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Republic of the Philippines )

City of Davao . . . . . . . . . . .) S.S.


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AFFIDAVIT–COMPLAINT

I, CRISOSTOMO IBARRA, of legal age and residing at Unit 911, Verdon Parc
Condominium, Ecoland, Davao City, having been duly sworn to in accordance with law,
do hereby depose and say THAT:

1. I am the same and identical person who caused the execution of this instrument;

2. I am filing this Affidavit Complaint before the Office of the City Prosecutor of Davao
in order that Information may be filed against PADRE DAMASO (hereinafter,
“DAMASO” for brevity) of legal age, single, Filipino, and a resident of Block 1, Lot
2, St. Children, Davao City, for violation of the provisions of the Revised Penal
Code, particularly of the crime of PERJURY under Article 183, the ultimate facts
of which are discussed hereinbelow.

3. DAMASO is a long-time acquaintance of mine who wants to be employed in a


public office. In order to do so he made an application before the Civil Service
Commission Regional Office (XI) in order that he may take the Civil Service
Examination on August of 2019.

4. As part of the requirements for said exam, a Civil Service (CS) Application Form
No. 100 entitled Application for Civil Service Examination (hereinafter, “FORM” for
brevity) was filled-out by DAMASO.

5. In the said FORM, on its second page, under subcategory D. Additional


Information, question no. 1, which asked whether he has been found guilty of
crime involving moral turpitude, or of infamous, disgraceful or immoral conduct,
drunkenness or addiction to drugs, or of offense relative to or in connection
with the conduct of a civil service examination, DAMASO answered “NO” by
checking the box, knowing that such statement is false, because he had been
found guilty of a crime involving moral turpitude, particularly, RAPE, decision from
the Regional Trial Court Branch 99, Davao City is attached herewith.

6. Said FORM was made before Atty. Maria Clara De Los Santos of the Civil Service
Commission Regional Office XI, a competent officer duly authorized to receive and
administer oath.

7. The said FORM is required for the purpose of taking the Civil Service Examination
and to obtain eligibility, upon passing said exam, to be employed in public office.

8.

9. I am executing this affidavit – complaint to attest the truthfulness and veracity of


the foregoing statements and for the purpose of filing a criminal complaint against
Padre Damaso for the crime of PERJURY under Article 183 of the Revised Penal
Code and / or such other penal laws as may be justified or warranted by the facts
of this case.

IN WITNESS WHEREOF, I have hereunto set my hand this 5 th day of August 2019 in
Davao City, Philippines.
CRISOSTOMO IBARRA
Affiant

SUBSCRIBED and SWORN TO before me this 5th day of August 2019 at Rizal
Memorial Colleges, Davao City, Philippines, affiant exhibiting to me his LTO Driver’s
License with ID No. 8888 issued by the Land Transportation Office, as competent
evidence of his identity, and he personally acknowledged to me that the foregoing
affidavit-complaint is his free and voluntary act and deed. Machine copy of this LTO ID is
hereto attached.

ATTY. ABC D. EFG


Notary Public
PTR No. 8765432, Davao City, 01/02/17
IBP OR No. 1357911, Davao City, 01/02/17
Attorney’s Roll No. 96321
MCLE Compliance Certificate No. IV-22600499, Davao City, 01/02/17

Doc No. 28;


Page No. 11;
Book No. 7;
Series of 2019.

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