REPUBLIC OF THE PHILIPPINES

Regional Trial Court

Branch 24
PASAY CITY

MARA D. RODRIGUEZ,
Complainant, Docket Case No. 101016-001
- versus - For: ACTS OF LASCIVIOUSNESS
KENNEDY F. TERRADO,
Respondent.
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COMPLAINT

COMES NOW, the plaintiff together with the undersigned counsel to this
Honorable Court, respectfully states:
1. That plaintiff, Mara D. Rodriguez, of legal age, Filipino, single and a
resident of Block 8 Lot 67, Villa Antonina San Nicholas II, Bacoor, Cavite.
For purposes of this action, plaintiff may be served with all orders, notices,
and other processes of this Honorable Court through the office address of
the undersigned counsel indicated below;
2. That defendant, Kennedy F. Terrado, of legal age, Filipino, married, and
may be served with summons and other processes of this Honorable Court
at his last known address at 6630 Segundo Street Gatchalian 1 Subdivision
Parañaque City;
3. That plaintiff is an employee of Kimani Wellness Company, located at
RGM Center, El Grande Avenue BF Homes Parañaque City;
4. That defendant is a manager in the said company and plaintiff is under
direct supervision of the defendant;
5. That on September 29, 2016 at around 10:30 in the evening, around the
vicinity of the company, plaintiff after her shift, went to the women’s
locker room to change her clothes;
6. That plaintiff was surprised when defendant opened the door of the
locker room and saw defendant holding a set of keys;
7. That defendant committed acts of lasciviousness on plaintiff by
embracing and kissing her and touching her breasts against her will and by
means of force;
8. That plaintiff kicked defendant on his groin, run and shouted for help;
9. That as a result of the incident, plaintiff suffered psychological and
emotional disturbance, anxiety, sleeplessness and humiliation;

PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of this
Honorable Court that judgement be rendered in favor of the plaintiff and
that after judgement;
a. The defendant shall be ordered to pay plaintiff the amount of P100,
000.00 for moral damages and P50, 000.00 for exemplary damages.
b. The defendant shall be ordered to pay the cost of the suit.
Such further or other relief as may be deemed just or equitable are
likewise prayed for.
Pasay City, Philippines, this 10th day of October 2016.

VERIFICATION AND CERTIFICATION

I, Ms. Mara D. Rodriguez, of legal age, single , Filipino Citizen and a
resident of Block 8 Lot 67, Villa Antonina San Nicholas II, Bacoor, Cavite
after being sworn according to law, hereby depose and state that;
1. I am a plaintiff in the above-stated case;
2. I caused the preparation of the foregoing complaint;
3. I have read the contents thereof and the allegations stated therein are
true and correct of my own knowledge and belief;
4. I have not commenced any other action or filed any claim involving the
same issues in any court, tribunal or quasi-judicial agency and to the best
of my knowledge, no such other action or claim is pending therein;
5. If there is such other pending action or claim, a complete statement of
the present status thereof; and
6. If I should thereafter learn that a similar action or claim has been filed
or is pending, I shall report that fact within five (5) days therefrom to the
court wherein his aforesaid complaint or initiatory pleading has been filed.

Mara D. Rodriguez
Complainant
SUBSCRIBED AND SWORN to me before this 10th day of October, 2016 in
Pasay City, Philippines. I hereby certify that the plaintiff has read and
understood the contents thereof

Atty. Kimberly Sendin

Counsel for the Plaintiff
SENDIN-RATIO LAW OFFICES
Unit 17, Avida Towers
Sucat, Parañaque City