
legal age, and resident of #45 Bario Talaan, Lian, Batangas, of the crime of
Rape, committed as follows:

1. At around 11:00PM of Saturday, June 12, 2016, I, Julia Marie B. Torres

was passing by a farm near the house of Mario L. Perez in Bario
Talaan, to my house at #69, Bario Talaan, Lian, Batangas.

2. When I was about fifty meters away from Marios house, Ronald came
from behind asking if he can walk me home.

3. When I declined his offer, he became furious and started cursing me.

4. Because I was frightened with his behavior, I doubled my steps.

However, Ronald caught my arm and wrestled me to the ground.

5. I screamed for help but no one was around the vicinity that night. He
also covered my mouth and pointed a knife threatening to stab me if I
persisted in fighting back.

6. While I was lying on the grass with my legs apart, Ronald drew his
pants down to his knees, and after lifting my skirt and lowering down
my underwear, he inserted his penis into my vagina.

7. Fearing for my life, I could not do anything but to yield to his evil intent.
After satisfying his carnal desires, Ronald once again pointed a knife
and warned me not to tell anyone about what happened or else, he will
kill me and my family.

8. I kept the matter to myself for a while because of the trouble that might
arise if my parents and brothers found out.

9. After two days of worrying and feeling bad, I decided to tell my family
about what happened. Then, we went to the Lian police to file a police
report (Marked as Exhibt A).
10. Thereafter, I submitted myself to medical examination conducted by
Dr. Ampil which corroborated my testimony as his report (Marked as
Exhibt B) showed that I suffered from laceration of the cervix posterior
portion and laceration of the vaginal canal posterior portion which were
about two days old.

11. Based on the foregoing, it is beyond cavil that respondent Ronald D.

Galang committed the crime of rape punishable under Art. 266-A of the
Revised Penal Code. He had sexual intercourse with me through the
use of violence, force, and intimidation.

12. Further, whenever the crime of rape is committed with the use of a
deadly weapon or by two or more persons, the penalty shall be
reclusion perpetua to death.

13. That all these stated herein are true and were stated freely without any
force or intimidation done against me.

14. To attest to the truthfulness of the foregoing, I, Julia Marie B. Torres,

complainant, attaches my signature below.

Julia Marie B. Torres


WHEREFORE, it is respectfully prayed that an information for the

crime of rape be filed against the defendant.

NOW COMES the defendant in the above-entitled case and by his

undersigned counsel, unto this Honorable Court, most respectfully shows:

1. That the defendant ADMITS that he was with the complainant on the
night of June 12 near Marios house but alleges that it was the complainant
who asked him to accompany her in going home.

2. That the defendant ADMITS a particual content of paragraph 7 which

states that he had a carnal knowledge with the complainant but DENIES the
rest of the allegations in paragraphs 4, 5, 6 and 7 of the complaint as said
complainant consented to have sex with him without the attendance of any
force or violence.

3. That the defendant DENIES the content of paragraph 7 which states

that he threatened to kill the complainant and her family but avers that it was
the complainant who threatened him of filing a complaint for rape if the he
will not marry her.

4. That the defendant DENIES the contents of paragraphs 11 and 12 since the
carnal knowledge with the complainant was initiated and consented by the
latter. Therefore, the complaint establishes no cause of action.


WHEREFORE, it is respectfully prayed that the complaint be

dismissed for maliciously imputing a crime against the defendant.