REPUBLIC OF THE PHILIPPINES)

CITY OF MANILA )S.S.

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

COMPLAINT-AFFIDAVIT

I, MALAN DIDAW, of legal age, single, Filipino citizen, with

assistance of counsel, and a resident of 123 Tomorrowland, Plur St.,
Malate, Manila, Philippines, do hereby state under oath that:

1. I am a DJ (disc jockey) and Music Producer based in Manila,

Philippines having just accepted a contract for three (3) years under
It’s Lit Man Productions on April 23, 2016.

2. I accuse and hereby charge MS. TAK LESA, residing at 5

Badroll, Ultra St., Makati, of violating Article 358 of the Revised Penal
Code (Slander and Oral Defamation), committed against me when she
publicly, maliciously and deliberately uttered defamatory remarks
against me.

3. The acts complained were committed as follows:

a. On the evening of May 3, 2016, I had a DJ gig at The

Palasyo Bar in Taguig City. While I was busy spinning
records, Tak Lesa went to the stage and grabbed the
microphone from MC Palo and started uttering “Sarap
maging DJ, right? Is it as good as fucking around with all of
your bosses? Hands to you, girl! You’re really willing to do
anything just to be in the business. You aren’t even that
good! Now that’s what you call a fame whore! Everyone,
let’s give it up for our bad bitch DJ in town!!!”.

b. Other than the fiasco she made, I was informed by my

colleagues in the music industry that there were rumors
circulating about me being the mistress of the President of
the It’s Lit Man Productions, Mr. Music Islife. The said
rumors were purportedly started by Tak Lesa when It’s Lit
Man Productions did not renewed her contract in order to
make room for me in the production company.

4. Ms. Tak Lesa’s remarks, falsely saying that I have illicit sexual
relationships with several married men uttered in public are clearly
insulting and defamatory as they malign me and attribute to me a
criminal act, nature and predisposition. There is, moreover, no doubt
that Ms. Tak Lesa’s malicious spreading of rumors against me was
deliberate as her explanation and clarification a few utterances
thereafter would show. Ms Tak Lesa’s remarks are also very serious
as they cast aspersions on my reputation, line of business, character
and very person before my peers, fans, and fellow artists.

5. Mr. Tak Lesa’s remarks have injured my name, reputation and

character before my colleagues and fans. By reason of the foregoing,
I suffered sleepless nights, wounded feelings, moral and social
embarrassment which Ms. Tak Lesa should compensate by way
of damages which is the natural, proximate and necessary result
of the malicious utterances in the amount of not less than Five
Hundred Thousand Pesos (PhP 500,000.00).

6. While my name, reputation and character are incapable of

pecuniary estimation as these are the result of a lifetime’s effort to build
a name, reputation and character that my future descendants can be
proud to bear, Ms. Tak Lesa cannot be allowed to simply go scot-free
without bearing the consequences of her acts. For this reason, I am
also holding Ms. Tak Lesa liable civilly for defaming me in the
amount of One Million Pesos (P1,000,000.00) in nominal damages
and Five Hundred Thousand Pesos (P500,000.00) in exemplary
damages.

IN WITNESS WHEREOF, I have hereunto affix my signature this

th
14 day of May 2016 in Manila, Philippines.

MALAN DIDAW
Affiant

SUBSCRIBED AND SWORN to before me this 14th day of May

2016 in the City of Manila. I hereby certify that I have personally
examined the above-named affiant and that I am satisfied that the
foregoing statements were given to her voluntarily and of his own free
will.

EDWARD TOGONON
Investigating Prosecutor

Azanith Ann B. Payad

11583371 G04
Counsel
 Republic of the Philippines
REGIONAL TRIAL COURT
Branch 34
Manila City

PEOPLE OF THE PHILIPPINES,

Plaintiff,

Criminal Case No: 12345

For: Slander and Oral
Defamation

-versus-

TAK LESA,
Accused.
X----------------------X
INFORMATION

The undersigned Assistant City Prosecutor accuses TAK LESA, a

resident of 5 Badroll, Ultra St., Makati City, Philippines of the crime of
Slander and Oral Defamation, defined and penalized under Article 358,
of the Revised Penal Code, as amended, committed as follows:

On May 3, 2016 on or about 11:30 in the evening at The Palasyo

Bar in Taguig City, in the presence of more or less a hundred of
person, accused TAK LESA, with the use of a microphone and
within hearing distance of everyone present, unlawfully,
maliciously and feloniously uttered in a serious and insulting
manner at the undersigned complainant the following words:
Sarap maging DJ, right? Is it as good as fucking around with all
of your bosses? Hands to you, girl! You’re really willing to do
anything just to be in the business. You aren’t even that good!
Now that’s what you call a fame whore! Everyone, let’s give it
up for our bad bitch DJ in town!!!, which utterances are serious
and insulting in nature, tending to cause dishonor, discredit and
contempt of complainant and causing her extreme mental
anguish, wound (sic) feelings, besmirched reputation and
serious anxiety for which she is entitled to recover moral and
exemplary damages in an amount to be determined by the
honorable court.

CONTRARY TO LAW.

Manila, Philippines, May 14, 2016

Associate City Prosecutor

I hereby certify that a preliminary investigation has been conducted in
this case, that on the basis of the sworn statement and other evidence
submitted before, there is reasonable ground to believe that the
offense charged

Subscribed and sworn to before me this day of 14 May 2016, in the

City of Manila, Philippines.

CITY PROSECUTOR

Azanith Ann B. Payad

11583371 G04
Counsel