You are on page 1of 2


In support of his complaint, the herein complainant attached the followingdocuments

;1. Joint Affidavit of Manuel Del Rio and Carla De La Cruz;2. Affidavit of Sgt. Pedro Santiago3. Affidavit of Dr.
Bienvenido Torres
Statement of Facts
Based on the investigation conducted by the Police Investigator, SP02 ENRICOVALENCIA, the facts of the case
are stated hereunder:That on the 24th of December, 2012, in the City of Quezon, National Capital Region,
Philippines and withinthe jurisdiction of this Honorable Court, accused MARINAANGELES Y BARON, with
intent to kill, did then and therewilfully, unlawfully and feloniously attack, slash and stabGINA DEL RIO Y DELA
CRUZ with a bladed weapon,thereby inflicting fatal wounds on the right side of herchest, thus performing all the acts
of execution whichwould have produced the crime of Homicide as aconsequence, but which, nevertheless, did not
producethe same by reason of causes independent of her will,that is, by the timely and able medical assistance

rendered to GINA DEL RIO Y DELA CRUZ , to her damageand prejudice.That the crime was attended by
an aggravatingcircumstance of obvious ungratefulness, accused MARINAANGELES Y BARON, as house
help, fatally stabbed heremployers, Manue
l and Carla del Rio’s, daughter.
CONTRARY TO LAW.In the joint affidavit of witnesses Manuel Del Rio and Carla , they stated thaton December
24, 2012, Gina asked for their permission to attend a party of a friendto which they agreed. Manuel Del Rio
specifically instructed his daughter Gina, thatif she goes home past 8:00 p.m., she should pass through the back door
of theirhouse. At around 7:00 in the evening, Manuel Del Rio arrived home after a meetingand thereafter
instructed his subordinate Sgt. Pedro Santiago to obtain certain filesfor him in Camp Crame. At about
8:55 p.m., Manuel Del Rio received a textmessage from Gina saying that the latter is already within the premises of
house. At 9:01 p.m., Manuel Del Rio heard Sgt. Santiago’s voice
and immediatelyran to the guest room where his wife , Carla De La, was having a massage. The twoimmediately
went down and rushed to scene where they saw Gina lying down andcovered with blood. Manuel immediately
called the police by phone to report theincident. He and his wife then carried Gina to their car and rushed her straight
tothe hospital which was only five (5) minutes away from their house. When theyarrived at the hospital, several
doctors rushed to their aid. The head doctorinformed Manuel Del Rio and Carla De La Cruz that their daughter Gina
was incritical condition, however, her situation would have been more severe if she didnot receive timely medical
intervention.In the affidavit of Sgt. Pedro Santiago, he stated that at 8:45 p.m. of December 24, 2012,
he was resting on the 2nd floor of his superior, Manuel Del
Rio’s house. He was instructed by Manuel Del Rio to proceed to Camp Crame toobtain some documents from the
latter’s office. While going down the stairs, he saw
the light in
the house’s garage was open and heard that there were people talkingin the garage. He recognized Tenorio Palparan
a.k.a. MangTino’s voice (the family’sdriver) “Bakit mo nagawang saksakin si Gina?” When he opened the door, he
sawGina’s body sprawled on
the floor. He also saw Palparan