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Republic of the Philippines

REGIONAL TRIAL COURT


Angeles City, Pampanga
Branch 1, Angeles City

PEOPLE OF THE PHILIPPINES


Criminal Case No: 12345
-versus- For: RAPE (Article 266-A, paragraph 1
of the Revised Penal Code, as amended
Juan Manyak,
Accused.
x------------------------------------x

INFORMATION

The undersigned City Prosecutor accuses Juan Manyak, a resident of


1234 Sampaguita St., Salapungan, Angeles City, Philippines of the crime of
RAPE, defined and penalized under Article 266-A, par. 1, as amended,
committed as follows:

That on January 12, 2019, at the accused’ apartment unit at 1234

Sampaguita St., Salapungan, Angeles City, Philippines, the above-named


accused, did then and there, willfully, unlawfully and feloniously raped the
person of Amanda Paige, by inserting his penis into the complainant’s vagi-
na while the complainant is sleeping/unconscious.
That the accused invited the complainant to drink some beer along
with a few friends to celebrate his promotion and after a few shots the com-
plainant felt dizzy and she decided to lie down on his bed. That the com-
plainant woke up due to the painful sensation in her vagina and there saw
accused undressed and having sexual intercourse with her and due to the

Accused’ superior strength all she was able to do was to clutch tightly and

painfully pull complainant’s hair with his other hand, while he performs the
sexual act.
That the accused placed a kitchen knife directly on the complainant’s
throat and warned her not to tell anyone about the incident or else he would
come back to kill the complainant.
That as a result of said rape, the victim suffered actual and moral
damages in the amount as may be awarded by Honorable Trial Court under
the Provisions of the New Civil Code.

CONTRARY TO LAW.
Angeles City, Pampanga, Philippines, January 18, 2019

Atty. Ivan Manaligod


City Prosecutor

I hereby certify that a preliminary investigation have been conducted


in this case, the witnesses having been examined under oath; that on the ba-
sis of the sworn statement and other evidence submitted before me, there is
reasonable ground to believe that the offense charged was committed.

Subscribed and sworn to before me this 19th day of January 2019, in


Angeles City, Philippines.

WITNESSES:

Rochelle Pangilinan – Angeles City, Philippines


Jopay Paguia – Angeles City, Philippines
Police Chief Inspector Rodrigo C. Dela Cruz- Angeles City Police Station 1,
Philippines
BAIL RECOMMENDED: TWO HUNDRED THOUSAND PESOS (PhP
200,000.00)
APPROVED
City Prosecutor Roll No. 12345
MCLE Compliance No. IV - 000555

Address of Accused: 1234 Sampaguita St., Salapungan, Angeles City, Phil-


ippines

CERTIFICATE OF PRELIMINARY INVESTIGATION

I
I hereby certify that a preliminary investigation in this case was successfully
conducted by me in accordance with law; that I examined the Complainant
and her witnesses; that there is reasonable ground to believe that the offence
charged had been committed and that the accused is probably guilty thereof;
that the accused was informed of the Complaint and the evidences 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.

Atty. Ivan Manaligod


City Prosecutor

SUBSCRIBED AND SWORN TO BEFORE ME this 19th day of January


2019 in Angeles, Philippines.

Atty. Ivan Manaligod


City Prosecutor

Bail Recommended: P200, 000.00


Republic of the Philippines
REGIONAL TRIAL COURT
Angeles City, Pampanga
Branch 1, Angeles City

PEOPLE OF THE PHILIPPINES


Complainant

Criminal Case No: 12345


-versus- For: RAPE (Article 266-A, paragraph 1
of the Revised Penal Code, as amended

JUAN MANYAK
Respondent

X-----------------------------------------------------x

COMPLAINT - AFFIDAVIT

I, Amanda Paige, of legal age, Filipino citizen, Single, residing at 123 Dahlia St.
Baranggay Lourdes Sur, Angeles City, Pampanga, Philippines, after having duly sworn to
in accordance with law do hereby depose and say:

(1) That I am the complainant in this case;

(2) That I am formally charging respondent Juan Manyak, with postal address at no.
1234 Sampaguita St., Salapungan, Angeles City, Philippines, for the crime of
RAPE penalized under Article 266-A, par. 1 of the Revised Penal Code, as
amended, committed as follows, to wit:

(a) That at around 7:00 pm in the evening of Saturday, January 12, 2019, I
was in my apartment at 123 Dahlia St. Baranggay Lourdes Sur, Angeles
City, Pampanga when herein accused called me and said that he was pro-
moted as a training specialist at the BPO company where he works;

(b) That after hearing the news he invited me along with two other friends for
some drinks at his apartment;

(c) That I have known the accused for 3yrs already as he and I worked on a
same BPO company before;

(d) That because of our friendship and trust in his person I complied with his
invitation and at around 8:00pm the same evening we went to a nearby
seven eleven to buy the beers;

(e) That at around 11:00pm after drinking a few bottles of beer I suddenly felt
dizzy and decided to lie down the nearby bed which is the bed of the ac-
cused;

(f) That after falling asleep I felt rather odd sensations around my body but
chose to disregard it because I was dizzy;
(g) That after a few minutes from that incident I felt a searing pain on my vag-
inal area which caused me to wake up;

(h) That after waking up I saw the accused and myself along inside the room
along with my shirt lifted up and my underwear removed;

(i) That the next I saw was the accused on top of me penetrating my vagina
and violently humping me which caused me to struggle;

(j) That because of the accused superior strength I wasn’t able to prevent him
from having carnal knowledge with me;

(k) That after the said incident while I was gathering my clothes he pointed a
knife at my throat while uttering the words that no one should know about
anything that happened that night because if I did he will hurt not only me
but my entire family;

(l) That after the said incident I immediately went to my parents to tell them
what happened;

(m) That despite his threats I came to a decision to file a criminal case against
the Juan Manyak for RAPE.

(3) That I am executing this affidavit to attest to the truth of the foregoing statements,
and for the purpose of charging respondent JUAN MANYAK for the crime of
RAPE penalized under Article 266-A, par. 1 of the Revised Penal Code, as
amended

IN WITNESS WHEREOF, I have hereunto affixed my signature this 19th day of


January 2019, in the City of Angeles.

AMANDA PAIGE
Complaint/Affiant

SUBSCRIBED AND SWORN TO before me this 19th day of January 2019, in


Angeles City.

IVAN MANALIGOD
City Prosecutor

CERTIFICATION

I hereby certify that I personally examined the affiant and that I am satisfied that
he voluntarily executed and understood his complaint-affidavit.

IVAN MANALIGOD
City Prosecutor