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REPUBLIC OF THE PHILIPPINES )

Province of Laguna )
Municipality of Santa Cruz ) S.S.

COMPLAINT-AFFIDAVIT

I, ROMINA A. ANDRADA, 36 years old, married, and a resident of


Block 30, Lot 11, Ilang-ilang Street, Phase 4, Lynville Subdivision, Brgy.
Calios, Santa Cruz, Laguna after having been duly sworn to in accordance
with law, hereby depose and state THAT:

1. I am the mother of Cassie A. Andrada, 9 years old, enrolled as a


Grade Three Pupil at Santa Cruz Central Elementary School. A
machine copy of the birth certificate of Cassie A. Andrada is
hereunto attached and made as an integral part hereof as Annex
“A”;

2. Last April 19, 2019, on or about 10:30 P.M., my daughter Cassie


A. Andrada with her cousin Rhian A. Bonifacio, 20 years old,
asked for my permission to attend the funeral of their
grandmother, the late Ruby Azucena.

3. Because of the assurance of Rhian that she will be looking and


taking care of Cassie, I allowed them to go ahead of me as I was
also planning of going there and that the place of the wake was
only a few houses away. While I was on my way to the wake, I
heard a commotion at a near distance, which was followed by
shouting and crying so I hurriedly went to the place. Upon my
arrival, I saw my daughter lying in the ground, bathe in her own
blood, with Rhian hoarsely shouting and crying for help. Trembling
and lost for words, I asked Rhian who was the culprit of the crime
which she answered without hesitation as one named Franco B.
Segismundo. I asked her where Franco is and she replied,
“umalis na tita” (he has already fled auntie). Crying for help, I
shouted and begged the people around us to help me bring my
daughter to the nearest hospital which was responded to with
haste by Alan Del Mundo who was around. The sworn statement
of Alan Del Mundo is hereunto attached and made an integral part
of this complaint as Annex “B”;

4. Upon arrival at the Laguna Holy Family Hospital, Dr. Feona


Villanueva, immediately attended my daughter and after a
thorough examination, declared her dead on arrival. The medico-
legal autopsy report and the NSO death certificate from the City
Civil Registrar of Cassie A. Andrada is hereunto attached and
made an integral part of the complaint as Annex “C” and “ D”,
respectively;

5. While at the hospital, I inquired Rhian if the said Franco B.


Segismundo was the same Franco B. Segismundo who is our
neighbor and who came to our house earlier that day to borrow
money from me which she positively identified as the same
person. The sworn statement of Rhian A. Bonifacio is hereunto
attached and made an integral part of this complaint as Annex
“E”;

6. I denied the request of said Franco B. Segismundo because of his


notorious character in our neighborhood as a drunkard, gambler
and without a permanent job and that after the said refusal to lend
money, he mumbled and uttered to me that I would surely regret
my decision which statement I took for granted.

7. I immediately reported the stabbing incident on or about 11:30


P.M. at the Santa Cruz Police Station which is the nearest police
station. The original copy of the excerpt of the police blotter duly
issued by Senior Police Officer Cardo Dalisay of Santa Cruz Police
Station is hereunto attached and made as an integral part hereof
as Annex “F” of the complaint;

8. I am therefore executing this affidavit freely and voluntarily in


support of my intent to file a case for MURDER qualified by
treachery and/or the appropriate criminal case against Franco
Segismundo, who is 35 years of age and a resident of Block 30,
Lot 9, Ilang-ilang Street, Phase 4, Lynville Subdivision, Brgy.
Calios, Santa Cruz, Laguna.

IN WITNESS HEREOF, I hereunto set my hand this 20th day of April,


2019 at Santa Cruz, Laguna.

ROMINA ANDRADA
Affiant

SUBSCRIBED AND SWORN to before me this 20th day of April 2019


at Santa Cruz, Laguna, Philippines and I FURTHER CERTIFY that I have
personally examined the affiant and I am satisfied that he/she has read and
personally understood the contents of her foregoing “Complaint-Affidavit”.

SANTIAGO L. GUERRERO
Prosecutor II
Roll No. 51379-2006
IBP No. 808787-1/3/11
PTR No. 4128464- 1/3/11; Laguna
MCLE Compliance III No. 0013601
ANNEX A
ANNEX B
Republic of the Philippines }
Province of Laguna }
Municipality of Santa Cruz }

AFFIDAVIT OF WITNESS

I, Rhian A. Bonifacio, 20 years of age, single, resident of Block 30, Lot 11, Ilang-ilang
Street, Phase 4, Lynville Subdivision, Brgy. Calios, Santa Cruz, Laguna, after having
sworn in accordance with law, do hereby depose and state THAT:

1. I was present and personally saw that accused, Franco Segismundo, committed
the crime of murder against the victim Cassie Andrada;
2. I was with the victim and we are walking to the direction of Gumamela St.,
because we are going to our grandmother’s funeral when the crime was
committed;
3. Suddenly, a middle-aged man surprised us and stabbed my cousin on the back
using a knife;
4. I was crying during that time when he said, “Dahil yan sa kadamutan ng nanay
mo,” then stabbed again the victim in her left abdomen;
5. I was about to stopped him but he pushed me hardly so that I cannot stand;
6. He stabbed my cousin repeatedly until she became unconscious but
Segismundo stop when he heard someone running on our direction.

I executed this affidavit to attest the truthfulness of the foregoing facts and to
support the filing of Criminal Cases against FRANCO B. SEGISMUNDO for violations of
Murder qualified by treachery.

AFFIANTS SAYETH NAUGHT.

IN WITNESS WHEREOF, I hereunto affixed my signature this 20th day of April,


2019 at, Santa Cruz, Laguna.

RHIAN BONIFACIO

Affiant

SUBSCRIBED AND SWORN to before me this 20th day of April, 2019 at Santa
Cruz, Laguna. I HEREBY CERTIFY that I have personally examined the herein affiant
and I am satisfied that they voluntarily executed and understood their given affidavit.

Notary Public
ANNEX C

HOLY FAMILY HOSPITAL

SANTA CRUZ

MEDICO LEGAL CERTIFICATE

April 20, 2019

TO WHOM IT MAY CONCERN:

This is to certify that Ms. Cassie A. Andrada, 9 years old, with


residence at Block 30, Lot 11, Ilang-ilang Street, Phase 4, Lynville Subdivision, Santa
Cruz, Laguna, was examined and treated in this hospital on April 19,
2019 with the following findings:

-Three (3) stab wounds in the back portion and five (5) stab
wounds in the left abdomen by using a kitchen knife

Issued this 20th day of April 2019, for whatever purpose it may
serve.

This certificate is issued by authority of the Director:

DR. FEONA VILLANUEVA


Consultant-Specialist
ANNEX D
ANNEX E
Republic of the Philippines }
Province of Laguna }
Municipality of Santa Cruz }

AFFIDAVIT OF WITNESS

I, Allan Del Mundo, 25 years of age, single, resident of Block 31, Lot 16, Gumamela
Street, Phase 4, Lynville Subdivision, Brgy. Calios, Santa Cruz, Laguna, after having
sworn in accordance with law, do hereby depose and state THAT:

1. I was present and personally saw that accused, Franco Segismundo, committed
the crime of murder against the victim Cassie Andrada;
2. I was sleeping at my tricycle waiting for passengers in the same place where the
crime was committed;
3. While I was sleeping I heard and saw a child and a woman crying and asking for
help;
4. The incident was so clear to me because of the street lights in the subdivision;
5. I was about to help them but I was not able to do such because I fear for my own
safety;
6. I saw the face of the accused clearly when he was saying something to the child;
7. I saw Segismundo stabbed the victim on the back using a knife.

I executed this affidavit to attest the truthfulness of the foregoing facts and to
support the filing of Criminal Cases against FRANCO B. SEGISMUNDO for violations of
Murder qualified by treachery.

AFFIANTS SAYETH NAUGHT.

IN WITNESS WHEREOF, I hereunto affixed my signature this 20th day of April,


2019 at, Santa Cruz, Laguna.

ALLAN DEL MUNDO

Affiant

SUBSCRIBED AND SWORN to before me this 20th day of April, 2019 at Santa
Cruz, Laguna. I HEREBY CERTIFY that I have personally examined the herein affiant
and I am satisfied that they voluntarily executed and understood their given affidavit.

Notary Public
ANNEX F
REPUBLIC OF THE PHILIPPINES
DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
PROVINCIAL PROSECUTION OFFICE
SANTA CRUZ, LAGUNA

MEMORANDUM
FOR : Provincial Director
Provincial Prosecution Office
Santa Cruz, Laguna
FROM : Chief Of Police
SUBJECT : Spot Report on Stabbing Incident
DATE : April 19, 2019

1. Reference Blotter Entry No. 11-009 dated April 19, 2019.

2. Please be informed that on or about 11:30 pm of this date that a


stabbing incident transpired at the Gumamela Street, Phase 4, Lynville
Subdivision, Brgy. Calios, Santa Cruz, Laguna where in the victim was identified
as Cassie Andrada y Azucena, 9 years old, grade 3 pupil and a resident of Ilang-
ilang Street, Phase 4, Lynville Subdivision, Brgy. Calios, Santa Cruz, Laguna,
while the at suspect was identified as FRANCO SEGISMUNDO Y BANAL, 35
years old, single, drunkard, gambler, and a resident of Ilang-ilang Street, Phase
4, Lynville Subdivision, Brgy. Calios, Santa Cruz, Laguna

3. Investigation conducted disclosed that afternoon on the said date,


FRANCO SEGISMUNDO Y BANAL went to the house of ROMINA ANDRADA Y
AZUCENA to borrow some money but ROMINA refused and after the said
refusal to lend money, SEGISMUNDO mumbled and uttered to ANDRADA that
she would surely regret her decision of not lending him some money which
statement she took for granted. On or about 10:30 P.M., the victim with her
cousin Rhian BONIFACIO Y AZUCENA, asked for ROMINA’S permission to
attend the funeral of their grandmother. While the victim and her cousin RHIAN
was walking going to the direction of Gumamela St., they were unaware of the
presence of the suspect SEGISMUNDO at the stated place of the incident then
stabbed the victim eight (8) times back portion and her left abdomen not
contented he mauled resulting the victim laid on the ground which was witnessed
by her cousin. The suspect walked away from the place of the incident. ROMINA
heard the commotions, she saw her daughter bathe in blood. Upon arrival at the
Laguna Holy Family Hospital, Dr. Feona Villanueva, immediately attended my
daughter and after a thorough examination, declared her dead on arrival.

4. For information.

CARDO DALISAY
SENIOR POLICE OFFICER
MPS Investigation Form No. 01, S. 2008 FOR REGULAR PRELIM INVESTIGATION

REPUBLIC OF THE PHILIPPINES


DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
PROVINCIAL PROSECUTION OFFICE
SANTA CRUZ, LAGUNA

INVESTIGATION DATA FORM

To be accomplished by the Office

DATE RECEIVED: April 20, 2019 NPS DOCKET NO. 11E-03792_______________

(Stamped and initialed) _________________ Assigned to: __________________________

Time received: Date signed: ___________________________

To be accomplished by complainant/s/counsel/law enforcer


(use back portion if space is not sufficient )

COMPLAINANTS RESPONDENT/S
(Name (First/M.I./Last Name), Sex, Age, & Address) (Name (First/M.I./Last Name),Sex,
Age, & Address)

1. Romina Andrada, 36 y/o, married, and a Franco Segismundo, 35 y/o, single, and a
resident of Brgy. Calios, Santa Cruz, resident of Brgy. Calios, Santa Cruz,
Laguna. Laguna.

LAW/S VIOLATED: WITNESS/ES: (Name and address

“Murder” Allan Del Mundo, legal age and a resident of


Brgy. Calios, Santa Cruz, Laguna

Rhian Bonifacio, legal age and a resident of


Brgy. Calios, Santa Cruz, Laguna

DATE & TIME OF COMMISSION PLACE OF COMMISSION


At around 11:30 PM of April 19, 2019 Barangay Calios, Sta. Cruz, Laguna

1. Has a similar complaint been filed before any other office? YES_______ NO___X____
2. Is this complaint in the nature of a counter affidavit? YES________ NO___X_____
If yes, indicate details below.

3. Is this complaint related to another case before this office? YES____NO____X_____

If yes, indicate details below.


I.S. No. _____________________________

Offense _____________________________

Handling Prosecutor _____________________________

CERTIFICATION

I CERTIFY, under oath, that all the information on this sheet are true and correct to the best of my
knowledge and belief, that I have not commenced any action or filed any claim involving the same issues
in any court, tribunal, or quasi-judicial agency, and that if I should thereafter learn that a similar action has
been filed and. or is pending, I shall report that fact to this Honorable Office within five (5) days from
knowledge thereof.

CARDO O. DALISAY

(Signature over printed name)

SUBSCRIBED AND SWORN TO before me this 19th day of April 2019 in Sta.
Cruz, Laguna.