Republic of the Philippines

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
Branch VIII
Muntinlupa City

PEOPLE OF THE PHILIPPINES,

- versus ​- Criminal Case No.: 1098765

FOR: KIDNAPPING AND SERIOUS

ILLEGAL DETENTION

(Under Art. 267 of the Revised Penal

Code)

DAME GROTHEL REYES,

Accused.

x-------------------------- x

JUDICIAL AFFIDAVIT OF QUEEN MOTHER DELA CRUZ

I. Preliminary Information

A. Name and Other Personal Circumstances of the Witness

Name : ​QUEEN MOTHER DELA CRUZ

Age : 50 yrs. Old
Address : ​310 Acacia Ave., Ayala Alabang, Muntinlupa City
Occupation : Business Owner
Language : English, Spanish, Tagalog

B. Lawyer who Conducted the Examination of the Witness

Name : ​ATTY. WILLIAM HARI

Address : Hari Law Office
2121 Madrigal Business Center, Muntinlupa City
Place of : Hari Law Office
Examination 2121 Madrigal Business Center, Muntinlupa City
 II. Offer

The testimony of the witness ​QUEEN MOTHER DELA CRUZ is being

offered to prove the following:
1. The fact that the victim was the lawful daughter of the witness.
2. The fact that the victim was unlawfully taken from the witness in
the latter’s principal residence.
3. The fact that the witness had been searching for the missing
victim for years.

III. Judicial Affidavit Proper

I, QUEEN MOTHER DELA CRUZ, of legal age, born on 14 December 1977 in

Metro Manila, Philippines, married, Filipino citizen, and a resident of 310
Acacia Ave., Ayala Alabang, Muntinlupa City, Philippines, after having been
duly sworn in accordance with law, do hereby depose and state:

1. Q: Please state your name, age, residence, and occupation.

A: My name is Queen Mother Dela Cruz, 50 years old, a resident of 310
Acacia Ave., Ayala Alabang, Muntinlupa City, and a business owner.

2. Q: Why are you here now?

A: I was invited to give a sworn statement by way of affidavit and
testify that I am the mother of the victim Princess Dela Cruz, also
known as Rapunzel.

3. Q: Please state the name and address of the lawyer who is now
conducting or supervising your examination and the place where the
examination is being held.
A: Atty. William Hari of the Hari Law Office at ​2121 Madrigal Business
Center, Muntinlupa City.

4. Q: In what language do you want your examination to be conducted?

A: The examination is being conducted in English, a language that I am
most familiar with.

5. Q: Do you undertake to answer the questions to be asked of you, fully

conscious that you will do so under oath, and that you may face
criminal liability for false testimony or perjury?
A: Yes.
6. Q: Let us now proceed. Why are you testifying in this case?
A: I am testifying in this case to narrate what happened during the
kidnapping of my daughter, as well as to the events that happened
thereafter.

7. Q: How are you related to the alleged victim, Rapunzel?

A: I am her biological mother. ​(Authenticated birth certificate attached
as Exhibit A)

8. Q: When and where was the last time you saw your daughter?
A: It was around 10:30 in the evening of March 14, ​2008. I tucked her
in bed and after realizing that she is already sleeping soundly. I went
downstairs to make a phone call to my business partner.

9. Q: Why did you leave your daughter alone in the room?

A: She was already sleeping soundly and I had to make a phone call.

10. Q: What time did you return to the room?

A: After some 20 to 30 minutes, I went back to my room. To my
surprise, my daughter was already missing. The window was also left
open.

11. Q: What did you do after you realized that your daughter was
missing?
A: I went hysterical. I went to the opened window and saw a woman
dressed in black holding my crying infant. She was running away. I
called all the helpers immediately.

12. Q: Were you able to catch the culprit?

A: No. There was a car already waiting across our house. The woman
went inside the car and the car drove away very fast.

13. Q: What happened after that?

A: We went to the head of security of Ayala Alabang. They advised us to
go the police station to formally report what happened.

14. Q: What happened at the police station?

A: I filed a complaint and was issued a police report. ​(Attached police
report is marked as Exhibit B)

15. Q: How certain are you of what you saw that night?
A: I am very certain because I will never forget that night. We also had
CCTV at home and we were able to catch the face of the suspect who is
Dame Grothel Reyes’s face. ​(Attached CCTV footage is marked as Exhibit
C)
 16. Q: How sure are you that the daughter you are referring to here is
the one that was taken from you?
A: My daughter has a red birthmark in her left cheek just like the one
on Rapunzel’s face. ​(Attached copy of pictures of Princess Dela Cruz
a.k.a. Rapunzel is marked as Exhibit D)

17. Q: How were you able to find your daughter?

A: After almost 10 years of trying to find clues, were informed by the
police of a certain girl that has been allegedly locked in a house with
neither stairs nor doors in Alabang Hills Subdivision. In less than 12
hours after informing us, the girl was rescued and she had the
birthmark that we were looking for.

18. Q: Do you have anything else to add?

A: No.

I have nothing further.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 15th day

of ​March 2018​ at ​Muntinlupa City​, Philippines.

​Queen Mother Dela Cruz

Affiant

SUSCRIBED AND SWORN to before me this ​15th day of March 2018​, affiant
exhibiting to me her Passport no. 12345 issued at DFA Manila, Philippines on
20th of December 2017.

ATTY. CHARLOTTE PRINCESA

NOTARY PUBLIC
Unit 152, Commercenter, Filinvest, Muntinlupa City
SC Roll No. 247383, May 1990
IBP Lifetime No. 075757, Metro Manila Chapter
PTR No. 1136795, January 3, 2000
MCLE Compliance No. III-031299
Doc. No. 23
Page No. 23
Book No. 23
Series of 2018.
IV. Sworn Attestation of the Lawyer who Conducted the
Examination of the Witness

The undersigned ​ATTY. WILLIAM HARI​, of legal age, married, and with
law office address located at 2121 Madrigal Business Center,
Muntinlupa City, under oath, deposes and states that:

1. He is the Legal Counsel for the Plaintiff in the above-entitled case;

2. He faithfully recorded or caused to be recorded the questions he

asked and the corresponding answers that the above-named
witness gave;

3. Neither he nor any other person then present or assisting him

coached the witness regarding the latter’s answers; and

4. He conducted the examination of the witness at his law office

WILLIAM HARI LAW OFFICE ​located at 2121 Madrigal Business
Center, Muntinlupa City

Muntinlupa City, 2018.

ATTY. WILLIAM HARI

Affiant

SUBSCRIBED and SWORN to before me, this 15​th day of March

2018 at Muntinlupa City, personally appeared WILLIAM HARI ​with LTO
Driver’s License No. IR7890123 to expire on 27 October 2018. I further
certify that I personally examined the affiant and I am satisfied that he
fully understood and voluntarily executed the foregoing attestation.

Witness my hand and seal.

 ATTY. CHARLOTTE PRINCESA
NOTARY PUBLIC
Unit 152, Commercenter, Filinvest, Muntinlupa City
SC Roll No. 247383, May 1990
IBP Lifetime No. 075757, Metro Manila Chapter
PTR No. 1136795, January 3, 2000
MCLE Compliance No. III-031299

Copy Furnished by personal service:

Doc. No. 23
Page No. 23
Book No. 23
Series of 2018.